Neurology & Pain Management Coding Alert

HCFA has released Program Memorandum No. B-01-28, dated April 19, 2001, outlining the supervision rules for more than 700 diagnostic tests. The memo, effective July 1, 2001, assigns specific levels of physician supervision required for neurological diagnostic tests payable under the Medicare physician fee schedule. The levels include general, direct and personal supervision. The delay in implementation is intended to allow physical therapists (PTs) (for those practices where physical therapists perform some of the diagnostic tests) time to acquire the necessary certification from the American Board of Physical Therapy Specialties (ABPTS) to perform those services without supervision.

The regulation defines these levels as follows:

General supervision means the procedure is furnished under the neurologists overall direction and control, but the neurologists presence is not required during the procedure. The training of the nonphysician personnel who performs the diagnostic procedure and the maintenance of the necessary equipment and supplies is the continuing responsibility of the neurologist.

Direct supervision in the office setting means the neurologist must be present in the office suite and immediately available to furnish assistance and direction throughout the procedure. It does not mean that the neurologist must be present in the room.

Personal supervision means a neurologist must be in the room during the performance of the procedure. Neurology coders should note that effective July 1, 2001, certain codes in the 95860-95937 range will have new supervision levels (either 21, 22, 6a, 66, or 77a).

Coding With New Supervision Levels

1 = Procedure must be performed under the general supervision of a neurologist, which means that the procedure is furnished under the neurologists overall direction and control but the neurologists presence is not required during the procedure. The training of the nonphysician personnel who performs the diagnostic procedure and the maintenance of the necessary equipment and supplies is the continuing responsibility of the neurologist. For example, an EEG performed only during sleep would be performed under neurologist direction and control. This is coded as 95822.

2 = Procedure must be performed under the direct supervision of a neurologist in the office setting, which means a neurologist must be present in the office suite and immediately available to furnish assistance and direction throughout the procedure. It does not mean that a neurologist must be present in the room. For example, testing of the autonomic nervous system function with cardiovagal innervation would be performed with a neurologist available in the office suite. This is coded as 95921.

3 = Procedure must be performed under the personal supervision of the neurologist, which means the neurologist must be in the room during the performance of the procedure. For example, functional cortical and subcortical mapping performed to provoke seizures [...]