Neurology & Pain Management Coding Alert

Reader Question:

Physician Supervision Requirements

Question: I am still confused by the new supervision requirements for electrodiagnostic studies. We have an RN who performs the technical component of codes 95900, 95903 and 95904. She was trained by our neurologist but has no formal training or certification. Can she perform these studies? And if so, what level of supervision is required?

Indiana Subscriber
 
 
Answer: According to CMS Memorandum B-01-28 (Physician Supervision of Diagnostic Tests, change request 850), dated April 19, 2001, and effective July 1, 2001, both the technical and professional components of nerve conduction studies (95900-95904) may be performed by a registered nurse (RN) or other nonphysician practitioner under the direct supervision of a physician. The memo specifies, Direct supervision in the office setting means the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. The physician does not need to be present in the room when the procedure is performed.
 
A technician under the general supervision of a physician may also provide the technical component of these tests, but the physician must provide the professional component. General supervision, the memo specifies, means the procedure is furnished under the physicians overall direction and control, but the physicians presence is not required during the performance of the procedure. The training of the person who performs the diagnostic procedure and the ongoing maintenance of the equipment and supplies necessary to conduct the tests are the continuing responsibility of the physician.
 
In addition, certain codes in the 95860-95937 range include new supervision levels to make it possible for physical therapists to acquire the certification necessary to perform the services without supervision. According to these new guidelines, nerve conduction studies may be provided without supervision by a physical therapist with ABPTS certification. This certification also allows them to supervise personally another physical therapist performing the procedure, but only the former may bill. Personal supervision means the physician (or, in this case, the certified physical therapist) must be in the room when the procedure is performed.
 
Note: For more information on supervision requirements, see the June 2001 issue of Neurology Coding Alert.
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