Neurology & Pain Management Coding Alert

Question: Our practice wants to hire a neuro-physiologist who has a PhD, but not an MD, to perform EMG and NCS in the office. What are the supervision requirements? Does a physician have to be in the room while the neurophysiologist performs the testing?

Arizona Subscriber Answer: Medicare supervision requirements differ for electromyography (EMG, 95860-95872) and nerve conduction studies (NCS, 95900-95904), but in each case you probably cannot bill for a neurophysiologist conducting the tests.
 
A physician must personally provide an EMG study, according to Medicare supervision guidelines as explained in Program Memorandum B-01-28 (April 19, 2001). The guidelines do allow a physical therapist (PT) certified as a qualified electrophysiologic clinical specialist by the American Board of Physical Therapy Specialties (ABPTS) to perform the tests without physician supervision, but make no provision for billing by other nonphysician practitioners (NPPs).
 
For NCS, a PT with ABPTS may perform the procedure alone, or a PT without ABPTS may provide the test under the physician's direct supervision. Direct supervision requires that the neurologist be present in the office suite and immediately available to furnish assistance and direction throughout the procedure. The neurologist does not have to be in the same room. Again, however, the guidelines make no provision for other non-physician practitioners, such as those with PhDs.
 
The above are CMS guidelines: Rules governing supervision requirements and scope-of-practice for nonphysician practitioners vary. Be sure to check with other payers directly for their policies and with your state laws for scope-of-practice limitations.