Wiki ? regarding split billing of EEG interpretation from polysomnography study.

[maganr]

Does anybody have any substantial information in writing regarding the fact that you cannot bill the EEG interpretation separate from the PSG study as the EEG interpretation is included in the PSG study?

I've already presented the NCCI edits reflecting these code pairs as bundled but apparently this is not substantial enough!

My employer is having a hard time understanding that there is an EEG included with the PSG study and that it should not be billed separately. There stance is because a pulmonary doctor is billing for the PSG with a TC modifier and a neurologist is billing for the EEG with a 26 modifier that they are independent of one another and thus ok but I disagree as their EEG documentation states "EEG for PSG".

Any help would be greatly appreciated!

Thanks, Magan R

 

[mhstrauss]

Does anybody have any substantial information in writing regarding the fact that you cannot bill the EEG interpretation separate from the PSG study as the EEG interpretation is included in the PSG study?

I've already presented the NCCI edits reflecting these code pairs as bundled but apparently this is not substantial enough!

My employer is having a hard time understanding that there is an EEG included with the PSG study and that it should not be billed separately. There stance is because a pulmonary doctor is billing for the PSG with a TC modifier and a neurologist is billing for the EEG with a 26 modifier that they are independent of one another and thus ok but I disagree as their EEG documentation states "EEG for PSG".

Any help would be greatly appreciated!

Thanks, Magan R

Where do they get these ideas from?!
So, a couple questions...if the pulm MD is billing the tech part of the PSG, and the neuro MD is billing only the prof EEG...who is billing/interpreting the prof part of the PSG? If the neuro is doing the entire interp of the entire PSG, then (s)he neeeds to bill the PSG with mod 26. Is there a 3rd MD (sleep specialist maybe?) that is interpreting the remainder of the PSG (minus the EEG)? If yes, I would expect him to interpret the entire test. But if not...I guess the other option would be for the neuro to bill the EEG, and the sleep specialist to bill the PSG, with a mod 52 ??

 

[maganr]

Where do they get these ideas from?!
So, a couple questions...if the pulm MD is billing the tech part of the PSG, and the neuro MD is billing only the prof EEG...who is billing/interpreting the prof part of the PSG? If the neuro is doing the entire interp of the entire PSG, then (s)he neeeds to bill the PSG with mod 26. Is there a 3rd MD (sleep specialist maybe?) that is interpreting the remainder of the PSG (minus the EEG)? If yes, I would expect him to interpret the entire test. But if not...I guess the other option would be for the neuro to bill the EEG, and the sleep specialist to bill the PSG, with a mod 52 ??

Unfortunately its sounding like the compliance department told them to do it this way! That's the thing nobody is billing the PSG code for the professional portion! Apparently they increased the fee on the technical side to cover both? I am now being told that the EEG being performed during the PSG for sleep staging is sometimes "augmented" and that additional leads are placed to use for a separate purpose i.e. to capture abnormal CNS activity and this is why they are billing the EEG separate. This still does not sound right to me. Have you ever heard of this before? I found the below Excerpt from the 1996 CPT assistant...

Can I report code 95816 for an EEG study with 95808, Polysomnography?

AMA Comment

Yes, when the two studies are performed independently of one another. Polysomnography requires at least one central and usually several EEG electrodes. The EEG used during polysomnography differs from that performed for separate diagnostic purposes. However, do not use the EEG code to report the EEG recording component of the sleep study. Code 95808 includes this type of EEG monitoring. If a full EEG study is done separately from the EEG parameters obtained during the sleep study, it may be reported on the same date of service.

I don't think what they are doing constitutes a "separate study"? Separate study to me would mean an EEG performed at a different time other than during the PSG study. I am thinking that they should start billing out the PSG code with a 26 modifier even when they are "augmenting" the EEG. If after doing this study the patient is found to have abnormal CNS activity then another EEG can be performed and billed. Maybe its because these are being done on children and they are trying to alleviate stress on them by not performing two separate EEGs? It just seems shady to me...

Any thoughts on this?


Thanks for responding!!!

Magan

 

[mhstrauss]

Unfortunately its sounding like the compliance department told them to do it this way! That's the thing nobody is billing the PSG code for the professional portion! Apparently they increased the fee on the technical side to cover both? I am now being told that the EEG being performed during the PSG for sleep staging is sometimes "augmented" and that additional leads are placed to use for a separate purpose i.e. to capture abnormal CNS activity and this is why they are billing the EEG separate. This still does not sound right to me. Have you ever heard of this before? I found the below Excerpt from the 1996 CPT assistant...

Can I report code 95816 for an EEG study with 95808, Polysomnography?

AMA Comment

Yes, when the two studies are performed independently of one another. Polysomnography requires at least one central and usually several EEG electrodes. The EEG used during polysomnography differs from that performed for separate diagnostic purposes. However, do not use the EEG code to report the EEG recording component of the sleep study. Code 95808 includes this type of EEG monitoring. If a full EEG study is done separately from the EEG parameters obtained during the sleep study, it may be reported on the same date of service.

I don't think what they are doing constitutes a "separate study"? Separate study to me would mean an EEG performed at a different time other than during the PSG study. I am thinking that they should start billing out the PSG code with a 26 modifier even when they are "augmenting" the EEG. If after doing this study the patient is found to have abnormal CNS activity then another EEG can be performed and billed. Maybe its because these are being done on children and they are trying to alleviate stress on them by not performing two separate EEGs? It just seems shady to me...

Any thoughts on this?


Thanks for responding!!!

Magan

Yes, definitely doesn't sound right. The funny thing is, usually when MD's want to bill a different code, they try to make an argument of why they deserve a higher reimbursement. In this case, the reimbursement is lower!! Point that out to them!

So IMO, I agree with the part I underlined from your post. And if an independent EEG is warranted, there definitely needs to be enough documented to meet medical necessity.

So other issue...you said that they increased the charge of the TC portion to cover both. BUT a payer is only going to pay "X" amount for the TC, regardless of the charge amount on the claim. Are these providers all part of the same practice? Someone is definitely losing money.