LCD Reference Article Response To Comments Article

Response to Comments: Nerve Conduction Studies and Electromyography

A54991

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Draft Articles are works in progress and not necessarily a reflection of the current billing and coding practices. Revisions to codes are carefully and thoroughly reviewed and are not intended to change the original intent of the LCD.

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Source Article ID
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Article ID
A54991
Original ICD-9 Article ID
Not Applicable
Article Title
Response to Comments: Nerve Conduction Studies and Electromyography
Article Type
Response to Comments
Original Effective Date
06/01/2016
Revision Effective Date
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Article Text
Noridian's response to provider recommendations for comment period ending 11/26/2013.

Note: Comments and responses are those received for both JFA DL34111 and JFB DL33984. Both draft LCDs were retired and finalized under L36526.

Response To Comments

Number Comment Response
1 Several comments received from associations representing Physical Therapists and from individual Physical Therapists expressed concern that the draft LCD excluded licensed, qualified and experienced Physical Therapists from performing both the technical and professional components of EMG and NCV services. CMS Transmittal No. B-01-28 Change Request #850 of April 2001; CMS Transmittal 1725, Change Request 1756 of September 27, 2001; CMS Transmittal 2287 of August 26, 2011; CMS Transmittal 2663 of March 4, 2013 and the CMS Benefit Policy Manual, Chapter 15, Section 80 were referenced in support that this is incorrect and should be changed. The LCDs have been made explicitly consistent with the most to-date CMS instructions. Physical Therapists meeting the indicated criteria may perform the specific services indicated by the CMS Physician Supervision of Diagnostic Procedures Indicators (see pp. 4-5 of the LCD).
2 Several physicians expressed the contrary concern that Physical Therapists certified by the ABPTS are expressly trained in the technical component of the services but should not be permitted to perform interpretations (professional component). The LCDs have been made explicitly consistent with the most to-date CMS instructions. Physical Therapists meeting the indicated criteria may perform the specific services indicated by the CMS Physician Supervision of Diagnostic Procedures Indicators (see pp. 4-5 of the LCD).
3 One comment indicated there are some specific state statutes with educational requirements for a PT to perform EMG & NCS examinations. Medicare always incorporates compliance with state licensing and other regulatory requirements as a condition of performing a Medicare service.
4 Two commenters noted inconsistencies between JF Draft DL33984 and current JE LCD L33476. The policy in Draft LCDs DL34109 for JE and DL33984 for JF are now identical. Only the Jurisdiction identifying language is different.
5 A manufacturer of botulinum toxin and others pointed out confusion that may arise between these LCDs and instructions and criteria located in the LCDs for “Botulinum Toxin Types A and B” (currently LCD L35170 for JE and L35172 for JF) where add-on codes 95873 and 95874 are addressed. The language in the section ”ICD-10 Codes that Support Medical Necessity” of these LCDs, clarifies under both “Group 1” and “Group 2” that “These diagnosis codes do not apply to codes 95873 or 95874.” Additionally, language is being added to these LCDs referencing the separate LCDs for “Botulinum Toxin Types A and B.” At a future revision of the LCDs for “Botulinum Toxin Types A and B” consideration will be given to possible further references to or other coordination with these LCDs for NCV and EMG. Noridian has been coordinating with other Medicare Administrative Contractors to try to keep these LCDs for NCV and EMG as near-identical as possible across jurisdictions nationally. Recommendations on other means of achieving these separate but related objectives, will continue to be welcome.
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Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
Related Local Coverage Documents
LCDs
L36526 - Nerve Conduction Studies and Electromyography
Related National Coverage Documents
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SAD Process URL 1
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SAD Process URL 2
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Statutory Requirements URLs
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Rules and Regulations URLs
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CMS Manual Explanations URLs
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Public Versions
Updated On Effective Dates Status
04/09/2016 06/01/2016 - N/A Currently in Effect You are here

Keywords

  • nerve
  • conduction
  • studies
  • NCS
  • NCV
  • EMG