LCD Reference Article Response To Comments Article

Response to Comments: Nerve Conduction Studies and Electromyography

A55432

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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
A55432
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Article Title
Response to Comments: Nerve Conduction Studies and Electromyography
Article Type
Response to Comments
Original Effective Date
03/06/2017
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The following are comments received by CGS Administrators during comment period, 11/16/2016 to 01/03/2017, for DL35897 Nerve Conduction Studies and Electromyography.

Response To Comments

Number Comment Response
1

We find the policy comprehensive and well researched . We would like CGS Administrators to consider the following revisions and recommendations below. In the Coverage Indications , Limitations and/or Medical Necessity section please add the following language: Electrodiagnostic Lab Requirements CGS Administrators expects electrodiagnostic laboratories to ad here to a minimum standard of quality, such as that offered by the American Association of neuromuscular and Electrodiagnostic Medicine (AANEM) Laboratory Accreditation Program . The AANEM developed the Electrodiagnostic Laboratory Accreditation Program to identify and acknowledge electrodiagnostic laboratories for achieving and maintaining the highest level of quality, integrity and patient safety. Accreditation of an electrodiagnostic laboratory i s a voluntary, peer review process that assesses the expertise of the staff, evaluates the policies and procedures utilized , and ensures the safety of the laboratory and equipment to improve accuracy and reliability of the electrodiagnostic testing and the patient care being provided. CGS Administrators expects al l electrodiagnostic laboratories to be accredited by AANEM by 2018.

CGS agrees in theory with this comment. CGS agrees that accreditation is very important to ensure the quality of service provided to the Medicare beneficiary. However, CGS is not able to limit the accreditation to just one agency. CGS will make sure the language is strong and clear that accreditation by a Nationally recognized organization is required.
2 In the paragraph that states "Th e only exception to this is a situation when a provider may consider it appropriate to perform a CS without doing an EMG for the diagnosis of carpal tunnel syndrome. . ." the AANEM recommends changing the wording that allows carpal tunnel to be the only exception. Thanks for the suggestion,but no changes will be made at this time
3 There have been increasing reports of physicians not receiving reimbursement for nerve conduction studies in these instances. Patient refusal of an EMG test should not result in a qualified physician not receiving reimbursement for the portion of the plan of care performed and agreed upon by the patient. AANEM recommends that blanket statements refusing payment of NCS when an EMG is not performed be avoided, and instead allow for specific exceptions (e.g., carpal tunnel) and in situations where "the patient's medical record supports the decision to perform NCS testing alone, such as in instances of patient refusal". Medicare does not allow for reimbursement for any procedure that is not performed.
4 Commenter requests that CGS Administrators consider the following revision in the ICD-10 Codes that Support Medical Necessity section. A05.0, A05.2-A05.5, A05.8-A05.9, A30.0-A30.5, A30.8-A30.9, A33, A34, B02.23, B92, C49.9, D21.9, D48.1, E25.0, E25.8, E74.01-E74.04, E74.09, F44.4, F44.6, F44.9, F45.42, F65.81, F66, G04.90-G04.91, G21.0, G21.11, G21.19, G21.2-G21.3, G21.8-G21.9, G23.0-G23.2, G23.8-G23.9, G25.0-G25.1, G25.3, G25.82, G31.9, G31.85, G40.001, G40.009, G40.101, G40.109, G40.111, G40.119, G40.201, G40.209, G40.211, G40.219, G40.301, g40.309, G40.311, G40.319, G40.A01,G40.A19, G40.A11, G40.A19, G40.401, G40.409, G40.501, G40.509, G40.801-G40.804, G40.811-G40.814, G821-G40.824, G40.89, G40.901, G40.909, G40.911, G40.919, G43.001, G43.019, G43.111, G43.119, G43.401, G43.409, G43.411, G43.419, G43.501, G43.509, G43.511, G43.519, G43.601, G43.609, G43.611, G43.619, G43.701, G43.709, G43.711, G43.719, G43.A0, G43.A1, G43.B0, G43.B1, G43.C0, G43.C1, G43.D0, G43.D1, G43.801, G43.809, G43.821, G43.829, G43.831, G43.839, G43.901, G43.909, G43.911, G43.919, G50.9, G51.1, G51.9, G52.0, G54.9, G58.9, G62.9, G81.91, G82.20, G82.50, G83.9, G90.1, G90.3, G90.9, G92, G93.0-G93.2, G98.8, H55.00, H55.02-H55.04, H55.09, H55.81, H55.89, I67.81-I67.83, I67.841, I67.848, I67.89, I73.9, I95.0, I95.89, M15.3, M15.9, M19.011, M19.012, M19.021, M19.022, M19.031, M19.032, M19.041, M19.042, M19.071, M19.072, M21.41, M21.42, M25.511, M25.512, M25.521, M25.522, M25.531, M25.532, M25.551, M25.552, M25.561, M25.562, M25.571, M25.572, M25.78, M31.6, M32.10, M33.20, M33.90, M43.21-M43.28, M46.48, M46.49, M47.891-M47.898, M50.021-M50.023, M50.03, M50.10, M50.80, M50.81, M50.821-M50.823, M50.83m M50.90-M50.93, M51.9, M53.2X7, M53.3, M53.84, M53.85, M53.9, M54.5, M54.9, M60.9, M62.28, M62.838, M65.011, M65.012, M65.021, M65.022, M65.031, M65.032, M65.041, M65.042, M65.051, m65.052, M65.071, M65.072, M65.08, M65.311, M65.312, M65.321, M65.322, M65.341, m65.342, M65.351, M65.352, M65.4, M65.811, M65.812, M65.821, M65.822, M65.831, M65.832, M65.841, M65.842, M65.851, M65.852, M65.861, M85.862, M65.871, M65.872, M65.88, m65.89, M71.9, M72.9, M75.31, M75.32, M75.41, M75.42, M75.81, M75.82, M79.0, M79.2, M79.89, M93.211, M93.212, M93.221, M93.222, M93.231, M93.232, M93.241, M93.242, M93.251, M93.252, M93.261, M93.262, M93.271, M93.272, M93.28, M93.29, M96.1, M99.26, N31.9, N32.81, O26.821-O26.823, O90.89, Q07.8, Q76.2, R06.00-R06.02, R06.09, R26.2, R29.3, R29.6, R29.810, R29.818, R29.891, R40.0, R40.1, R40.20, R40.4, R47.01, R53.2, R55, S04.71X, S04.72X, S24.143, S24.144, S64.498, S99.811, S99.812, S99.821, S99.822, T75.4XX After consultation with our SME’s, we believe that our LCD has the diagnoses that are Medically Necessary for this service. Many of the codes in your list are in the LCD already. Thanks for the comment.
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Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
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