After more than 20 years since the last time long-term EEG procedures were reviewed, the AMA and CMS have assessed and revised the CPT® coding for long-term continuous recording EEG procedures. Through a long-established process of accepting and reviewing comments and holding direct meetings with a number of groups directly affected by the changes, such as the AES, ACNS, NEAC, AAN, ASET and several service providers, including CortiCare, Inc. CMS published its final rule for the Physician Fee Schedule (PFS) November 15[i]. This is a summary of the changes that cover the Professional Component and are in full effect on January 1, 2020.
Those changes include:
The first point is that the new procedure codes separate the technical activities related to the delivery of long-term EEG studies from the professional activity of reviewing, reading and reporting the results of the studies. One set of codes for the technical procedure and a separate set of codes for the professional reporting of results. Before January 1, 2020, all studies were reported using 95951 and the technical or professional designations of -TC or -26. Now the technical portion is reported based on the duration of the study, the inclusion of video in the study, and the level of EEG technologist monitoring of the study. The professional component is coded according to the length of the study and whether the physician provides a daily review and report of a multiday recording or just provides a single final report at the end of the recording period.
A second point is that there is no Place of Service requirement for these new technical service codes. This recognizes that the technical advances over the last 20 years have made it practicable to provide long-term continuous EEG recordings in almost any location, including ambulatory EEG with video recording, remotely monitored in the patient’s home. The same technical codes are used for studies performed in the Epilepsy Monitoring Unit or Critical Care Unit of the hospital, an Independent Diagnostic Testing Facility (IDTF), a physician’s office or the patient’s home.
The new set of Professional Component Codes replace the one previous code 95951-26 and new code that is applied is based on three factors: EEG study with or without digital video, duration of recording and whether the physician reviews and generates a daily report on a multiday recording or only reviews the study at the end of the recording and generates one final report (see Figure 2. Sourced from the NAEC).
Long-Term EEG Codes (PROFESSIONAL Services)
|Recording Type||2 to 12 hours recording|
Typically 8 hours
|12 to 26 hours recording|
Typically 24 hours
|36 to 60 hours recording|
Typically 2 days
|60 to 84 hours recording|
Typically 3 days
|Greater than 84 hours recording|
Typically 4 days
|EEG w/ video||95718||95720||95722||95724||95726|
When billing for services, codes 95717 through 95720 require physical access to the data (EEG with or without video) during the recording. They require the generation of a daily report and a final summary report at the end of the study. 95717 and 95718 may be applied once during a multiday recording if a period of fewer than 12 hours is part of the total duration of the recording.
In cases where the physician does not have real-time access during a multiday study (for example an ambulatory EEG study that is not monitored), the study is reviewed and a report is generated after the study is concluded, then Codes 95719 to 95726 are used depending on the length of the study (note 95719 and 95720 may be used for only a 12 to 26-hour recording, studies lasting more than [SH1] 26 hours but less than 36 hours are billed by adding on the appropriate 2 to 12 hour codes 95717 or 95718).
The changes were predicated by a significant increase in the use of the procedure code for long term video-EEG, 95951. In November 2016, CPT code 95951 was identified via the High-Volume Growth screen with total Medicare utilization of 10,000 or more and increased by at least 100% from 2009 through 2014.[ii] The American Medical Association (AMA)/Specialty Society RVS Update Committee (RUC) submits the enclosed recommendations for work relative values and direct practice expense inputs to the Centers for Medicare and Medicaid Services (CMS). The RUC recommended that the long-term video-EEG service be referred to the CPT Editorial Panel for needed changes, including code deletions, revision of code descriptors, and the addition of new codes to this family. Revisions to this family of codes are needed to capture that video is now an element of most long-term EEG monitoring tests and to better differentiate inpatient and ambulatory monitoring services. In May 2018, the CPT Editorial Panel approved the revision of one code, deletion of five codes, and the addition of twenty-three codes for reporting long-term EEG professional and technical services. [iii]
Thirteen new codes were created for reporting the technical component of long-term EEG services (95700, 95705-95716) and 10 new codes were created for reporting the professional component of long-term EEG services (95717 – 95726). The Long-Term EEG codes are diagnostic services primarily used to evaluate patients with intractable epilepsy as well as patients with new-onset seizures to determine if spells are seizures, to characterize seizure type, and to localize seizure focus for pre-surgical evaluation. The new professional services code set is used to report the professional service of reviewing, analyzing, interpreting and reporting the results of the continuous recording of EEG or EEG with simultaneous video recording with recommendations based on the findings. The professional code set is divided into 2 groups defined by the timing of the physician report generation and the ability of the physician to access the EEG (and video) data during the recording period.
The Professional Services for Long-term EEG are reduced significantly under the proposed changes. For example, CPT Code 95951-26 will now be reported as 95720 for the 24-hour Video-EEG professional service. The RUC recommended 3.86 RVUs for physician work of this code, a significant drop from the current physician work RVUs of 5.99 for 95951-26. This change was largely based on the results of a survey of physician members of AAN, ACNS, NAEC, and AES. The survey was distributed to 2239 physician members of the organizations and was completed by 152 physicians who performed Video-EEG studies 100 times (median) in the past year.
The RUC evaluated the survey results and proposed RVU levels for physician work for each code. CMS agreed with the RUC recommendations on the codes for professional activity for Long-term EEG studies after receiving and reviewing public comments.
The 2020 PFS Conversion Factor of $36.0896, is a slight increase from the 2019 factor of $36.0391.
Payment Rates for Medicare Physician Services from 2020 Final Physician Fee Schedule (CMS-1715-F)
|CPT Code||Descriptor||Work RVUs||Facility PE RVUs||Malpractice RVUs||Total Facility RVUs||CF= $36.0896|
|95717||EEG 2-12 hr w/o video||2.00||0.78||0.12||2.90||$104.66|
|95718||VEEG 2-12 hr||2.50||1.13||0.18||3.81||$137.50|
|95719||EEG each 24 hr w/o video||3.00||1.29||0.21||4.50||$162.40|
|95720||VEEG each 24 hr||3.86||1.76||0.28||5.90||$212.93|
|95721||EEG>36<60 hr w/o video (2 day)||3.86||1.78||0.28||5.92||$213.65|
|95722||VEEG>36<60 hr (2 day)||4.70||2.15||0.35||7.20||$259.85|
|95723||EEG>60<84 hr w/o video (3 day)||4.75||2.21||0.37||7.33||$264.54|
|95724||VEEG>60<84 hr (3 day)||6.00||2.74||0.44||9.18||$331.30|
|95725||EEG>84 hr w/o video (4+ days)||5.40||2.52||0.42||8.34||$300.99|
|95726||VEEG>84 hr (4+ days)||7.58||3.46||0.56||11.60||$418.64|
CPT Codes 95717 – 95726 are used when the physician has real-time access to the EEG data with or without video during the recording – such as a recording in an EMU, ICU or remotely monitored in-home ambulatory EEG.
80 Hour Video-EEG with Continuous EEG remote Monitoring (with Daily Review & Report)
|$36.09 x||5.90||$212.93 (95720 per day with daily report)|
|$36.09 x||3.81||$137.50 (one time 95718 with report)|
|Reimbursement x 3.33 days||=||$776.29|
CPT Codes 95718 – 95723 are used when the physician cannot access the data with or without video during the recording – such as an unmonitored in-home ambulatory EEG.
72 Hour Video-EEG with Intermittent or No EEG remote Monitoring (with Final Review & Report)
|$36.09 x||9.18||$337.80 (per study)|
|Reimbursement x 3 days||=||$337.80 (no daily report, so only one professional charge at end of study)|
Having remote access to the ambulatory Video-EEG data during the recording with review and daily report increases the reimbursement by $310.74 per 72-hour study.
[i] https://www.federalregister.gov/documents/2019/11/15/2019-24086/medicare-program-cy-2020-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other (accessed November 16, 2019)