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 several 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 affecting the Codes and Reimbursement for the Technical Components that are in full effect on January 1, 2020.

Those changes include:

• Deletion of CPT Codes 95827, 95950, 95951, 95953, and 95956
• Addition of 13 codes for the technical component of long-term EEG services (95700, and 95705-95716)
• The addition of 10 codes for the professional component of long-term EEG services 95717 – 95726)
• Revisions to the EEG guidelines with definitions and parentheticals following codes 95812, 95813, 95816, 95819, 95822, 95827, 95957 will be included in the 2020 CPT Manual

The New Long Term EEG CPT Codes Explained

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.

An important third point is that though initially there were Relative Value Units (RVUs) assigned to each of the Technical Component codes (95700-95716), from the extensive feedback CMS received during the comment period, they have held off assigning any RVUs to these codes until they gather more cost inputs from providers and other stakeholders. Therefore, they have decided to go to the “contractor-pricing” for these procedures. Making it necessary to negotiate reimbursement with each of the regional MACs (Medicare Administrative Contractors) and indeed, with other third-party payers.

New Technical Component Codes

Preparing the patient for the study, including applying electrodes (8 or more), providing orientation and instructions and removing the electrodes at the end of the recording, is now coded as a separate procedure – CPT Code 95700.  This is a one-time charge regardless of whether the study lasts 2 hours or 10 days.  It is intended to cover the costs associated with the setup and take-down of a study by an EEG technologist.

Long-term continuous EEG recordings are billed daily and coded based on whether the study employs digital video recording with the EEG (video-EEG or VEEG), the duration of the recording (2 to 12 hours or 12 to 26 hours) and if and how the study is monitored by an EEG technologist (see Figure 1, Sourced from the NAEC).

Digital Video recording has become an essential part of assessing long-term EEG recordings. To qualify for the set of codes that include video, at least 80% of the recording of the VEEG must have concurrent video.

Monitoring is defined in the new codes based on the maximum number of patients’ EEG or VEEG one EEG technologist can monitor simultaneously. For “Continuous Monitoring” that Patient: Tech ratio is a maximum of 4:1; for “Intermittent Monitoring” that ratio is 12:1; and any number of patients greater than 12 by one EEG technologists the study is classified as “Unmonitored”. It also is a requirement that if a continuously monitored is interrupted for any significant time that it be reclassified as intermittently monitored (this is also the case if the EEG technologist is ever required to monitor more than 4 patients simultaneously – all the patients the tech is monitoring at the time convert to Intermittent).

Long-Term EEG Codes (TECHNICAL Services)

Set Up/Take Down Code billed one time during recording period; in-person service – 95700

The 24-hour period for a study begins at the time it is initiated. This means that a “day” for study may start at 10:00 AM or 9:30 PM or 3:00 AM depending on when the recording began. When coding for a multiday study, a partial day code (less than 12 hours) may be applied once to capture the period.

A Deeper Dive: The background story

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 monitoring 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.

Long-term EEG Technical Component Codes (95700, 95705 – 95716)

The new CPT Codes for Long term EEG is now defined by the length of time of the long-term recording, whether the study includes the recording of video with the EEG and if there is no monitoring of the study, intermittent monitoring or continuous monitoring.

For the new codes to report the technical component of long-term EEG services, the RUC had made recommendations that for various reasons did not account correctly for the cost of providing long term video-EEG recordings, especially in the home environment.  A concerted lobbying effort by professional medical, technologist and industry groups brought this to the attention of CMS which resulted in their decision, published November 15, to “contractor pricing” for the new technical codes for the next year or two, while they gather more information on the cost of providing these procedures.

For Long-term Video-EEG recordings performed in the hospital EMU or ICU, or for ambulatory video-EEG studies recorded in a patients home setting, the most applicable CPT Codes are 95700 (Set-up and Take-down), 95715 Electroencephalogram with video (VEEG), review of data, technical description by EEG technologist, each increment ^[iv]of 12-26 hours; with intermittent monitoring, and maintenance; and 95716 Electroencephalogram with video (VEEG), review of data, technical description by EEG technologist, each increment of 12-26 hours; with continuous monitoring, and maintenance.  The new codes have been “crosswalked” to the previous code for long-term monitoring of EEG with video, 95951.  This gives insurance payers some guide on reimbursement for this service code.

Impact on Facility and Non-Facility Reimbursement

The new CPT codes are applied to both Facility and Non-Facility procedures beginning January 1, 2020.  The impact will be different, however.  For procedures performed in an in-patient Facility (i.e. hospital), the CMS reimbursement for the new codes will be covered through the DRG diagnosis coding, the changes will not likely affect the use of long-term video-EEG monitoring in the EMU or ICU, though it defines the boundaries for continuous and intermittent monitoring by the technologist to monitored patient ratio; no more than 1:4 for continuous monitoring and not to exceed 1:12 for intermittent monitoring.

Facility coding also affects outpatient procedures if ordered by the hospital’s outpatient clinic or hospital-based physician AND performed by the facility (i.e., hospital) staff. An outpatient ambulatory EEG study that is set up and possibly monitored by hospital EEG Technologists is billed and reimbursed through the Outpatient Prospective Payment System (OPPS) which groups procedures by Ambulatory Payment Classifications (APCs).^[v]

The HCPCS Code 95716 (Video-EEG 12-26 hours with Continuous Monitoring) is assigned the APC code of 5724 – Level 4 Diagnostic Test and Related Service, which has a Payment Rate of $908.84 in FY2020.

All other 12-26 hour HCPCS Codes for Long-term EEG Monitoring are assigned to APC Code 5723, with a Payment Rate of $485.55.

Non-Facility PFS reimbursement covers procedures performed in a physician’s office, IDTF, or the patient’s home by a physician’s office or IDTF. 

Hospital inpatient services are usually covered under a DRG reimbursement process and it is unclear at this time what effect the changes in procedure coding will have on payment rates. 

Reference Links

[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)

[ii] https://www.ama-assn.org/sites/ama-assn.org/files/corp/media-browser/public/rbrvs/jan-2017-RUC-meeting-minutes-FINAL.pdf (accessed August 8, 2019)

[iii] https://www.ama-assn.org/system/files/2019-07/oct-2018-ruc-meeting-minutes.pdf (Accessed August 9, 2019)

[iv] https://www.ama-assn.org/press-center/press-releases/ama-releases-2020-cpt-code-set (Accessed September 10, 2019)

[v] https://www.federalregister.gov/documents/2019/11/12/2019-24138/medicare-program-changes-to-hospital-outpatient-prospective-payment-and-ambulatory-surgical-center (accessed November 18, 2020)

CPT is a registered trademark of the American Medical Association

NAEC is the National Association of Epilepsy Centers www.naec-epilepsy.org