Familiarize yourself with the 2020 code changes for long-term electroencephalograph recording.
Auditing medical claims for long-term electroencephalograph (EEG) and video EEG (VEEG) recordings changed significantly at the beginning of 2020 due to new, revised, and deleted CPT® codes representing these services. As an auditor, it’s essential that you are aware of annual updates to code sets, and why the changes were necessary.
Why the New EEG Codes?
Effective Jan. 1, 2020, CPT® introduced 23 new codes for routine and special EEG monitoring and deleted five codes: 95827, 95950, 95951, 95953, and 95956. Why? In 2016, the Centers for Medicare & Medicaid Services (CMS) identified 95951 as a high-volume service because the code was submitted to Medicare more than 10,000 times and increased by more than 100 percent from 2009 to 2014 according to the American Academy of Neurology.
When high-volume codes are identified, CMS seeks a re-evaluation and looks to the affected medical specialty societies to survey the existing codes and develop new relative value units (RVUs) or propose coding changes, if needed. The new EEG and VEEG recording codes are a result of much work involving the CPT® Editorial Panel, medical societies, the American Medical Association’s (AMA’s) Relative Value Update Committee (RUC), and CMS.
Specifically, the changes involve:
- Deletion of 95827, 95950, 95951, 95953, 95956
- Creation of 10 professional component (PC) codes (for physician work only)
- Creation of 13 technical component (TC) codes (no physician work included)
The new codes more accurately represent the current practice of long-term EEG and VEEG monitoring.
Understand EEG Code Criteria
As an auditor, you must understand the key criteria that differentiate the codes. For the new professional component codes, ask yourself these three questions as you validate the code selection by comparing it to the documentation:
- How long was the EEG monitoring?
- Was the study done with or without video?
- Were there daily physician reports or a report written at the conclusion of a multiple-day study?
With the answers to these questions, you can readily validate the code selection. The CPT® code book and quality coding software, such as Codify (formerly AAPC Coder), assist users in accurate code selection and verification.
The new PC codes include:
Two codes for daytime monitoring (typically eight hours) with physician access to data throughout the recording period and a report written at the end of the two- to 12-hour period:
- 2-12 hours of EEG continuous recording; without video (95717)
- 2-12 hours of EEG continuous recording; with video (95718)
Two codes for between 12 and 26 hours of monitoring (typically 24 hours) with physician access to data throughout the recording period and a report written each 12- to 26-hour period:
- 12-26 hours EEG continuous recording, interpretation, and report after each 24-hour period; without video (95719; prior to 2020, 95956)
- 12-26 hours EEG continuous recording, interpretation, and report after each 24-hour period; with video (95720; prior to 2020, 95951)
Six new codes for multi-day testing, typically for patients tested in their homes, physician access to data at conclusion of study when the summary report is written (formerly 95953):
- 36-60 hours (2-day) EEG continuous recording, without video (95721)
- 36-60 hours (2-day) EEG continuous recording, with video (95722)
- 60-84 hours (3-day) EEG continuous recording, without video (95723)
- 60-84 hours (3-day) EEG continuous recording, with video (95724)
- > 84 hours (4 or more days) EEG continuous recording, without video (95725)
- > 84 hours (4 or more days) EEG continuous recording, with video (95726)
Validate EEG Code Selection
Step one in an audit is accomplished when you can validate the code selection. Step two should be a check for national and local coverage determinations (if you are auditing Medicare claims) or coverage policies that may apply to other payer types. When accessing this kind of information, you will find the circumstances for which long-term EEG/VEEG monitoring is deemed medically necessary, as well as some circumstances that may not. Payer policies also usually include a list of covered ICD-10-CM codes.
As an auditor, you will want to review this list and comment in your report whether the appropriate codes were reported and whether the medical record documentation you reviewed supported the selection of the codes. Please note, it is never appropriate to select a code from a so-called payable list if it is not documented in the medical record.
You may be asked to audit the TC codes used for reporting these services. There is a single code for setup, takedown, and patient education by an EEG technologist, and 12 monitoring codes differentiated by the length of EEG recording (2-12 hours versus 12-26 hours) and the level of monitoring:
- Unmonitored or more than 13 patients monitored concurrently
- Intermittent monitoring, between five and 12 patients concurrently
- Continuous monitoring, four or fewer patients concurrently
The TC codes include 95700 (reported for the setup, takedown, and patient/caregiver education) and 95705-95716 (reported for the monitoring, maintenance, review of data, and technical summary). The TC codes are reported for services provided in a physician office, independent diagnostic testing facility (IDTF), or for services provided in a patient’s home if ordered by a physician’s office or an IDTF. The TC codes are not reported for hospital inpatient or outpatient studies or for home studies ordered by hospital-based physicians and provided by technologists who are employed by the hospital. The facility fees for all hospital-based studies are included in the hospital diagnosis-related group (DRG) payment for inpatients or the hospital ambulatory payment classification (APC) payment for outpatient or home studies ordered by the outpatient clinic or hospital-based physician.