AANEM News Express

AANEM News Express

Comparative Billing Reports in EDX Medicine: An Analysis

Approximately 4,300 Medicare providers of electrodiagnostic (EDX) tests received comparative billing reports (CBRs) this past February. The CBRs were sent to providers who had different billing averages (per beneficiary, per overall charges and/or NCSs performed without EMG) as compared to other providers in their specialty. The reports are intended to give providers an opportunity to compare themselves to their peers (based on the specialty they billed Medicare most often under), check their records against data in CMS files, and review Medicare (and AANEM) guidelines to ensure compliance. CBRs are for educational and comparison purposes and do not indicate the identification of overpayments. These reports do NOT indicate a precursor to an audit. 

The group responsible for compiling the CBRs acknowledged that many practitioners routinely see more complex patients who require more extensive testing and that because the CBRs are based solely on claims data and not a chart review, the reports did not account for this fact.

Another CBR on EDX medicine was released back in 2014 and provided some interesting comparative information. For example, the average allowed charges per beneficiary and average weighted services by category stayed nearly identical for neurologists and PM&R physicians, while the number of NCSs performed without an EMG (excluding claims with a diagnosis of carpal tunnel) went down slightly for both neurology (from 10% to 7% in 2015) and PM&R (from 5% to 3% in 2015).

Average Allowed Charges per Beneficiary
Specialty Oct 2014 – Sept 2015 Jan 2013 – Dec 2013
Neurology $299.72 $292.88
PM&R $312.01 $295.91
National Average $303.53

Average Weighted Services by Category
Specialty Oct 2014 – Sept 2015 Jan 2013 – Dec 2013
Neurology 8.33 1.47 1.77 8.45 1.46 1.80
PM&R 7.71 1.42 1.63 7.74 1.24 1.65
National Average 8.35 1.46 1.73 8.72 1.41 1.78


The specialty with the highest “allowed charger per beneficiary” was pulmonary disease with a charge of $500.36; however, it is not clear how many physicians were included in this specialty and it may have been a single physician. Physical therapists ($373.06) and Pain Management physicians ($388.38) rounded out the top three highest specialties.  Again, it is not clear how many providers from each category were included. Providers from General Practice, Pulmonary Disease and Independent Diagnostic Testing Facilities (IDTFs) all performed, on average, over 13 NCS studies and over 2 NCS&EMG.

There were several specialties that performed NCS-only over 50% of the time in patients without a carpal tunnel diagnosis:

Percent of Visits with NCS CPT Codes Only
Specialty Percent
Podiatry 100%
Colorectal Surgery 100%
Gastroenterology 89%
General Practice 82%
Endocrinology 82%
IDTF 69%
Cardiology 67%
Physician’s Assistant
General Surgery 66%
If you did receive a CBR, you are encouraged to perform a self-audit to ensure that you are, in fact, coding and billing correctly. By developing compliance policies and guidelines, and conducting internal audits, a practice can illustrate that it has met its full responsibility for accurate coding and billing.  
  • For more information on developing a compliance program, please visit our website here.   
  • AANEM’s 2016 Online Coding Guide contains information on correct coding, frequently asked questions, and sample appeal letters.  This guide is available for purchase here.   
  • If you have specific coding and billing questions, AANEM members can submit questions using the Coding Question Form found on our website here.
As a reminder, if you received a CBR and have questions, please contact the CBR Support Help Desk at 1-800-771-4430 or CBRsupport@eglobaltech.com or visit the CBR website at www.cbrinfo.net.  A recording of the March 2 webinar should be available within the next week here.

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