Update and Clarification on Proposed Change to CMS Policy

AANEM wishes to clarify that a proposed change to Center for Medicare & Medicaid Services (CMS) would not affect AANEM members exactly as previously reported. 

We recently shared information about a proposed CMS policy that would reduce payment when a separately identifiable office or outpatient evaluation and management (E/M) service is provided on the same day as certain procedures. 

Following additional review of the proposed rule and the Medicare global-period indicators applicable to electrodiagnostic services, we want to clarify the potential impact on AANEM members. 

CMS's proposal applies when the same-day procedure has a 0-, 10-, or 90-day global period. Standard electromyography (EMG) and nerve conduction study (NCS) services generally have an XXX global-period indicator, meaning the global surgical concept does not apply. Therefore, based on the current proposal, an E/M service provided on the same day as standard EMG/NCS testing would not be subject to the proposed 50% reduction solely because modifier 25 is reported. 

AANEM continues to support the American Medical Association (AMA) and the broader physician community in opposing the proposed policy because of its potential impact on physicians who provide separately identifiable E?M services with procedures that are subject to the proposal.

We also believe it is important to clarify that the proposal is not expected to substantially affect standard EMG/NCS services provided by AANEM members.

AANEM will continue to monitor the proposal and keep members informed as CMS moved through the rulemaking process.