AANEM policy staff participated in a webinar by the authors of the recently released Comparative Billing Report
(CBR) on electrodiagnostic (EDX) medicine. Take-aways were:
Receiving a CBR is NOT a precursor to an audit and there is no assumption of wrongdoing. CMS will only have access to the same information as the public (i.e. only the national averages and averages by specialty – not individual data by NPI). Although not discussed on the webinar, CMS could take the averages and conduct its own analysis of individual providers to identify outliers.* As long as your medical records support your testing, you should be able to defend your testing.
The CBRs went out to approximately 5,000 practitioners, all of whom had “different billing averages” than their specialty. This included physicians from a variety of specialties. Some interesting statistics included:
% of EDX Studies Billed NCS-only (excluded carpal tunnel) by specialty
Physiatrists = 5%
Neurology = 10%
Independent Testing Facilities = 80%
Podiatry = 100%
The presenters acknowledged that physiatrists and neurologists were likely to have higher averages due to the likelihood that they are dealing with more complex cases (and some physicians in these groups may have higher averages than others in their specialty, again based on the complexity of their cases).
AANEM policy staff have provided some of these statistics to law enforcement agencies and private insurance companies in the hopes of helping identify and stopping fraud and abuse in EDX medicine – as well as support for AANEM’s position that only qualified physicians (physiatrists or neurologists) should be performing EDX medicine. Please contact the policy department with any questions or concerns: firstname.lastname@example.org
* Speculated by AANEM policy staff; not discussed during the webinar.