Health care is facing challenging times in 2025 as the FDA, CDC, NIH and other health related government agencies face reorganization. Recent headlines, including the case reported by the U.S. Department of Justice involving a multimillion-dollar medical billing fraud scheme, serve as a sobering reminder of the importance of ethical and legal billing practices across all areas of healthcare. While these incidents span many different treatment modalities, they reinforce the responsibility we all carry to ensure our work maintains the highest standards of integrity and transparency.
At ISNR, our ongoing efforts to strengthen and clarify CPT coding for neurofeedback and QEEG are grounded in this exact mission. Properly defined codes not only help expand access to care and support reimbursement for providers—they are also essential tools in promoting lawful, ethical billing practices. When codes are ambiguous or lacking, the risk of unintentional misuse or misrepresentation increases. Our work with the AMA and allied organizations seeks to address this by solidifying the language, structure, and reimbursement pathways for these services.
Only licensed health care professionals properly enrolled with individual insurance companies can bill insurance for neurofeedback services. What an insurance company chooses to do with a CPT code is what they choose to do. As of this date, the current information on the use of CPT codes for neurofeedback are as follows:
90901 – Includes EEG biofeedback (neurofeedback) and that has been clarified by the AMA CPT Editorial Panel at the time the codes were created. 90901 is the appropriate code to describe EEG Biofeedback (including z score and multichannel neurofeedback) when it is not done simultaneously with psychotherapy.
90875 and 90876 are used when neurofeedback is done WITH psychotherapy.
NOTE: Not describing EEG biofeedback as 90901, 90875, or 90876 when it is provided by a licensed provider with FDA authorized equipment, one to one and face to face, or within “incident to” requirements would actually be incorrect and may subject someone to an accusation and investigation of fraud.
Medicare does not cover Neurofeedback. They recently changed their policy in 2023 which took effect early 2024. It was previously excluded from the contract because it was considered experimental/investigational. Now, it is included and no longer experimental/investigational; but considered “Not medically necessary.”
Mark Trullinger (ISNR’s representative working on the CPT Code Project on behalf of ISNR) reports: “90901-GA, 90875-GA, or 90876-GA would be the appropriate way to bill Medicare, and to complete the ABN process with your clients. This will ensure that you comply with the Medicare policy as you will clarify that the service is determined “not medically necessary” by Medicare with the client allowing you to charge them directly for the service. When you bill the GA modifier to Medicare it will notify them that the service is not included in their “medically necessary” forms of biofeedback, and it will trigger an automatic denial. However, this will allow the procedure to show up in the Medicare utilization numbers even if it is not covered.”
Mark also explains; “It is possible to utilize technicians and not commit fraud. To do so, there are some specific rules to follow regarding state scope of practice laws and regulations, which can vary by state and license type, and “incident to” requirements, which also vary by insurance company. 90901, 90875, 90876 are not technician codes. Therefore, they cannot be done solely by a technician who is supervised by a licensed provider. A technician can be utilized via “incident to” when the licensed provider is allowed to supervise technicians within their state scope of practice, and they meet the “incident to” requirements (which can vary from one insurance company to another). Look at the definition in your contract with the insurance company, and Medicare’s can be found with an internet search.”
He goes on to say: “To meet the requirements of the code it needs to be a one-to-one and face-to-face service, meaning someone needs to be in the room with the patient the whole time and only one patient at a time. Lastly, the equipment needs to be FDA approved or cleared, both hardware and software, for more information on what those devices are see here ”.
We should all be very careful and make sure we meet all the requirements of the code. We should also be careful what we are advising people and putting on public forums. As professionals who frequently teach on ethics in clinical neurofeedback practice, we can attest to how critical this issue is—not only to individual practitioners but to the credibility of our field as a whole. Our goal is not only to advance Neuroregulation but to do so responsibly and sustainably.
We recognize that billing fraud occurs in many areas of healthcare, and it is not unique to neurofeedback. Rather than reacting with fear or disengagement, we remain committed to shaping the future of our field through clearly defined CPT codes that reflect the time, training, and value of the services we provide. These codes must remain within scope, legally defensible, and ethically applied—and that is the foundation of ISNR’s advocacy on behalf of its membership. And we will continue to educate and set industry standards on best practices consistent with licensing laws and legal and ethical insurance billing.
Thank you for continuing to be part of this mission.
Warm regards,
Rob Longo & Leslie Sherlin
President & President-Elect
