tele-NP coding FAQ with Dr. Neil Pliskin
Neil Pliskin, Ph.D., ABPP-CN, APA’s advisor to the CPT answers tele-NP coding questions. If you have a question for Dr. Pliskin that you don’t see asked/answered here, scroll down to fill out the question form.
Q: Can you bill a neurobehavioral status exam for a parent interview if you did not see the child on the same day? The hospital requires a bill to be submitted for each date of service. Now that we are conducting a portion of the assessment virtually, it is sometimes easier for the parent to complete the remote interview on a day when the child is not present. The assessment of the child would be completed separately, either in-person or virtually. If you cannot use 96116, what code would you use for the parent interview?
A: 96116 (neurobehavioral status exam) can only be used when the patient is present. I presume that this is part of a neuropsychological evaluation. If so, then bill 96116 for the face to face with the child and the collateral interviews would be professional work using the professional services code.
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Q: At our children’s hospital, we would like to move toward conducting clinical interview with parents via telehealth, followed by administration of tests in person with the child and then feedback via telehealth with parents (to limit exposure as much as possible). Since we have to drop the entire bill at the end of service and each code has to either be assigned a 95 modifier or not, how would we bill? For instance, several units of 96132/3 would be in person (interpreting scores and adjusting plan as we test) while the feedback (same codes) would be telehealth.
A: First question: How much time between the Neurobehavioral Status Examination and when they come in face to face?
You could drop the 96116/96121 separately at the time of service if there is a long lag.
Otherwise, you would include all on the single billing form, with multiple codes and dates, some with a 95 modifier and some without.
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Q: Does tele-NP ‘count’ towards annual limits for neuropsychological testing?
A: Yes. Tele-NP would ‘count’ towards whatever limits on units of testing your local medicare carrier has imposed through the neuropsychological testing LCD. You may already know this, but Medicare is divided into several regions, and each region is responsible for developing Local Coverage Determinations (LCDs). LCDs guide reimbursement in your region- how many units, for what conditions, etc. You will want to continue to assume that any limits on testing spelled out in your Medicate Jurisdiction’s LCD still stand.
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Q: If I do a clinical interview, do some testing within the session, and get enough information to formulate a diagnosis, how do I bill after the consult? I would still have to have a feedback session. Does all my interpretation/write up go under 96121 (neurobehavioral status exam)? And if so, how do I bill for feedback? Would that be 96132? Would I do the interpretation of the tests and write up under 96132 if that's the case?
A: Sounds to me like you administered neuropsychological tests and you are integrating your behavioral observations with formal test results and parent/teacher questionnaires into a report. Sounds like 96116 + evaluation services (96132-33) + tests administered and scored (96136) if time thresholds were met.
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Q: Following a comprehensive diagnostic interview, I provide a written report culminating from a review of records and integration of information ultimately providing diagnosis(es), impressions, and in-depth treatment planning options relating to the patient's cognitive symptoms and behavioral presentation. No testing was administered. This could amount to one to two hours of professional time. How should I bill?
A: You are conducting a neurobehavioral status examination and you would use 96116/96121.
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Q: How would I bill feedback, assuming I first conducted the interview, then reviewed records and integrated results, and needed to provide feedback on a separate session?
A: Interactive feedback is a professional service. If it lasts 31 minutes, then you would bill the professional services code (96132).
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Q: What if I provide a second opinion based on prior neuropsychological testing, record review, and new clinical information from an interview that results in a brief report documenting diagnosis, impressions, and treatment planning. Here testing was reviewed but not administered as part of the encounter. This takes at least one (probably more) hours of professional time. How should I bill?
A: You are providing professional evaluation services and would bill 96132/96133
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Q: Will Medicare reimburse Tele-NP using audio (telephone) only?
A: Yes, here is the announcement. https://www.apaservices.org/practice/clinic/covid-19-telehealth-phone-only
Q: Will Medicare reimburse for Telehealth Neuropsychological CPT codes 96116, 96132, 96133, 96136 and 96137 even if all of these services are audio only services?
A: Yes.
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Q: In terms of providing audio only services what form of audio only technology is permissible? May Neuropsychologists provide Neuropsychological testing via telephone or is some other audio only format required? Are there audio only formats that are HIPAA compliant?
A: At this time, there are no restrictions or further comments from CMS about audio technology. Whether you can effectively perform these services over audio only of course is a different question.
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Q: Regarding audio only Neuropsychological test administration - How would one practically go about administration of Neuropsychological tests in this manner? I could see where it might be possible to administer verbal memory tests (e.g., the CVLT-II) via phone, as well as, other certain other Neuropsychological test measures. Obviously administration of visual memory tests would not be possible via an audio only format.
A: This is exactly my point. You will be limited in what you can do and there will be only limited control over the testing environment.
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Q: How would one bill for provision of audio and/or video telehealth Neuropsychological services?
A: Use your typical code(s) and add a 95 modifier to indicate telehealth.
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Q: What modifiers and place of service codes should be used for video-telehealth services?
A: Same as above.
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Q: I am in the process of reopening my practice. I have set up a separate room in my office where patients can be tested “remotely” via computer and materials placed in the room prior to them arriving. Should I bill this as telehealth?
A: No. This is still an in-person encounter. Do not bill as if it is tele-NP.
Q: I understand that services should be billed for as an in-person encounter when the patient and provider are in the same location but technology is used as way to permit physical distancing. CMS guidance on this point seems linked to the PHE set to expire 7/26/20, although the need to physically distance and lessen density in rooms for NBSE and feedback sessions is likely to persist after that point. For how long can in-office tele be billed as in-person?
A: There is no expectation that this will ever change. That is, even when emergency orders are lifted, continue to bill ‘in-clinic’ tele-NP as an in-person encounter.
Q: If a patient does not have technology available to complete a telehealth interview from their home, and we have them come into the the clinic for an interview via Zoom using our clinic computer, but the provider they were interviewing with was NOT physically in the clinic (and only support staff were to help the patient get set up), would this then be classified as "in person" or "telehealth" for billing purposes?
A: If the psychologist is engaging remotely from the patient (different building), it is a remote assessment, regardless of whether the patient is at home, or in a clinic tele-NP room. The only scenario where an in-clinic tele-NP set up would be considered ‘regular in office’ is if the computer terminal is in the same physical building, but the provider for virus mitigation purposes is in another room.