Tele-nP billing codes, general reimbursement and licensure
This page has been created in consultation Neil Pliskin, Ph.D., ABPP-CN (current APA advisor to the CPT), Stephen Gillaspy, Ph.D. (Head of APA office of Healthcare Finance), and Tony Puente, Ph.D. (former delegate to the CPT) and shares CMS, Medicare, and private insurance reimbursement information.
The IOPC has been leveraging its established network of connections to vigorously advocate for expanded coverage of TeleNP during the current COVID-19 crisis with both public and private insurers. This information will be continuously updated. Please check back regularly. It is the responsibility of the individual clinician to determine if an insurer they are billing covers TeleNP. Scroll down for licensure and practice of telehealth across state lines
New! Link here for the IOPC/APA 50 state grid for Tele-NP coverage policies.
Link here for tele-nP coding FAQ with Dr. Neil Pliskin
Medicare
New as of 5/1/20: Medicare is now covering 96121. Medicare is also covering TeleNP via audio only (telephone).
Medicare allows the following mental and behavioral health services to be provided via telehealth. APA is advocating with CMS to expand the list and have requested that all psychological and neuropsychological testing codes be allowed via telehealth during this crisis. This information will be updated as soon as any coverage decisions change.
Interview and intervention codes:
90791: Psychiatric diagnostic interview
96116-96121: Neurobehavioral status examination
96156: Health and behavior assessment or reassessment
96130- 96133: Psychological testing
96136- 96139: neuropsychological testing
90832 -34 -37: Individual psychotherapy
90785: Psychotherapy with interactive complexity (likely met by telepsychology)
90846 -47: Family psychotherapy
90839, -40: Psychotherapy for crisis
90845: Psychoanalysis
95158 -59: Health and behavior intervention, individual
96164 -65: Health and behavior intervention, group
96167 -68: Health and behavior intervention, family with patient present
96170 -71: Health and behavior intervention, family without patient present
Psychologists can also bill for brief communications (known as e-Visits) with established Medicare patients. E-Visits involve a brief communication, typically initiated by the patient, and can be furnished in any location or geographic area. Link here for additional information on these new G codes.
G2061: Qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the seven days: 5-10 minutes.
G2062: cumulative time of 11-20 minutes during the seven days.
G2063: cumulative time of 21 or more minutes during the seven days.
All services provided through telehealth technology will need to include the appropriate place of service/location and other modifier codes:
Effective March 31, 2020 providers furnishing services through telehealth should use the place of service that would have been reported if the service was being furnished in-person.CMS is making this change to identify when it is appropriate to pay a non-facility fee, rather than a facility fee which would have automatically been included under POS 02.
To illustrate, a psychologist who would have seen patients in a private office should use POS 11. Those who would have treated the patient in a clinic or skilled nursing facility should use the appropriate POS. All claims for telehealth services should now include modifier 95.
The APA has provided the following recommendation for use of available CPT codes when billing Medicare during the pandemic. This information will be updated regularly.
If the case is a DSM diagnosis case (e.g., psychiatric), use 90791-psychiatric diagnostic evaluation code. Please note that this is an untimed code. Those patients would then return at a later date to obtain their Test Administration and Scoring and Testing Evaluation services in a face-to-face situation.
If the case is an “ICD” diagnosis case involving a medical condition, conduct a health behavior assessment and use code 96156. Please note that this is an untimed code and includes a health focused clinical interview, behavioral observations, and clinical decision making. This is NOT a testing code. Information on billing and coding for the new Health Behavior Assessment and Intervention codes can be found at https://www.apaservices.org/practice/reimbursement/billing/new-codes.
If the case is an “ICD” diagnosis case involving a neurological condition, conduct the neurobehavioral status exam and use 96116. Those patients would then return at a later date to obtain their Test Administration and Scoring and Testing Evaluation services in a face-to-face situation. Note that the 1st hour (96116) is approved but at this point the add on code (96121) has yet to be approved.
Private Insurers and State Medicaid Carriers
Many private insurers and state Medicaid providers have indicated their intent to open up all of the neuropsychology CPT codes to be reimbursed via telehealth. We are following this closely and will update IOPC.online as details become available.
96116/121: Neurobehavioral status exam is completed prior to the administration of neuropsychological testing. Consider using 96116/121 to determine the potential utility of doing additional testing using TeleNP, both in terms of the technical issues and the patient characteristics.
96132/33: Neuropsychological testing evaluation services by physician or other qualified healthcare professional, including integration of patient data, interpretation of standardized test results and clinical data, clinical decision making, treatment planning and report and interactive feedback.
96136/37/38/39: Psychological or neuropsychological test administration by professional (36/37) or technician (38/39).
96146: Computerized psychological/neuropsychological testing. This is a single unit code used for tests administered via a computer. This does not mean TeleNP in general, but indicates a test was given in a computer-based format (e.g., computer administration of the WCST, MMPI-2RF, etc).
Feedback - See 96132/33
All services provided through telehealth technology will need to include the appropriate place of service/location and other modifier codes:
Place of Service/Location Codes: -02 (Telehealth)
CARES ACT Impact on Reimbursement:
On March 27, 2020, Congress passed the Coronavirus Aid, Relief, and Economic Security Act (H.R.748). The CARES Act signals strong support for telehealth and recognition that expanding access to telehealth is critical to defeating COVID-19. Some provisions that may impact reimbursement include:
Section 3701. Health Savings Accounts for Telehealth Services Allows a high-deductible health plan (HDHP) with a health savings account (HSA) to cover telehealth services prior to a patient reaching the deductible.
Section 3703. Expanding Medicare Telehealth Flexibilities
Removes the COVID-19 Medicare telehealth waiver requirement that a provider must have seen the patient within the last 3 years.
Removes the definition of telehealth under the COVID-19 waiver as real-time audio/visual technology, providing the Secretary of HHS additional authority to give flexibility to providers to use audio-only telehealth.
Provides the Secretary with expanded authority to waive additional 1834(m) statutory restrictions on Medicare telehealth services. This is critical to ongoing advocacy efforts. Additional Medicare changes will be continuously updated
Licensure
Many states allow psychologists who are licensed in another state to temporarily practice in their own state.
APA has created a very helpful 50 state grid documenting each state’s pandemic licensure rules.
Examples:
o Connecticut temporarily suspend requirements for licensure, certification or registration effective March 23, 2020, and lasting for 60 consecutive days.
o NewHampshire allows out of state psychologists to obtain an emergency license at no cost. Application for Emergency License is online.
o RhodeIsland allows emergency reciprocal licensure for psychologists for 90 days at no cost.
o Vermont – allows for temporary license due to the COVID-19 crisis. They will verify any licenses you hold and then issue a 90-day temporary license.