When billing for psychotherapy and an Evaluation and Management (E/M) service, the CPT coding will no longer be based on the time of psychotherapy. Instead, providers should bill the E/M and a psychotherapy add-on code (See chart).
“Some things seem clear to me from audit defense point of view,” said Buechner. “The interactive codes were confusing, so folks were using them to get paid for multiple hours worth of work.” One of the problems was that group therapy paid as only one hour, and the specialty associations didn’t want to change the definition “because their concept of therapy did not cover alcohol groups lasting two to three hours,” he said. Another problem was that some groups misused the interactive group to bill for time spent on exercise machines as part of weight loss with psychotherapy. Finally, the interactive codes were also being used to bill for biofeedback services. “Now, we have clearly spelled out conditions for use,” said Buechner.
In fact, there was a lot of abuse of the old codes, said Buechner. “That’s part of the rationale for the new psychotherapy codes and part of the reason for the add-on therapy codes for use with E/M,” he said.
“Interactive complexity” (90785) is a new code designed to be an “add on” to new and existing codes shown in Figure 2, including codes for:
· diagnostic psychiatric evaluation (90791, 90792),
· psychotherapy (90832, 90834, 90837),
· psychotherapy when performed with an E/M (90833, 90836, 90838, 99201-99255, 99304-99337, 99341-99350), and
· group psychotherapy (90853).
Interactive complexity refers to communication problems that can occur, typically with patients who have maladaptive communication issues and with whom there are other issues such as abuse, negative report, or caregiver emotions and behaviors. Often, such patients have third parties — parents, courts, or schools — involved in their care.
Additionally, the idea of a separate code for psychotherapy when an E/M is performed helps to clarify the time issue: that the time spent on an E/M is separate from the time spent on psychotherapy. This is reinforced by the longstanding ban on the use of time in selecting an E/M.
More on E/M and diagnostic codes
Learning the E/M terminology is going to be daunting for mental health providers: it’s hard enough for medical offices, which usually have coding and billing staff as well. These “office visit” codes have levels that are based on the extent of the history obtained, the extent of the examination performed, and the complexity of medical decision-making. There are two sets of guidelines that coders can use – 1995 or 1997 – but in either case, the documentation involves much more than the number of minutes spent with the patient.
You can, of course, use the new psychotherapy codes instead of E/M codes. The main differences between the new and old psychotherapy codes are that:
1. the place of service (inpatient or outpatient) no longer matters,
2. the time spent on the service must follow CPT convention, and
3. psychotherapy codes may be used for time spent with family members as long as the patient is present for some of the session.
Two code sets — those for family psychotherapy (90846, 90847, 90849) and group psychotherapy (90853) — were retained.
There are two new codes for diagnostic evaluations: 90791 (without medical services) and 90792 (with medical services). The code that many have long used for diagnostic interviews, 90801, is no more. The 90791 and 90792 codes never include psychotherapy. They cannot be used for reassessments, should not be reported on the same day as psychotherapy or crisis psychotherapy, and may be reported more than once per patient when medically necessary, provided that separate diagnostic evaluations are conducted.
Components of diagnostic evaluation codes 90791 and 90792
· History and mental status
· Review and order of diagnostic studies as needed
· Recommendations (including communication with family or other sources)
Additional components of 90792 (medical services in addition)
· Examination (psychiatric specialty examination)
· Prescription of medications when appropriate
· Ordering of laboratory tests as needed
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