Practice leaders at a 2005 APA Annual Convention symposium said it's time for psychologists to prepare for what they called a "watershed event" in psychology practice: a change and expansion in the Current Procedural Terminology, or CPT, codes for psychological and neuropsychological testing that will better reflect psychologists' status as health-care professionals.
Effective Jan. 1, the changes result from more than 10 years of persistent advocacy and negotiation by APA with members of the American Medical Association (AMA) CPT committee and its Relative Value Scale Update Committee, or RUC, the entities responsible for shaping and assigning value to the codes. AMA publishes and annually updates the CPT manual, which lists procedural codes and descriptions for health-care specialties.
The changes mark the first time that the Centers for Medicare and Medicaid Services (CMS)--the entity that finalizes federal reimbursement rates for the codes under the Medicare physician fee schedule--will formally acknowledge the psychologist's work component in psychological and neuropsychological testing, said Antonio E. Puente, PhD, a University of North Carolina-Wilmington psychology professor and APA's representative to the CPT panel. While the fee schedule only applies to Medicare, it influences public and private reimbursement rates nationwide, he said.
The 2006 fee schedule is expected for the first time to grant psychologists an explicit "work value," or professional value, for administering testing services. At present, most neuropsychological and psychological tests, whether administered by psychologists, technicians or computers, are reimbursed at the same nonprofessional or technical rate.
Replacing old codes
The code changes will initially come via two means. The new code numbers--which will replace codes 96100, 96115 and 96117 for psychological testing, neuropsychological testing and the neurobehavioral status exam, respectively--will first appear in the 2006 CPT manual, scheduled for release in October, said Diane Pedulla, director of regulatory affairs in APA's Practice Directorate.
Meanwhile, the monetary values for those codes will first appear in the final rule of the 2006 Medicare fee schedule when it is issued by CMS in early November. The fee schedule is published in the Federal Register, but because of its considerable length, the document may be available online at the CMS Web site (www.cms.hhs.gov) several days before it appears in print, she noted.
The process is frustratingly truncated both in the short amount of time between the release of the codes and their values and their start date, and in the fact that insurers don't have a grace period to enact the new system as they did in the past, said Practice Directorate Deputy Executive Director Randy Phelps, PhD.
"This means that on Dec. 31, you'll be using the existing testing codes," he said, "and the next day you will have to use the new codes." Phelps urged practitioners to be aware of the new codes, to work with Practice Directorate staff to clear up billing problems during the transition period, and, if necessary, to talk to insurers directly.
The new system is not complicated, but practitioners will need to learn two new strategies to apply it effectively, symposium presenters emphasized.
One strategy is to understand the new codes and document them accurately, said Kimberley Moore, federal and regulatory affairs officer in the Practice Directorate. In essence, you must code who has conducted the testing and for how long, she explained.
Under the new system, psychological and neuropsychological testing will each receive three new codes that reflect who does the testing: a psychologist, a technician or a computer. The neurobehavioral status exam, which is typically not administered by a technician or a computer, will be replaced by a single new code similar in content to code 96115. Meanwhile, the time a procedure takes will be noted in hourly units if it is conducted by a professional or a technician, and by a single code if the test was taken via computer, she explained.
Practitioners will need to bill insurers in terms of that information, she noted. For example, if you conduct three hours of testing and two hours of interpretation and report-writing and a technician conducts an hour of testing, you would bill for five units of the professional code and one unit of the technician code. Similarly, if a patient works alone on a computer test for an hour and you spend three hours interpreting it and writing it up, you would bill the computer-based code and three units of the professional code, she explained. (More information on billing is available on the APA Practice Organization's Web site, www.apapractice.org.)
The other new strategy is learning to document what the CMS calls "medical necessity," the notion that the service you're providing is necessary for improving or maintaining a patient's health, said James M. Georgoulakis, PhD, an APA consultant and APA's representative to the AMA's RUC, which provides input on the professional elements embodied in the codes that the CMS translates into dollar amounts.
In general, medical necessity requires you to:
Document that you provided a service because the patient needed it for medical reasons, rather than for your convenience or that of your patient.
Document the procedure at the time the care is provided.
Learning to properly apply the concept of medical necessity is critical for receipt of payment, said Georgoulakis.
Specific information about the new codes and their proper usage will be available through www.apapractice.org; the Practice Update e-mail newsletter, also located at the Web site; state psychological association vehicles; and practice listservs.
Practice leaders realize that practitioners face a learning curve that only time and education can fully address, Puente acknowledged. But in the beginning phases of the process, let two words guide you, he advised: common sense.
"If what you're doing makes sense and it's defensible, then you should be fine," he said.Tori DeAngelis is a writer in Syracuse, N.Y.