Questions and Answers About the 2006 Revised CPT Testing Codes
by Federal Regulatory Affairs Staff
January 19, 2006 -- In our ongoing education campaign to help practitioners know about and properly use the 2006 Current Procedural Terminology (CPT)® psychological and neuropsychological testing codes, the APA Practice Directorate is offering this question-and-answer guide.
This guide is a compilation of information from articles posted on APApractice.org beginning in 2004, when the American Medical Association’s (AMA) CPT Editorial Panel accepted the APA’s proposal to develop an expanded set of testing codes to more accurately reflect psychological and neuropsychological testing.
Note: View estimated Medicare payments for 2006 testing services. A congressional legislative proposal pending as of late January would freeze Medicare rates for 2006 at the 2005 level. See related article, "2006 Medicare Fee Schedule: Reversal of 4.4% Payment Reduction Expected Soon."
Q: What changes are there to the CPT psychological and neuropsychological testing codes in 2006?
A: As of Jan. 1, 2006, the CPT codes for psychological and neuropsychological testing have been revised. New code numbers have replaced the old CPT code numbers 96100, 96117 and 96115 for psychological testing, neuropsychological testing and the neurobehavioral status exam.
The revised psychological and neuropsychological testing codes now reflect who does the testing: a psychologist, a technician or a computer. The neurobehavioral status exam, which is typically not conducted by a technician or a computer, has been replaced by a single new code.
The revised codes finally provide more appropriate reimbursement and recognition for psychologists who administer psychological and neuropsychological tests. The Practice Directorate successfully sought the revised codes as part of a persistent, multi-year effort to obtain a “professional work value” for testing and assessment codes reflecting the time and effort expended by a psychologist in providing these services. Previously, psychological testing codes had a work value of zero for the psychologist’s effort.
Q: Is there a grace period during which I may continue using the old codes?
A: No. Practitioners must use the revised codes as of Jan. 1, 2006. The CPT testing codes for 2005 are no longer being accepted.
Q: What are the new code numbers?
A: The code for psychological testing, interpretation and reporting, formerly known as 96100, is now:
• 96101, for psychological testing, interpretation and reporting per hour by a psychologist
• 96102, for psychological testing per hour by a technician
• 96103, for psychological testing by a computer
The code for Neuropsychological testing, formerly known as 96117, is now:
• 96118, for neuropsychological testing, interpretation and reporting per hour by a psychologist
• 96119, for neuropsychological testing per hour by a technician
• 96120, for neuropsychological testing by a computer
The neurobehavioral status exam, formerly coded as 96115, is now coded as 96116. There is only a single code reflecting the psychologist’s work in conducting the exam, which is typically not conducted by a technician or a computer.
The new code numbers are published in CPT 2006©, which is available from the AMA at 1-800-621-8335.
Q: How should I handle billing under the revised codes?
A: Billing under the revised codes is based on who administers a test and how long it takes. Testing conducted by a psychologist is billed in hourly units, based on the number of hours the psychologist spends administering a test and interpreting and reporting test results. Testing conducted by a technician is based on the number of hours the technician spends administering a test. Testing conducted by computer is billed at a flat rate using a single code. When billing the revised codes, it is important to note in the client’s record who administered the test and for how long.
The following scenarios offer examples for how to bill under the revised codes:
Billing example #1: If a psychologist conducts five hours of psychological or neuropsychological testing and three hours of interpreting and reporting the test results, he or she would bill for eight units of the psychologist-based code.
Billing example #2: If a technician conducts two hours of testing and a psychologist conducts 3.5 hours of testing and 2.5 hours of interpretation and reporting, he or she would bill for two units of the technician-based code and six units of the psychologist-based code.
Billing example #3: If a patient completes two hours of computerized testing and a psychologist conducts two hours of testing and one hour of interpretation and reporting, he or she would bill for the computer-based code (which is a single, flat-payment rate that is not measured in units) and three units of the psychologist-based code.
Q: What type of testing work by a technician is billable under the new technician-based codes?
A: The time a technician is with the patient, administering tests, or supervising the patient as he or she completes the tests, is considered billable under the technician-based code. The technician must be with the patient, face-to-face, during the testing in order for the psychologist to be able to bill for the time.
Q: Is the time that a technician spends scoring tests billable under the technician-based codes?
A: Scoring is not a billable activity unless it is done while the technician is face-to-face with the patient during the test administration.
Q: If a psychologist sits in an observation room and monitors a technician administering a test, does the psychologist bill for this service under the psychologist code or the technician code?
A: Since the technician is administering the test to the patient, the psychologist must bill using the technician code. The code billed must reflect who is doing the test administration face-to-face with the patient.
Q: If a patient takes a paper-and-pencil test, what code should be used?
A: It depends. If a psychologist is with the patient during the test, then that time is allocated to the psychologist code. If a technician provides oversight during the test, then the technician-based code is used. If the patient is entirely on his or her own during the test, that time is not billable.
Q: When is the computer billing code used?
A: The computer code is used when the patient takes a computer-based test and there is no involvement in the administration of the test by either a psychologist or a technician. Scoring by computer is not a billable activity.
Q: Can I bill the computer code if my patient takes a paper-and-pencil test, and I use a computer to score it?
A: No. The codes are for identifying how test administration is done, not scoring. If the paper and pencil test is self-administered (i.e., only the patient is involved in the testing) then the psychologist may not bill for either the time the patient spends on the test or the computerized scoring of the test. In this situation, the psychologist may only bill for the time spent on interpretation and reporting.
Q: If a patient takes three computerized tests and no one is with him or her, does the psychologist bill the computer code three times?
A: No. The computer code should be billed only once.
Q: Suppose a full battery of testing includes a single computer administered test like the Continuous Performance Test, in addition to tests administered by either the psychologist or a technician. Can the psychologist bill the computer code as well as the psychologist or technician codes?
A: Yes. If a testing battery involves a computerized test, and the patient is completely alone during that test, then the computer code (96103 or 96120) may be billed in addition to the technician and psychologist codes.
Q. If I conduct an MMPI as part of neuropsychological testing, should I bill using the psychological testing code during that portion of the battery?
A. No. Coding is not based on the tests that are conducted. It is based on the reason for testing. If you are testing a patient for neuropsychological functions, then the neuropsychological testing codes should be used no matter which tests are done.
Q. If I spend less than one hour on interpretation and reporting, after my technician has conducted a test, can I bill for the full hour?
A. It depends on how much time you spend. If you spend 30 minutes or less, then you must bill the code using the -52 modifier which indicates a reduced service. If you spend more than 30 minutes then you may bill for the full hour. The same applies to billing the technician code if the technician spends less than one hour on testing.
Q: What is the definition of “technician” under the revised codes?
A: The revised codes do not include a definition of a technician. The question of who can serve as a technician for purposes of psychological or neuropsychological testing may be determined by state law and/or coverage policies of third party payers. In addition,
Division 40 of APA, the American Academy of Clinical Neuropsychology, and the National Academy of Neuropsychology all have policies on the use and training of technicians, and define administration and scoring as appropriate roles for them. However, it should be noted that under the revised CPT codes, scoring is not a billable activity, unless it is done while the technician is face-to-face with the patient during the test administration.
Q: Do the revised codes allow for students or trainees to administer tests?
A: Yes. Because the codes do not contain a definition of the term “technician,” students’ and trainees’ time spent conducting tests may be billed under the technician-based codes (96102 or 96119) so long as this does not conflict with any applicable laws or policies.
Q: Can students or other unlicensed individuals interpret and report test results?
A: No. Only a licensed psychologist or other licensed health care professional may bill for time spent on interpretation and reporting psychological and neuropsychological tests.
Q: What should I do if a carrier tries to restrict my use of the psychologist-based code?
A: Some psychologists have expressed a concern that private insurance carriers could impose the restriction that they will only pay for technicians to administer tests (thus only reimbursing psychologists for interpreting tests and writing reports). If you become aware of such activity, please alert the Practice Directorate’s Office of Legal & Regulatory Affairs at (202) 336-5886 or by email at praclegal@apa.org. We will be ready to respond to such restrictions should there be any attempt to impose them.
Q: Where can I get help with questions about or billing problems related to the revised codes?
A: Anyone with questions or billing problems should call the Practice Directorate’s Government Relations Department at (202) 336-5889 or email pracgovt@apa.org.
Current Procedural Terminology © 2006 American Medical Association. All Rights Reserved.
