Billing for psychological services provided during the COVID-19 public health emergency

These examples illustrate how to use specific CPT^® codes, place of service (POS) and modifiers on patient billing forms for Medicare during the COVID-19 public health emergency.

Patient is a 46-year-old woman who has completed 5 of 6 scheduled treatment sessions for moderate depression.

Place of service

POS code 11 has been entered to indicate that each service was provided to this patient from the “Physician Office.”

• During COVID-19, CMS instructs practitioners to report the POS code that would have been reported had the service been provided in person at their regular POS to ensure the telehealth service is paid at the non-facility rate. Visit the CMS website for additional information on POS codes (PDF, 162KB).

March 20, 2020

Patient completed session 6 of psychotherapy focusing on reviewing her activity levels and managing self-critical thoughts. Her depression rating scores were in the range of minimal depression. Two additional sessions were scheduled for a month later to continue developing a relapse prevention plan.

• CPT^® Code 90834; Psychotherapy, 45 minutes with patient via Telehealth

Modifier use: The CPT telehealth modifier, modifier 95, is entered to explain that services were provided via telehealth.

March 28-April 4, 2020

On March 28, the patient submits an online query through the EHR portal about her decrease in activity due to the COVID-19 stay at home order and worry about her husband’s recent job loss. Upon reviewing the symptoms outlined on the patient query, the psychologist responds through the portal assessing depressive symptoms in case they warrant an in-person office or emergency department (ED) visit.

Subsequent to the patient’s reassuring response, the psychologist follows up online regarding use of cognitive/behavioral techniques the patient has been previously taught and instructs patient to use these techniques. Several hours later, after employing the cognitive/behavioral techniques, the patient provides her psychologist with a symptoms update along with pre-and post-treatment depression symptom ratings.

On the third day, the patient provides the psychologist with a follow-up portal message stating that symptoms are improving. The psychologist saves the clinical documentation in the EMR as an e-visit encounter to support reporting a professional claim.

• HCPCS code G2062; Qualified nonphysician healthcare professional online assessment service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes

Modifier use: This service is regularly provided online but is not considered a Medicare telehealth service; therefore, no modifier (not even modifier 95) is required to be used with online assessment and management services (CPT codes G2061, G2062, G2063).

April 12-April 18, 2020

On April 12, the patient calls expressing renewed concern about her decreasing activity levels and some self-critical thoughts she was having. The psychologist spends time on the telephone normalizing the patient’s feelings during the public health emergency. They spend several minutes reviewing her work on self-critical thinking and increasing self-compassion.

The patient also brainstormed several virtual activities she could participate in this week. They agree that they will reconnect via telehealth for her regularly scheduled psychotherapy appointment on April 24.

• CPT^® Code 98967; Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion

Modifier use: This service is regularly provided remotely over the telephone but is not considered a Medicare telehealth service; therefore, no modifier (not even modifier 95) is required to be used with telephone services (CPT codes 98966, 98967, 98968).

Reminder: Telephone assessment and management services can be billed for new and established patients; however, they cannot be billed if the call results in a face-to-face service (including via telehealth) within the next 24 hours

A 25-year-old male, who is experiencing depressive symptoms, social withdrawal and substantial fatigue, presents with a positive history of recent emotional trauma. His primary care physician refers him for psychological testing.

Place of Service

POS code 11 has been entered to indicate that each service was provided to this patient from the “Physician Office.”

• During COVID-19, CMS instructs practitioners to report the POS code that would have been reported had the service been provided in person at their regular POS to ensure the telehealth service is paid at the non-facility rate. Visit the CMS website for additional information on POS codes (PDF, 162KB).

April 20-22, 2020

An evaluation for Major Depressive Disorder and Psychosis assessment is conducted via telehealth over three dates of service.

The psychologist performs the diagnostic interview (1 unit of 90791), does the preliminary selection of tests for 15 minutes (portion of a unit of 96130) and completes the first 30 minutes of test administration (1 unit of 96136) on April 20.

The next day, a technician performs 90 minutes of test administration and scoring (1 unit of 96138 + 2 units of 96139) and the psychologist performs additional elements of evaluation services 96130 (i.e. interpretation, integration) for 55 minutes (fulfilling the remaining amount of 96130 from day 1 and part of the first unit of 96131).

On April 22, the psychologist spends 50 minutes completing the evaluation services, including report creation/distribution, and then meets with the patient via telehealth for 60 minutes for an interactive feedback session (fulfilling remaining unit of 96131 from day 2 and adding an additional unit).

• CPT^® Code 90791; Psychiatric diagnostic evaluation via Telehealth

Modifier use: The CPT telehealth modifier, modifier 95, is entered to explain that services were provided via telehealth.

• CPT code 96136; Psychological or neuropsychological test administration and scoring by physician or other qualified health care professional, two or more tests, any method; first 30 minutes via Telehealth

Modifier use: The CPT telehealth modifier, modifier 95, is entered to explain that services were provided via telehealth.

• CPT codes 96138/+96139; Psychological or neuropsychological test administration and scoring by technician, two or more tests, any method; first 30 minutes/each additional 30 minutes (List separately in addition to code for primary procedure) via Telehealth

Modifier use: The CPT telehealth modifier, modifier 95, is entered to explain that services were provided via telehealth.

An additional modifier is required in cases when the psychologist and the technician perform test administration and scoring for same patient, on the same date of service.

In this example, modifier -XE was appended to CPT code 96138 to indicate that the test administration and scoring performed by the technician took place at a separate time or encounter from the psychologist’s initial test administration.

However, if the test administration and scoring took place during the same encounter, modifier -59 would need to be used. For more information, please refer to pages 6-7 of the APA 2019 Psychological and Neuropsychological Testing Billing and Coding Guide.

• CPT codes 96130/+96131; Psychological testing evaluation services by physician or other qualified health care professional, including integration of patient data, interpretation of standardized test results and clinical data, clinical decision making, treatment planning and report, and interactive feedback to the patient, family member(s) or caregiver(s), when performed; first hour /each additional hour (List separately in addition to code for primary procedure) via Telehealth

Modifier use: The CPT telehealth modifier, modifier 95, is entered to explain that services were provided via telehealth.