by Government Relations Staff

September 6, 2006 — Practicing psychologists are eligible to bill for applicable services and receive reimbursement from Medicare using new "health and behavior assessment and intervention" Current Procedural Terminology (CPT)® codes. These codes, which took effect in January 2002, apply to psychological services that address behavioral, social and psychophysiological conditions in the treatment or management of patients diagnosed with physical health problems. The Practice Directorate and other key APA representatives developed and won the inclusion of these codes in the CPT manual.

This question-and-answer guide provides information about the health and behavior assessment and intervention CPT codes and addresses frequent inquiries from APA members.

The use of these CPT codes requires a physical health diagnosis. Typically, health and behavior assessment and intervention services address an assortment of physical health issues — including patient adherence to medical treatment, symptom management, health-promoting behaviors, health-related risk-taking behaviors and overall adjustment to physical illness.

Yes, being diagnosed with a mental health disorder does not preclude a patient from being eligible to receive health and behavior services to address a diagnosed physical health problem.

Medicare reimburses for five out of the six codes, with the exception of 96155 (family intervention without the patient present). Some private health insurance plans have begun to pay for these codes as well. Private insurance plans may have payment policies that are more or less restrictive than under Medicare. Psychologists should check with the private insurer about a plan's payment policies regarding these codes.

All Medicare carriers are now reimbursing for the health and behavior assessment and intervention codes. First Coast Service Options in Florida finally agreed to recognize these codes effective April 2006.

As of July 2006, more than 50 private health plans are paying for these CPT codes. The Practice Directorate continues to work with psychologists to convince more private insurers to reimburse for health and behavior assessment and intervention services.

The health and behavior assessment and intervention code numbers and their descriptions can be found in a section of the CPT manual entitled, "Health and Behavior Assessment and Intervention". The codes are not listed in the psychiatric section of the CPT manual.

No, health and behavior assessment and intervention services are delivered to patients with an established physical health problem that has been diagnosed by a physician.

Psychologists, nurses, licensed clinical social workers, and other nonphysician health care clinicians whose scope of practice permits can bill the codes. Physicians performing similar services should use Evaluation and Management codes.

Psychologists cannot bill Evaluation and Management (E&M) codes when treating Medicare beneficiaries because the Center for Medicare and Medicaid Services (CMS) currently restricts the use of these codes. CMS has taken the position that E & M codes involve services unique to medical management, such as medical diagnostic evaluation, drug management, and interpreting laboratory or other medical diagnostic studies.

Although there are some similarities among the services, the health and behavior codes should not be viewed as a substitute for E&M codes. APA is continuing its advocacy with CMS to permit psychologists to be reimbursed for providing E&M services to Medicare beneficiaries.

Psychologists treating patients with private insurance may be able to bill for E&M services because not all insurers impose the same restrictions as Medicare. Psychologists should check with the private carrier to determine its policy on E&M services.

No, only an ICD-9-CM physical diagnosis code should be used in connection with these services. A physical diagnosis code applies since health and behavior assessment and intervention services focus on patients whose primary diagnosis is a physical health problem.

No, the psychologist’s scope of practice prohibits the clinician from diagnosing a physical health problem. Therefore, the existing medical diagnosis made by a physician should be used by a psychologist when reporting services captured under the codes.

No, the Outpatient Mental Health Treatment Limitation — whereby Medicare reduces its copayment for mental health services from 80 percent to 50 percent — only applies to services provided to outpatients with a mental, psychoneurotic, or personality disorder identified by an ICD-9 CM diagnosis code between 290 and 319. Health and behavior assessment and intervention services provided to outpatients are reimbursed at 80 percent.

Nationwide Medicare reimbursement rates are subject to geographic adjustment. To find out exact payments for health and behavior assessment and intervention services, psychologists should check with the local Medicare carriers in their geographic area.

Because private third-party insurance plans may have payment policies that differ from Medicare, psychologists should check with the insurer to find out about the reimbursement rates for these CPT codes. As explained in the answer to Question 5, only a few private insurers are now paying for these codes.

Each code is based on 15 minutes of service, face-to-face contact with the patient. Consequently, psychologists should report 1 unit per 15 minutes of the service. For example, a psychologist would bill 2 units for a 30-minute service and 3 units for a 45-minute service.

When the service falls between units, the healthcare provider must round up or down to the nearest increment. To illustrate, a psychologist would bill 3 units for a 50-minute service but would bill 4 units for a 55-minute service.

Values for CPT codes are periodically reviewed under the AMA's coding and reimbursement committee process. When it is time for the health and behavior codes to be reviewed, members of health professional groups that bill for these codes will be surveyed to ascertain if the complexity of the services has changed since the codes were first valued, thereby warranting a change in reimbursement rates.

It is extremely important that psychologists use the health and behavior codes when appropriate and participate in related code surveys. There are two main reasons. 

First, the survey process involves health professionals comparing codes for the specified service(s) to other services for which they bill. Psychologists' services generally are valued more highly than the services provided by other health care professionals who also use the health and behavior codes. Therefore, when surveyed, psychologists will make their comparisons to CPT codes that generally carry higher reimbursement values. Since other health professionals being surveyed will compare the codes to services with lower reimbursement values, their final recommendations for revised values for the health and behavior codes likely will be lower than those of psychologists. 

In addition, the health professional association whose members bill particular codes most often generally have the lead role on any projects involving the codes, including conducting surveys on code values. Until now, APA has headed all efforts involving the health and behavior CPT codes. But if other health professionals bill for these codes more often than psychologists, another professional group is likely to assume the lead role in the future.

Yes, the codes are subject to the National Correct Coding Initiative (NCCI). The NCCI is a series of correct coding methodologies based in part on the coding standards defined in the American Medical Association’s CPT manual, coding guidelines of numerous national specialty societies, principles of customary medical practice, and a continuous assessment of current coding practice. CMS developed the NCCI to help health care providers with coding their services properly for reimbursement. 

A number of private third-party payers have adopted the NCCI, but some insurers have developed coding guidelines of their own. Psychologists should check with private insurance plans about guidelines that are different from coding conventions under Medicare.

Yes, under the NCCI:

  • Health and behavior assessment and intervention codes cannot be used for treating patients with a psychiatric diagnosis.

  • The clinician cannot bill psychiatric codes (CPT codes 90801 - 90899) and health and behavior assessment and intervention codes (CPT codes 96150 - 96155) on the same day. For services rendered to patients that require both psychiatric and health and behavior assessment and intervention services, the clinician must report the principal service being provided.

Psychologists can get information from their local fiscal intermediary or CMS regional office about billing Medicare for these codes in a facility setting. When dealing with private third-party payers, psychologists should contact the individual insurer about that insurer's procedures for facility billing.

If receiving a denial from Medicare after reporting services associated with the codes, you should first contact your local Medicare carrier to find out what the problem is. In the case of an outright claim denial, Medicare offers health professionals an appeals process at the local level. A majority of local Medicare carriers have websites where information on appeals can be found.

Psychologists reporting services to private insurance plans should check with the carrier about appeal opportunities available to them.

Yes. APA wants to know about any difficulties psychologists experience in billing these codes with either Medicare or private insurers. Psychologists should contact the Practice Directorate’s Government Relations Office at (202) 336-5889.

Yes, beyond the local Medicare carrier, psychologists can contact the office of the Center for Medicare and Medicaid Services (CMS) in their region.

Further, the "Health and Behavior Assessment and Intervention" section of the CPT manual includes code numbers and their descriptions.