New CPT® codes for psychological and neuropsychological testing services, issued by the American Medical Association, entered into effect on Jan. 1, 2019. The new codes strive to eliminate several problems that existed under the prior code set for testing services and generally allow for a more accurate description of the work performed. Practitioners must use these new codes when billing Medicare, Medicaid and commercial insurance carriers.
Unfortunately, payers have been slow to implement the new codes. A variety of practical and organizational challenges have led to widespread delays and other difficulties. A significant number of these problems have occurred within state Medicaid agencies and Medicaid managed care organizations (MCOs). As a consequence, many psychologists who provide testing services to the Medicaid population are struggling with delays in payment, inconsistent claims processing and other negative repercussions.
Since January, the American Psychological Association and its companion organization, APA Services Inc., have been working to identify and resolve these issues. Through its own outreach and data collection, combined with reports received from psychologists across the country, APA Services Inc. has learned of problems with the implementation of the new codes in the Medicaid program in 25 states: Arizona, Connecticut, Florida, Georgia, Illinois, Iowa, Kansas, Kentucky, Louisiana, Massachusetts, Minnesota, Mississippi, Montana, Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Texas, Washington and Vermont.
Problems typically reported include the following:
- Delays in publishing a fee schedule.
- Delays in activating the new codes and/or in configuring computer systems to process them.
- Payers not making all the new codes available for use (e.g., not reimbursing for technician codes).
- Reductions in overall reimbursement.
- Individual Medicaid MCOs at times accepting claims, at times denying them, with no consistent policy.
- Inconsistent messaging and/or lack of communication from payers.
Given that each state Medicaid program is unique, efforts by APA Services Inc. to resolve these issues take different forms in different states. At times, APA Services Inc. plays a supporting role, assisting with strategy and messaging and providing legal research to state psychological associations and individual members working to solve problems in their states. APA Services Inc., for example, provided strategy support at the outset of successful efforts by the Connecticut state psychological association to reverse its Medicaid agency’s reimbursement cuts for the new codes and by the Mississippi association to overturn its agency’s decision to not reimburse for the new test administration codes (96136/96137).
In other instances, direct outreach by APA Services Inc. to Medicaid MCOs has facilitated the resolution of issues being faced by psychologists. For example, staff experts reached out to MCOs in New Hampshire and Pennsylvania to address ongoing delays in payment. APA Services Inc. believes these issues have now been resolved.
To assist APA and APA Services Inc. in this continuing effort to identify and resolve problems with implementation of the new testing codes in the Medicaid program, please report any such problems to the APA Office of Legal and Regulatory Affairs via email.
Article published May 2, 2019