Telephone assessment and management services

Qualified health care professionals (QHPs) — including psychologists — can receive reimbursement for time spent on audio-only telephone services if a patient calls because they are experiencing mental health issues or symptoms.

Telephone assessment and management services are patient-initiated non-face-to-face services provided by a QHP to a patient, parent, or guardian via real-time phone conversation. The services are billed using CPT® codes 98966, 98967, and 98968. Confirm access to these codes with your third-party payer prior to usage.

Telephone assessment and management services are not considered telehealth services; therefore, real-time audio/visual equipment is not required.

Typically, these calls involve:

• Obtaining a patient history
• Assessing the patient's condition
• Making a medical decision
• Communicating that decision via the phone with the patient

Psychologists should document the cumulative time spent on these services as they may only be reported once during a seven-day period (i.e. if more than one telephone call is required to complete the consultation request, the entirety of the service and the cumulative discussion and information review time should be reported with a single code). The nature of the service and other pertinent information should also be documented in the medical record (see below).

If the telephone call is in reference to a service performed and reported by the provider within the previous seven days, the telephone service codes cannot be reported. Further, if the telephone call results in the decision to see the patient within 24 hours, the telephone service cannot be reported, as it would be considered part of the subsequent visit.

Telephone assessment and management codes were built for relatively brief and directed services and, therefore, reimburse at a significantly lower rate when compared to services used for delivering ongoing therapy. For example, CPT code 90832, which is used to report 30 minutes of face-to-face psychotherapy, has a work RVU (wRVU) of 1.50.

*Although the code descriptor specifies that these services are to be provided to an established patient, the Centers for Medicare and Medicaid Services (CMS) stated in their March 30, 2020 interim final rule that these codes may be used for new and established Medicare patient visits during the current COVID-19 public health emergency.

Documentation of telephone assessment and management service should include the following elements:

• Notation that the telephone call was patient-initiated
• The length of the phone call and the nature of the service and other pertinent information
• Confirmation that the patient verbally consented to the service
• Assertation that the call was not related to a service performed and reported within previous seven days

• Do not report telephone services for consultations that last less than five minutes.
• Report telephone services once per seven-day period.
• If the patient is a minor, the episode of care must be initiated by a guardian/parent.
• Do not use telephone service codes if the initial inquiry from the patient comes within seven days of a previous treatment or service that both relate to the same problem.
• Similarly, do not use telephone service codes if the conversation results in the decision to see the patient within 24 hours.
• If the patient presents a new, unrelated problem within the seven-day period of a previous telephone service, add time spent on the assessment and management of the additional problem to the cumulative service time.
• For telephone services lasting longer than 30 minutes, APA is seeking clarification from payers regarding whether two telephone service CPT codes can be reported together in order to report the appropriate cumulative time. We will continue to provide updates. Psychologists can also contact their payers directly.

As stated above, telephone assessment and management codes were built for brief and directed services and, therefore, reimburse at a significantly lower rate when compared to services used for delivering ongoing therapy. For example, CPT code 90832, which is used to report 30 minutes of face-to-face psychotherapy, has a work RVU (wRVU) of 1.50, a Non-Facility (NF) Total RVU of 1.97, and a Medicare NF payment amount of $71.10. Below are the three (3) telephone services codes as well as their wRVU, NF total RVU, and projected average non-facility Medicare reimbursement.