Up to code: Examining the new testing codes

By APA Office of Health Care Financing

Beginning on Jan. 1, 2019, there will be new billing codes for psychological and neuropsychological testing services. The current codes, 96101-96103 and 96119-96120, will be eliminated after Dec. 31, 2018. The new set of codes can be found on the Practice Central website in the Reimbursement section or by visiting the Psychological and Neuropsychological Testing Codes for Psychologists webpage. In this article, psychology and legal experts at APA address the most pressing questions submitted by members following the release of the new family of testing codes and during the recent testing codes webinar.

Where/when will the Relative Value Units (RVUs) be posted?

RVUs will be released by the Centers for Medicare and Medicaid Services (CMS) in November 2018 and will be available on their Physician Fee Schedule Federal Regulation Notices page. APA will present these values and the payment structure for the testing codes during the Dec. 5 webinar. Payment information will also be added to the Reimbursement section of Practice Central once it is available.

Are these the procedure codes to use for all insurance companies?

Yes. Beginning Jan. 1, 2019, Medicare and private insurers will provide reimbursement for testing services utilizing the new coding structure.

Do you anticipate that base and add-on codes will have different rates of reimbursement?

Yes. The differences will be detailed in the final rule released by CMS in November.

How are students or postdoctoral trainees who provide test administration and/or scoring services while supervised by licensed psychologists treated in the new coding structure?

Specific guidance for assessment provided by unlicensed trainees under the supervision of licensed psychologists and neuropsychologists is not addressed by the new coding structure. This is something that is decided by Medicare, Medicaid and other third-party payers. 

CMS has specifically stated that under the Medicare Physician Fee Schedule there is no payment for services performed by students or trainees. Accordingly, Medicare does not pay for services represented by CPT codes 96102 and 96119 (the current technician codes) when performed by a student or a trainee. This position will not change with implementation of the new testing codes.

If I see a patient in 2018 and bill in 2019, which codes do I use?

All services provided through Dec. 31, 2018, regardless of when the bill is submitted, should use the old codes.

How should we handle testing cases that are being scheduled or are already scheduled for the end of 2018?

We strongly recommended adjusting your schedule as needed to complete all work on cases that began in 2018 by Dec. 31, 2018.

Can you use both a technician and a professional for administration and scoring with the same client/claim or does it have to be one or the other?

It is our understanding that you should use the code or codes that best describe the actual work taking place. If both a technician and a psychologist are doing some of the administration and scoring on the same evaluation, then yes, both codes should be used, documenting the time spent by each.

Is there a cap on the number of units billed? How will that be determined?

Any potential maximums or average number of units to be billed will be determined by CMS and individual insurers.

Could you provide any examples of what types of testing would typically be considered billed under 96116 and 96121? 

96116 and 96121 are the CPT codes for Neurobehavioral Status Exam. The neurobehavioral status exam is a clinical interview examination that might include use of some briefer behavioral measures to determine the individual’s mental status. It typically does not involve administration of neuropsychological tests, which would be subsumed under the testing codes.

APA staff have received numerous questions regarding specifics on how to bill the base codes versus the add-on codes for multi-day evaluations or in cases where the feedback session with the client is scheduled at a later date. Responses to these payment policy questions will be available when CMS releases the final rule with the fee schedule in November.

Want to learn more?

Join us on Wednesday, Dec. 5 at 12 p.m. EST as Antonio Puente, PhD, and Neil Pliskin, PhD, continue to discuss the specific changes to the codes covered in the July and October webinars as well as introduce CMS’s new payment structure. Registration for this webinar opens Nov. 1.

Please note: This question-and-answer set was prepared based on information available in October 2018 and is subject to change as we learn more about the 2019 testing codes and their implementation. The APA Practice Organization will continue to keep members apprised of related developments. Visit the Reimbursement section of the Practice Central web site and check our biweekly PracticeUpdate e-newsletter.