Up-to-Code: Understanding the new testing codes

Beginning 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 Centers for Medicare and Medicaid Services (CMS) have proposed reimbursement rates for the new testing codes in the proposed rule on the 2019 Medicare fee schedule. In this article, psychology and legal experts at APA address the most pressing questions submitted by members following the announcement of the upcoming changes and during the recent testing codes webinar provided by the APA Practice Organization.

Q: With the expected changes, will psychologists see increases or decreases in their Medicare payments for testing services in 2019?

Under the new coding structure for testing services, psychologists and neuropsychologists will bill using codes that are valued differently than the current codes. The values for each of these new codes will vary depending upon who is doing the service and whether it is a base code or an add-on code for subsequent periods of service. Based on a close examination of the proposal, we project that the Medicare payment for a six-hour battery of psychological tests, with the tests administered by the psychologist, would increase 6.3 percent. The Medicare payment for a comparable six-hour battery of neuropsychological tests administered by a technician and evaluated by the psychologist would increase 6.8 percent. The payment for a neuropsychological test battery, both administered and evaluated by a psychologist, would decrease by just over 3 percent. Please note that these examples reflect the rates for nonfacility services and are based on a total of six hours of administration and evaluation only.

Q: Why is APA calling it a win if psychologists and neuropsychologists that do their own testing are going to see a 3 percent decrease?

There was a legitimate chance of a catastrophic double-digit decrease across the board. CMS targeted these codes for revision and tasked the American Medical Association’s (AMA) Current Procedural Terminology (CPT^®) and Resource Based Relative Value Update Committees (RUC) with restructuring and revaluing the codes. Due to the very confidential nature of the CPT and RUC processes, we could not inform APA members of these potential catastrophic decreases; in fact, if we had broken confidentiality, APA would have been removed from future CPT and RUC reviews.

Even though we couldn’t say anything, our staff went to work. Following two years of advocacy at the CPT and RUC level and successful passage of the restructured code family, APA’s Practice Organization staff met repeatedly with CMS throughout the year to ask the agency not to make substantial cuts in testing service payments, and to convey the importance of testing services in caring for Medicare beneficiaries. We are gratified that CMS listened and rejected the significant reductions in payments that had been under consideration.

We are pleased to see that based on the proposal most psychologists will not see a decrease and will in fact receive a 6 percent increase for providing a psychological assessment battery regardless of whether they use a technician or collect their own data. The 6 percent increase and even the 3 percent decrease for a neuropsychological battery conducted entirely by a psychologist are truly huge wins. 

Q: How are folks to code/bill for and distinguish time spent doing technical work versus time spent doing professional work? What does “Must use tech only with professional service” mean?

The new coding structure strives to eliminate problems that resulted from professional and technician work being billed together in the same code and will include separate testing/data gathering codes for those who use technicians versus those who do their own test administration. It will also include scoring time for tech work. The codes for technician-administered tests must be billed along with the code(s) for evaluation by the psychologist (as highlighted on slide 19 in the July 2018 testing codes webinar).

Until the AMA publishes the new code descriptors and numbers in late September, we are unable to provide specific guidance on how to code for the separate work other than to reiterate the importance of accurately and appropriately documenting the cognitive work performed by psychologists in the new testing code structure. Further guidance on the new codes and how to use them will be provided via newsletter articles and additional webinars by the APA Practice Organization in the late Fall, after CMS releases the final rule.

Q: What about trainees (students, MAs, interns, post-docs) who do testing under supervision?

Specific guidance for assessment provided by unlicensed trainees under the supervision of licensed psychologists and neuropsychologists is not addressed in the proposal and will not be addressed in the final rule. 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 the new testing codes.

Q: Are there certain qualifications a technician must have?

Specific guidance on assessment technician qualifications is not addressed in the proposal and will not be addressed in the final rule. Psychologists should check with their state psychology licensing board and state psychological practice acts to determine whether psychologists may use supervised personnel for testing activities; what kinds of activities may be performed; and what qualification those persons must have. The associated state, provincial and territorial psychological associations (SPTAs) may also be a good resource for finding this information.

Q: What were some of the problems with the current system that the new testing codes attempt to address?

In crafting the new testing codes, APA addressed multiple issues psychologists and payers were encountering with the current system. As a result of APA’s advocacy work, the new testing codes solved a number of problems, including:

• The “double dip” perception when unique work is performed by both the professional and technician on the same day. According to the CMS proposal, “[t]his new coding effectively unbundles codes that currently report the full course of testing into separate codes for testing administration…and evaluation.” By doing this, the new coding structure eliminates ongoing CMS and commercial payer concerns with payments for technician services under the current codes.
• Psychologists were not being compensated for non-face to face work by a professional and/or technician. Under the new codes, they can be.
• The new codes clear up confusion over how to bill across multiple days of service.
• The new codes clear up how to code the “Interactive feedback.”

Please note: This question-and-answer set was prepared based on information available early in August 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. Further guidance on the new codes and how to use them will also be provided via additional upcoming webinars.