2006 nan advanced cpt 2006 nan advanced cpt 1 Coding, Billing and Coding, Billing and Documenting Clinical Documenting Clinical Neuropsychological Services: Neuropsychological Services: An Advanced Presentation An Advanced Presentation Antonio E. Puente Antonio E. Puente University of North Carolina Wilmington University of North Carolina Wilmington National Academy of Neuropsychology National Academy of Neuropsychology October 26, 2006 October 26, 2006
Transcript
2006 nan advanced cpt2006 nan advanced cpt 11
Coding, Billing and Documenting Coding, Billing and Documenting Clinical Neuropsychological Services:Clinical Neuropsychological Services:
An Advanced PresentationAn Advanced Presentation
Antonio E. PuenteAntonio E. PuenteUniversity of North Carolina WilmingtonUniversity of North Carolina Wilmington
National Academy of NeuropsychologyNational Academy of NeuropsychologyOctober 26, 2006October 26, 2006
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DisclaimerDisclaimer
The information contained in this extended presentation is The information contained in this extended presentation is not intended to reflect NAN, APA, Division 40, NCPA, AMA, not intended to reflect NAN, APA, Division 40, NCPA, AMA, and/or CMS policy. Further, this presentation is intended and/or CMS policy. Further, this presentation is intended to be informative and not meant to imply that it to be informative and not meant to imply that it supersedes APA or state licensing boards’ ethical supersedes APA or state licensing boards’ ethical guidelines and/or local, state or national regulations and/or guidelines and/or local, state or national regulations and/or laws. Further, Local Coverage Determination and specific laws. Further, Local Coverage Determination and specific health care contracts supersedes the information health care contracts supersedes the information presented. The information contained herein is meant to presented. The information contained herein is meant to provide practitioners as well as health care institutions provide practitioners as well as health care institutions (e.g., insurance companies) involved in psychological (e.g., insurance companies) involved in psychological services with the latest information available regarding services with the latest information available regarding the issues addressed. This is a living document that can the issues addressed. This is a living document that can and will be revised as additional information becomes and will be revised as additional information becomes available. The ultimate responsibility of the validity and available. The ultimate responsibility of the validity and utility of the information contained herein lies with the utility of the information contained herein lies with the individual and/or institution using this information and not individual and/or institution using this information and not with any supporting organization and/or the author of this with any supporting organization and/or the author of this presentation. Suggestions or changes should be addressed presentation. Suggestions or changes should be addressed to the author. Thank you…to the author. Thank you…
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AcknowledgmentsAcknowledgments
North Carolina Psychological AssociationNorth Carolina Psychological Association American Medical Association (AMA) CPT StaffAmerican Medical Association (AMA) CPT Staff American Psychological Association (APA) Practice Directorate (PD)American Psychological Association (APA) Practice Directorate (PD) National Academy of Neuropsychology (NAN)National Academy of Neuropsychology (NAN) Division of Clinical Neuropsychology of APA (40)Division of Clinical Neuropsychology of APA (40) Center for Medicare & Medicaid Services (CMS) Medical Policy Center for Medicare & Medicaid Services (CMS) Medical Policy
Staff- MedicareStaff- Medicare
Special thanks to theDepartment of Psychology, UNC-Wilmington, Special thanks to theDepartment of Psychology, UNC-Wilmington, James Georgoulakis, Neil Pliskin, Ted Peck and AEP’s Clinical and James Georgoulakis, Neil Pliskin, Ted Peck and AEP’s Clinical and Research StaffResearch Staff
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Specific Support Provided by Primary Specific Support Provided by Primary OrganizationsOrganizations
APA = All expenses paid for travel associated with APA = All expenses paid for travel associated with AMA CPT activitiesAMA CPT activities
NAN = (from PAIC budget) applied to UNCW NAN = (from PAIC budget) applied to UNCW activitiesactivities 2006 = $25,000 per year – two course per semester 2006 = $25,000 per year – two course per semester
teaching reduction per academic yearteaching reduction per academic year UNCW = Time away from university duties (e.g., UNCW = Time away from university duties (e.g.,
teaching) plus incidental support such as copying, teaching) plus incidental support such as copying, telephone calls, secretarial and work-study telephone calls, secretarial and work-study student assistancestudent assistance
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Part I: Coding, Billing & Part I: Coding, Billing & DocumentationDocumentation
Part I:Part I: A. MedicareA. Medicare B. Current Procedural TerminologyB. Current Procedural Terminology C. DiagnosingC. Diagnosing D. Medical NecessityD. Medical Necessity E. Documentation E. Documentation F. TimeF. Time G. TechniciansG. Technicians H. SupervisionH. Supervision
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A. Medicare: Why?A. Medicare: Why?
TheThe Standard for Universal Health Care: Standard for Universal Health Care: Coding (what can be done)Coding (what can be done) Value (how much it will be paid)Value (how much it will be paid) Documentation (what needs to be said)Documentation (what needs to be said) Auditing (determination of whether it occurred)Auditing (determination of whether it occurred)
Note: While Medicare sets the standard, Note: While Medicare sets the standard, there is no point-to-point correspondence there is no point-to-point correspondence with private carrierswith private carriers
2006 nan advanced cpt2006 nan advanced cpt 77
Medicare: Local ReviewMedicare: Local Review
Medical Review Policy Medical Review Policy National Policy Sets Overall ModelNational Policy Sets Overall Model Local Coverage Determination (LCD) Sets Local Coverage Determination (LCD) Sets
Local/Regional Policy-Local/Regional Policy- More restrictive than national policyMore restrictive than national policy Over-rides national policyOver-rides national policy Changes frequently without warning or publicityChanges frequently without warning or publicity Information best found on respective web pagesInformation best found on respective web pages
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B. Current Procedural B. Current Procedural Terminology (CPT): Terminology (CPT):
OverviewOverview
BackgroundBackground Codes & CodingCodes & Coding Existing CodesExisting Codes Model System X Type of ProblemModel System X Type of Problem
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CPT CopyrightCPT Copyright
CPT is Copyrighted by the American CPT is Copyrighted by the American Medical AssociationMedical Association
CPT Manuals May be Ordered from CPT Manuals May be Ordered from the AMA at 1.800.621.8335the AMA at 1.800.621.8335
2006 nan advanced cpt2006 nan advanced cpt 1010
Psychiatry: InterviewingPsychiatry: Interviewing
InterviewingInterviewing 9080190801 One time per illness incident or boutOne time per illness incident or bout Un-timedUn-timed Comprehensive analysis of records, Comprehensive analysis of records,
observations as well as structured observations as well as structured and/or unstructured clinical interviewand/or unstructured clinical interview
Rationale for CPT Changes:Rationale for CPT Changes:CNS Assessment CodesCNS Assessment Codes
Avoidance of Continuation of Avoidance of Continuation of Reimbursement Heavily Based on Practice Reimbursement Heavily Based on Practice ExpenseExpense
Greater Clarification of Activities Including Greater Clarification of Activities Including Interviewing and Testing by Professional, Interviewing and Testing by Professional, Technician and/or ComputerTechnician and/or Computer
Recognition of Cognitive WorkRecognition of Cognitive Work Great Clarity of What Actual is HappeningGreat Clarity of What Actual is Happening Differentiation of Professional, Technical Differentiation of Professional, Technical
and (non-assisted) Computer Testingand (non-assisted) Computer Testing Most Importantly, a Mandate from CMSMost Importantly, a Mandate from CMS
2006 nan advanced cpt2006 nan advanced cpt 1313
CPT: CNS AssessmentCPT: CNS AssessmentEffective 01.01.06 Effective 01.01.06 (no grace (no grace
Three New CodesThree New Codes New Numbers & DescriptorsNew Numbers & Descriptors
Neurobehavioral Status Exam (e.g., 2 Neurobehavioral Status Exam (e.g., 2 units)units) New Number & Revised DescriptorNew Number & Revised Descriptor
Neuropsychological Testing (e.g., 10 units)Neuropsychological Testing (e.g., 10 units) Three New CodesThree New Codes New Numbers & DescriptorsNew Numbers & Descriptors
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Psychological Testing:Psychological Testing:By ProfessionalBy Professional
9610196101 –Psychological Testing –Psychological Testing Psychodiagnostic assessment of Psychodiagnostic assessment of
emotionality, intellectual abilities, emotionality, intellectual abilities, personality and psychopathology, e.g., personality and psychopathology, e.g., MMPI, Rorschach, WAIS (per hour of MMPI, Rorschach, WAIS (per hour of psychologist’s orpsychologist’s or physician’sphysician’s time, both time, both face-to-face time with the patient and face-to-face time with the patient and time interpreting test results and time interpreting test results and preparing the report)preparing the report)
9610296102- Psychological Testing- Psychological Testing Psychodiagnostic assessment of Psychodiagnostic assessment of
emotionality, intellectual abilities, emotionality, intellectual abilities, personality and psychopathology (e.g., personality and psychopathology (e.g., MMPI, Rorschach, WAIS) with MMPI, Rorschach, WAIS) with qualified qualified health care professionalhealth care professional interpretation interpretation and reportand report, administered by , administered by techniciantechnician, per hour of technician time, , per hour of technician time, face-to-faceface-to-face
9610396103 - Psychological Testing- Psychological Testing Psychodiagnostic assessment of Psychodiagnostic assessment of
emotionality, intellectual abilities, emotionality, intellectual abilities, personality and psychopathology, (e.g., personality and psychopathology, (e.g., MMPI) administered by a MMPI) administered by a computercomputer, , with with qualified health professionalqualified health professional interpretation and the reportinterpretation and the report
2006 nan advanced cpt2006 nan advanced cpt 1717
Neurobehavioral Status Neurobehavioral Status ExamExam
9611696116 - Neurobehavioral status exam - Neurobehavioral status exam Clinical assessment of thinking, reasoning Clinical assessment of thinking, reasoning
and judgment ( e.g., acquired knowledge, and judgment ( e.g., acquired knowledge, attention, language, memory, planning attention, language, memory, planning and problem solving, and visual-spatial and problem solving, and visual-spatial abilities) per hour of abilities) per hour of psychologist’s or psychologist’s or physician’sphysician’s time, both face-to-face time time, both face-to-face time with the patient and time interpreting with the patient and time interpreting test results and preparing the reporttest results and preparing the report
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Neuropsychological Testing-Neuropsychological Testing-By ProfessionalBy Professional
Neuropsychological, WMS, Wisconsin Neuropsychological, WMS, Wisconsin Card Sorting) per hour of the Card Sorting) per hour of the psychologist’s or physician’spsychologist’s or physician’s time, time, both face-to-face time with the patient both face-to-face time with the patient and time interpreting test results and and time interpreting test results and preparing the reportpreparing the report
Neuropsychological, WMS, Wisconsin Neuropsychological, WMS, Wisconsin Card Sorting) with Card Sorting) with qualified health care qualified health care professionalprofessional interpretation and interpretation and reportreport, administered by a , administered by a techniciantechnician per hour of technician time, face-to-faceper hour of technician time, face-to-face
9612096120 - Neuropsychological testing - Neuropsychological testing (e.g., WCST) administered by a (e.g., WCST) administered by a
computercomputer with with qualified health care qualified health care professionalprofessional interpretation and the interpretation and the reportreport
2006 nan advanced cpt2006 nan advanced cpt 2121
CNS Assessment ExamplesCNS Assessment Examples Neurobehavioral Status with Neuropsychological Neurobehavioral Status with Neuropsychological
TestingTesting Interview by the ProfessionalInterview by the Professional Testing byTesting by
Interpretation & Report Writing by Qualified Health Interpretation & Report Writing by Qualified Health ProfessionalProfessional
A Technician or Computer Code are “Typically” Billed A Technician or Computer Code are “Typically” Billed Together with a Professional Code Assuming that Together with a Professional Code Assuming that Different Services are Being Provided (since the final Different Services are Being Provided (since the final product should be a product should be a comprehensive/integrative comprehensive/integrative report)report)
2006 nan advanced cpt2006 nan advanced cpt 2222
CPT: Health & Behavior CPT: Health & Behavior Assessment & ManagementAssessment & Management
Purpose: Medical DiagnosisPurpose: Medical Diagnosis Time: 15 Minute IncrementsTime: 15 Minute Increments AssessmentAssessment InterventionIntervention
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H & B: RationaleH & B: Rationale
Acute or Chronic Health IllnessAcute or Chronic Health Illness Not Applicable to Psychiatric IllnessNot Applicable to Psychiatric Illness However, Both Could be Treated However, Both Could be Treated
Simultaneously But Not Within the Simultaneously But Not Within the Same SessionSame Session
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Health & Behavior Health & Behavior Assessment CodesAssessment Codes
9615096150 Health and behavior assessment (e.g., Health and behavior assessment (e.g.,
each 15 minuteseach 15 minutes face-to-face with the patientface-to-face with the patient initial assessmentinitial assessment
9615196151 re-assessmentre-assessment
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Health & Behavior Health & Behavior Intervention CodesIntervention Codes
9615296152 Health and behavior interventionHealth and behavior intervention each 15 minuteseach 15 minutes face-to-faceface-to-face individualindividual
9615396153 group (2 or more patients)group (2 or more patients)
9615496154 family (with the patient present)family (with the patient present)
9615596155 (limited acceptability)(limited acceptability) family (without the patient present; not being family (without the patient present; not being
reimbursedreimbursed))
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New Code:New Code:fMRIfMRI
96020- Functional Brain Mapping96020- Functional Brain Mapping Neurofunctional test selection and Neurofunctional test selection and
administration during non-invasive administration during non-invasive imaging functional brain mapping with imaging functional brain mapping with test administered entirely by a physician test administered entirely by a physician or psychologist with review of test or psychologist with review of test results and reportresults and report
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CPT: Model SystemCPT: Model System
PsychiatricPsychiatric NeurologicalNeurological Non-Neurological MedicalNon-Neurological Medical
2006 nan advanced cpt2006 nan advanced cpt 2828
CPT ModelCPT Model
Rationale for a Specific CPT Code:Rationale for a Specific CPT Code: Choose Code that Best Describes the Choose Code that Best Describes the
Service Service Match the Interview with the Testing Match the Interview with the Testing
with the Intervention Code with the with the Intervention Code with the DiagnosisDiagnosis
Goal = Uniformity and FluencyGoal = Uniformity and Fluency
InterventionIntervention 9615296152 (individual) (individual) 9615396153 (group)(group) 9615496154 (family with patient)(family with patient)
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ModifiersModifiers(from Appendix A in CPT book; see oig reports)(from Appendix A in CPT book; see oig reports)
ExamplesExamples 22 = reduced service22 = reduced service 25 = additional payment for an E & M code as a 25 = additional payment for an E & M code as a
specific procedure code (problematic)specific procedure code (problematic) 51 = multiple procedures51 = multiple procedures 52 = reduced services52 = reduced services 59 = when two procedures occur on same 59 = when two procedures occur on same
dayday GN, GO, AH, etc. = local carrier specificGN, GO, AH, etc. = local carrier specific
ProblemsProblems Incomplete support for modifier from 15 to 35% Incomplete support for modifier from 15 to 35%
of documentation results in paybacks of documentation results in paybacks
2006 nan advanced cpt2006 nan advanced cpt 3333
National Work National Work RVU/Estimated $ 2006 RVU/Estimated $ 2006
Neurological & Non-Neurological MedicalNeurological & Non-Neurological Medical ICD – 9 CM (physical diagnosis coding)ICD – 9 CM (physical diagnosis coding) www.cdc.gov/nchs/about/otheract/icd9www.cdc.gov/nchs/about/otheract/icd9
2006 nan advanced cpt2006 nan advanced cpt 3535
D. CPT: Medical NecessityD. CPT: Medical Necessity
Scientific & Clinical NecessityScientific & Clinical Necessity Local Medical Review or Carrier Definitions Local Medical Review or Carrier Definitions
of Necessityof Necessity Necessity = CPT x DX formularyNecessity = CPT x DX formulary Necessity Dictates Type and Level of Necessity Dictates Type and Level of
ServiceService Screening or Regularly Scheduled Screening or Regularly Scheduled
Evaluations Do Not Meet Criteria for Evaluations Do Not Meet Criteria for NecessityNecessity
Will New Information or Outcome Be Will New Information or Outcome Be Obtained as a Function of the Activity?Obtained as a Function of the Activity?
2006 nan advanced cpt2006 nan advanced cpt 3636
Medically Reasonable and Medically Reasonable and NecessaryNecessary
““Services which are reasonable and necessary Services which are reasonable and necessary for the diagnosis and treatment of illness or for the diagnosis and treatment of illness or injury or to improve the functioning of a injury or to improve the functioning of a malformed body member”malformed body member”
Re-evaluation should only occur when there is a Re-evaluation should only occur when there is a potential change in;potential change in; DiagnosisDiagnosis SymptomsSymptoms
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E. CPT: DocumentingE. CPT: Documenting
General PrinciplesGeneral Principles AssessmentAssessment InterventionIntervention
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Documentation: Basic Documentation: Basic Information Across CodesInformation Across Codes
DateDate Time, if applicable (total time Vs. actual time)Time, if applicable (total time Vs. actual time) Identity of Observer (technician ?)Identity of Observer (technician ?) Reason for ServiceReason for Service StatusStatus ProcedureProcedure Results/FindingResults/Finding Impression/DiagnosesImpression/Diagnoses DispositionDisposition
Reason for ServiceReason for Service Dates (amount of service time; total Vs. Dates (amount of service time; total Vs.
actual)actual) Identity of Tester (technician?)Identity of Tester (technician?) Tests and Protocols (included editions)Tests and Protocols (included editions) Narrative of ResultsNarrative of Results ImpressionImpression DispositionDisposition
Reason for ServiceReason for Service Status of PatientStatus of Patient Intervention PerformedIntervention Performed Results ObtainedResults Obtained Impression(s) or Diagnosis (es)Impression(s) or Diagnosis (es) DispositionDisposition TimeTime
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Documentation:Documentation:CPT X ReportCPT X Report
Each CPT Code Should Generate a Each CPT Code Should Generate a Separate Report (or at least a Separate Report (or at least a separate section; titles should reflect separate section; titles should reflect the code that is being billed such as the code that is being billed such as “psychological testing)“psychological testing)
Alternatively, Clearly Label/Title Alternatively, Clearly Label/Title Sections of the Report to Match Sections of the Report to Match Codes UsedCodes Used
Consider Having a Multi-level System Consider Having a Multi-level System of Documentation;of Documentation; Raw data (e.g., test protocols)Raw data (e.g., test protocols) Internal routing sheets documenting Internal routing sheets documenting
such information as start/stop time, such information as start/stop time, dates, etc. (a master sheet could track dates, etc. (a master sheet could track technician as well as professional time)technician as well as professional time)
Final reportFinal report
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F. CPT: TimeF. CPT: Time
Time is Broadly Defined as What the Time is Broadly Defined as What the Professional DoesProfessional Does
For Intervention – Time is face-to-For Intervention – Time is face-to-faceface
For Assessment - Time could be For Assessment - Time could be either face-to-face or professional either face-to-face or professional timetime
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TimeTime
DefiningDefining Professional (not patient) Time Including:Professional (not patient) Time Including:
pre, intra & post-clinical service activitiespre, intra & post-clinical service activities Interview & Assessment CodesInterview & Assessment Codes
Use 15 or 60 minute increments, as applicableUse 15 or 60 minute increments, as applicable Intervention CodesIntervention Codes
Use 15, 30, 60 or 90 minute increments, as Use 15, 30, 60 or 90 minute increments, as applicableapplicable
2006 nan advanced cpt2006 nan advanced cpt 4545
Time (continued)Time (continued)
Communicating further with othersCommunicating further with others Follow-up with patient, family, and/or Follow-up with patient, family, and/or
othersothers Arranging for ancillary and/or other Arranging for ancillary and/or other
Billing for Services That Were Not Billing for Services That Were Not Provided” is FraudProvided” is Fraud
The Patient Possibly Could be Billed The Patient Possibly Could be Billed for Missed Appointment (not for for Missed Appointment (not for missed service)missed service)
For Timed Codes (in physical For Timed Codes (in physical medicine): The Beginning and Ending medicine): The Beginning and Ending Time Should be DocumentedTime Should be Documented
Time Should be Documented Along Time Should be Documented Along with the Treatment Descriptionwith the Treatment Description
2006 nan advanced cpt2006 nan advanced cpt 4848
Time: TestingTime: Testing
Quantifying TimeQuantifying Time Round up or down to nearest incrementRound up or down to nearest increment Actual time vs. Elapsed time?Actual time vs. Elapsed time?
Time Does Not IncludeTime Does Not Include Patient completing tests, scales, forms, etc.Patient completing tests, scales, forms, etc. Waiting time by patientWaiting time by patient Typing of reportsTyping of reports Non-Professional (e.g., clerical) timeNon-Professional (e.g., clerical) time Literature searches, learning new techniques, etc.Literature searches, learning new techniques, etc.
2006 nan advanced cpt2006 nan advanced cpt 4949
G. CPT: Defining a G. CPT: Defining a TechnicianTechnician
What is the Minimum Level of What is the Minimum Level of Training Required for a Technician?Training Required for a Technician? National Association of PsychometristsNational Association of Psychometrists
www.napnet.orgwww.napnet.org 40 & NAN Position Paper40 & NAN Position Paper
Level of Education- Probably a minimum of Level of Education- Probably a minimum of BachelorsBachelors
Level of TrainingLevel of Training Level of SupervisionLevel of Supervision
2006 nan advanced cpt2006 nan advanced cpt 5050
Defining a TechnicianDefining a Technician(Federal Register, Vol. 66, #149, page (Federal Register, Vol. 66, #149, page
40382)40382) RequirementRequirement
Employee (e.g., 1099); “employees, leased Employee (e.g., 1099); “employees, leased employees, or independent contractor”employees, or independent contractor”
Most common is independent contractorMost common is independent contractor ““We do not believe that the nature of the We do not believe that the nature of the
employment relationship is critical for purposes employment relationship is critical for purposes of payment to the services of physician…as of payment to the services of physician…as long as…(the personnel) is under the required long as…(the personnel) is under the required level of supervision.”level of supervision.”
Common PracticeCommon Practice Independent ContractorIndependent Contractor
2006 nan advanced cpt2006 nan advanced cpt 5151
Defining a TechnicianDefining a Technician
HCFA/CMS Line 25HCFA/CMS Line 25 This is the line that identifies in a common This is the line that identifies in a common
insurance form who is the “qualified health insurance form who is the “qualified health provider” that is responsible for and completing provider” that is responsible for and completing the servicethe service
Anybody else, from high school to post-doctoral Anybody else, from high school to post-doctoral fellow, is, for all practical purposes, a technicianfellow, is, for all practical purposes, a technician
Federal Government’s Federal Government’s Definition of a TechnicianDefinition of a Technician
DM & S Supplement, MP-5, Part IDM & S Supplement, MP-5, Part I Authority: 38 U.S.C. 4105Authority: 38 U.S.C. 4105 Appendix 17A Change 43Appendix 17A Change 43 Psychology Technician GS-181-5/7/9Psychology Technician GS-181-5/7/9
DefinitionDefinition Bachelor’s degree from accredited Bachelor’s degree from accredited
college/university with a major in college/university with a major in appropriate social or biological sciences (+ appropriate social or biological sciences (+ 12 psy hours)12 psy hours)
2006 nan advanced cpt2006 nan advanced cpt 5353
NAN’s Definition of NAN’s Definition of TechnicianTechnician
Approved by NAN Board of Directors Approved by NAN Board of Directors 08.200608.2006
Archives of Clinical Neuropsychology- Archives of Clinical Neuropsychology- in pressin press
2006 nan advanced cpt2006 nan advanced cpt 5454
NAN’s Definition of a NAN’s Definition of a TechnicianTechnician
Function- administration & scoring of testsFunction- administration & scoring of tests Responsibility- supervisor Responsibility- supervisor Education- minimum, bachelor’s levelEducation- minimum, bachelor’s level Training- include ethics, neuropsy, psychopath, Training- include ethics, neuropsy, psychopath,
testingtesting Confidentiality- APA ethics, HIPAA…Confidentiality- APA ethics, HIPAA… Emergencies- contingencies must be in placeEmergencies- contingencies must be in place Cultural Sensitivity- must be consideredCultural Sensitivity- must be considered Supervision- general (Medicare) levelSupervision- general (Medicare) level Contract- must be in placeContract- must be in place Liability Insurance- must be in placeLiability Insurance- must be in place
2006 nan advanced cpt2006 nan advanced cpt 5555
Use of TechniciansUse of Technicians
Practice Expense & Practice ImplicationsPractice Expense & Practice Implications Each tech code has .51 work valueEach tech code has .51 work value This means that the provider is engaged in the This means that the provider is engaged in the
workwork That engagement would include;That engagement would include;
Selection of testsSelection of tests Determination of testing protocolDetermination of testing protocol Supervision of testingSupervision of testing Interpretation of individual testsInterpretation of individual tests Reporting on individual testsReporting on individual tests
2006 nan advanced cpt2006 nan advanced cpt 5656
Uses of TechniciansUses of Technicians
The Qualified Health Provider must;The Qualified Health Provider must; See the patient firstSee the patient first Supervise the activitySupervise the activity Interpret and write the note/reportInterpret and write the note/report Engaged in an ongoing capacityEngaged in an ongoing capacity
NOTE: Pattern similar to medical NOTE: Pattern similar to medical providersproviders
2006 nan advanced cpt2006 nan advanced cpt 5757
Use of TechnicianUse of Technician
Technicians in a “Facility”Technicians in a “Facility” A “facility” in essentially an inpatient settingA “facility” in essentially an inpatient setting If a technician is an employee of a private If a technician is an employee of a private
provider but the service is provided in an provider but the service is provided in an inpatient setting, the inpatient fee would be inpatient setting, the inpatient fee would be usedused
If a technician is an employee of a a facility, If a technician is an employee of a a facility, there is some question as to whether they there is some question as to whether they could be supervised by a provider who is not could be supervised by a provider who is not an employee of the facilityan employee of the facility
2006 nan advanced cpt2006 nan advanced cpt 5858
H. CPT: SupervisionH. CPT: Supervision( ( Federal Register, Federal Register, 6969, #150, August 5, 2004, page 47553), #150, August 5, 2004, page 47553)
Hold Doctoral Degree in PsychologyHold Doctoral Degree in Psychology Licensed or Certified as a PsychologistLicensed or Certified as a Psychologist Applicable Only to “clinical psychologists” Applicable Only to “clinical psychologists”
(and not “independent” psychologists as (and not “independent” psychologists as defined by Medicare)defined by Medicare)
RationaleRationale Allows for higher level of expertise to superviseAllows for higher level of expertise to supervise Could relieve burden on physicians and Could relieve burden on physicians and
facilitiesfacilities May increase services in rural areasMay increase services in rural areas
Department of Health and Human Services- HCFADepartment of Health and Human Services- HCFATransmittal b-01-28; April 19, 2001Transmittal b-01-28; April 19, 2001
Levels of SupervisionLevels of Supervision GeneralGeneral
Furnished under overall direction and control, Furnished under overall direction and control, presence is not requiredpresence is not required
DirectDirect Must be present in the office suite and immediately Must be present in the office suite and immediately
available to furnish assistance and direction available to furnish assistance and direction throughout the performance of the procedurethroughout the performance of the procedure
PersonalPersonal Must be in attendance in the room during the Must be in attendance in the room during the
performance of the procedureperformance of the procedure
2006 nan advanced cpt2006 nan advanced cpt 6060
Level of SupervisionLevel of Supervision 42 CFR 410.32 42 CFR 410.32
According to Medicare published According to Medicare published guidelines as of July, 2006;guidelines as of July, 2006; General- activity is directed and General- activity is directed and
supervised by the doctoral level supervised by the doctoral level provider but the provider does not need provider but the provider does not need to be in office suiteto be in office suite
2006 nan advanced cpt2006 nan advanced cpt 6161
Part II: Part II: Summary, Resources & Summary, Resources &
Questions/AnswersQuestions/Answers
Summary of Present ProblemsSummary of Present Problems Continuing Concerns With FraudContinuing Concerns With Fraud National Provider Identification NumberNational Provider Identification Number CMS National DirectiveCMS National Directive National Correct Coding Initiative National Correct Coding Initiative
Contact InformationContact Information Questions & AnswersQuestions & Answers
DatesDates Issued September 29, 2006Issued September 29, 2006 Effective Date: January 1, 2006Effective Date: January 1, 2006 Implementation Date: December 28, Implementation Date: December 28,
20062006
2006 nan advanced cpt2006 nan advanced cpt 6565
CMS National Directive: CMS National Directive: Summary of September, 2006 Summary of September, 2006
StatementStatement 5204.15204.1
““Carriers and fiscal intermediaries shall pay for Carriers and fiscal intermediaries shall pay for medically necessary diagnostic psychological medically necessary diagnostic psychological and neuropsychological tests…”and neuropsychological tests…”
5204.25204.2 ““Contractors need not search their files to Contractors need not search their files to
either retract payment for claims already paid either retract payment for claims already paid or to retroactively pay claims to 01.01.06. or to retroactively pay claims to 01.01.06. However, contractors shall adjust claims However, contractors shall adjust claims brought to their attention”.brought to their attention”.
2006 nan advanced cpt2006 nan advanced cpt 6666
CMS National Directive: CMS National Directive: Summary of September, 2006 Summary of September, 2006
StatementStatement
““When diagnostic psychological tests When diagnostic psychological tests are performed by a psychologists are performed by a psychologists who is not practicing independently, who is not practicing independently, but is on the staff of an institution, but is on the staff of an institution, agency or clinic, that entity bills for agency or clinic, that entity bills for the psychological tests.”the psychological tests.”
2006 nan advanced cpt2006 nan advanced cpt 6767
CMS National Directive: CMS National Directive: Summary of September, 2006 Summary of September, 2006
StatementStatement
Independent is defined as:Independent is defined as: ““Free of professional control..”Free of professional control..” ““The persons they treat are their own patients”The persons they treat are their own patients” ““They have the right to bill directly…”They have the right to bill directly…”
For those psychologists practicing in an office For those psychologists practicing in an office located in an institution;located in an institution; The office is confined to a seperately-identified part of The office is confined to a seperately-identified part of
the facility which is used solely as the psychologist’s the facility which is used solely as the psychologist’s officeoffice
The psychologists conducts a private practice…services The psychologists conducts a private practice…services are rendered to patients in and outside of the institutionare rendered to patients in and outside of the institution
2006 nan advanced cpt2006 nan advanced cpt 6868
CMS National Directive: CMS National Directive: Summary of September, 2006 Summary of September, 2006
StatementStatement ““CPT … test codes 96101/96118 should CPT … test codes 96101/96118 should
not be paid when billed for not be paid when billed for the same the same tests or servicestests or services performed under the… performed under the…test codes 96102/103/96119/120.”test codes 96102/103/96119/120.”
““Medicare does not pay for services Medicare does not pay for services represented by CPT codes 96102 and represented by CPT codes 96102 and 96119 when performed by a student or 96119 when performed by a student or a trainee.”a trainee.”
Introduced in March 30, 2006 for Comment; Introduced in March 30, 2006 for Comment; Effective 10.01.06Effective 10.01.06
When 96118, 96119 and/or 961120 occur When 96118, 96119 and/or 961120 occur together, a modifier must be used;together, a modifier must be used; Most appropriate code is probably 59 (possibly Most appropriate code is probably 59 (possibly
51)51) Model used is radiology (when more than one Model used is radiology (when more than one
service is provided by the same provider to the service is provided by the same provider to the same patient)same patient)
2006 nan advanced cpt2006 nan advanced cpt 7070
Use of ModifiersUse of Modifiers
Routine in Medicine, Especially Routine in Medicine, Especially Radiology (since their common use Radiology (since their common use of technicians)of technicians)
Describes That More Than One Describes That More Than One Procedure Was Provide to the Same Procedure Was Provide to the Same Patient on the Same DayPatient on the Same Day
Should not Increase Time to Should not Increase Time to Reimbursement or Audit Probability Reimbursement or Audit Probability Nor Decrease ReimbursementNor Decrease Reimbursement
2006 nan advanced cpt2006 nan advanced cpt 7171
AMA CPT Assistant PublicationsAMA CPT Assistant Publications
Q & A Appeared September, 2006Q & A Appeared September, 2006 Full Length Article Last Approved 10.02.06 & Full Length Article Last Approved 10.02.06 &
to be Published in November, 2006to be Published in November, 2006 A Comprehensive Review of the Information A Comprehensive Review of the Information
Previously PresentedPreviously Presented Approved by the AMA CPT Editorial PanelApproved by the AMA CPT Editorial Panel Allows for the Use of All Codes Simultaneously or Allows for the Use of All Codes Simultaneously or
AloneAlone A Follow-up Q & A to Appear in December, A Follow-up Q & A to Appear in December,
20062006
2006 nan advanced cpt2006 nan advanced cpt 7272
APA’s Official Statement on APA’s Official Statement on Testing CodesTesting Codes
““APA is Going to Work With Outside APA is Going to Work With Outside Counsel to Analyze This Situation and Counsel to Analyze This Situation and Obtain Recommendations on the Obtain Recommendations on the Best Way to Proceed with CMS”Best Way to Proceed with CMS”
““Psychologists Should Read the CMS Psychologists Should Read the CMS Documents Carefully and be Alert for Documents Carefully and be Alert for Any New Information Issued by Their Any New Information Issued by Their Local Carriers”Local Carriers”
2006 nan advanced cpt2006 nan advanced cpt 7373
Potential SolutionsPotential Solutions
Not Accept Medicare Patients (if so, you Not Accept Medicare Patients (if so, you may want to contact your local may want to contact your local representative and/or congressmen)representative and/or congressmen)
Take a Conservative Approach Take a Conservative Approach Interface with Individual Carriers to Develop Interface with Individual Carriers to Develop
Specific Understanding and ProceduresSpecific Understanding and Procedures Use of ModifiersUse of Modifiers
The final decision on how to code rests on the individual The final decision on how to code rests on the individual and/or their institution’s assessment of carrier contract and/or their institution’s assessment of carrier contract as well as their understanding of the current policy as well as their understanding of the current policy situationsituation
2006 nan advanced cpt2006 nan advanced cpt 7474
Ongoing ActivitiesOngoing Activities
CMSCMS Conference Call With CCI Workgroup- late October, 2006 (Niles Conference Call With CCI Workgroup- late October, 2006 (Niles
Rosen, M.D.)Rosen, M.D.) Direct Interfacing with Director of Medical Director’s Workgroup Direct Interfacing with Director of Medical Director’s Workgroup
(Dick Whitten, M.D.)(Dick Whitten, M.D.) AMAAMA
CPT Assistant Article (November, 2006)CPT Assistant Article (November, 2006) CPT Assistant Q & A (December, 2006)CPT Assistant Q & A (December, 2006) CPT Manual- preamble, footnote?CPT Manual- preamble, footnote? Request Presentation at 2007 AMA CPT MeetingRequest Presentation at 2007 AMA CPT Meeting Consider Changing the Language in the CPT ManualConsider Changing the Language in the CPT Manual
Insertion of the words – “limited” or “minimal” or “single test” Insertion of the words – “limited” or “minimal” or “single test” interpretationinterpretation
Deletion of the words – “with interpretation and report”Deletion of the words – “with interpretation and report” APAAPA
Weekly Conference Calls with Psychological Test Work GroupWeekly Conference Calls with Psychological Test Work Group Development of Case Vignettes Along with All PossibleDevelopment of Case Vignettes Along with All Possible Clinical Clinical
PermutationsPermutations Presentation at the State Leadership ConferencePresentation at the State Leadership Conference
New CodesNew Codes 7 + 1 for a total of 8 new codes7 + 1 for a total of 8 new codes Allows the use of technicians and fMRIAllows the use of technicians and fMRI Allows for general supervision (used to be direct)Allows for general supervision (used to be direct)
Greater ReimbursementGreater Reimbursement 22 to 68% increase over 2005 levels22 to 68% increase over 2005 levels
Problems with the Use of Two Codes Problems with the Use of Two Codes Simultaneously with MedicareSimultaneously with Medicare At worse, return to 2005 levels for now but with At worse, return to 2005 levels for now but with
supervision and technicians gainssupervision and technicians gains Solutions are evident, just a matter of monthsSolutions are evident, just a matter of months APA PD, 40, NAN PAIC are working together for this APA PD, 40, NAN PAIC are working together for this
resolutionresolution
2006 nan advanced cpt2006 nan advanced cpt 7777
AMA Contact InformationAMA Contact Information
WebsiteWebsite www.amabookstore.com Link to; Link to;
American Psychological AssociationAmerican Psychological Association Russ Newman, J.D., Ph.D.Russ Newman, J.D., Ph.D. Practice DirectoratePractice Directorate American Psychological AssociationAmerican Psychological Association 750 First Street, N.W.750 First Street, N.W. Washington, D.C. 2002Washington, D.C. 2002
Association for the Advancement of PsychologyAssociation for the Advancement of Psychology www.aapnet.orgwww.aapnet.org P.O.Box 38129P.O.Box 38129 Colorado Springs, Colorado 38129Colorado Springs, Colorado 38129
2006 nan advanced cpt2006 nan advanced cpt 7979
Puente Contact InformationPuente Contact Information
WebsitesWebsites Univ = Univ = www.uncw.edu/people/puente Practice = Practice = www.clinicalneuropsychology.us NAN = www.nanonline.org/paioNAN = www.nanonline.org/paio
Can I Use 96118 for Interpretation and Report Can I Use 96118 for Interpretation and Report Writing When I Have Used 96119 for Testing?Writing When I Have Used 96119 for Testing?
Can I Do This on the Same Day or a Different Can I Do This on the Same Day or a Different Day of Service (e.g., under what Day of Service (e.g., under what circumstances are they similar or different circumstances are they similar or different services)?services)?
Should They be Billed on the Day That the Should They be Billed on the Day That the Service Occurred or on the Last Day of Service Occurred or on the Last Day of Service?Service?
2006 nan advanced cpt2006 nan advanced cpt 8282
Typical QuestionsTypical Questions
How and When Can I Use a “Student” How and When Can I Use a “Student” as a Technician?as a Technician?
What Codes Have a Professional and What Codes Have a Professional and Which Ones Have a Technical Which Ones Have a Technical Component?Component?
