CMS issues clarification on billing codes for testing services

Clarifications address issues of when more than one code can be billed and when psychologists can bill for professional time

By Communications and Government Relations staff

December 8, 2011—In response to advocacy efforts by government relations staff at the APA Practice Organization and the Epilepsy Foundation, The Centers for Medicare and Medicaid Services (CMS) issued clarification on Medicare billing and payment policy for the use of Current Procedural Terminology (CPT®) codes when billing for psychological or neuropsychological testing services. The testing codes were revised in 2006 to enable psychologists and physicians to bill for testing services administered by a technician or computer.

As explained further below, the clarification addressed issues of when more than one code can be billed and when psychologists can bill for professional time as well as for testing administered by a technician or computer, among other issues.  A complete list of the questions and answers addressed by CMS is available on the CMS website. 

Billing for more than one code

The responses provided by CMS clarified that when more than one test is administered on the same date to the same patient, the appropriate testing codes for psychological or neuropsychological testing by a physician/psychologist, technician or computer can be billed together. In addition, the agency explained that more than one code can also be billed when a psychologist needs to consolidate separate written reports and interpretations from distinct tests administered by technician or computer to the same patient on the same date into a comprehensive report.

Previously, some Medicare Administrative Contractors allowed psychologists to bill for testing by a physician/psychologist and testing by a technician or computer during the same encounter, while others did not. This information from CMS will resolve inconsistencies among the various Medicare Administrative Contractors on how to bill for testing services.

Billing for time spent interpreting tests

When additional time is needed for the psychologist or physician to integrate separate interpretations or reports into a comprehensive report, that time can be billed under CPT® code 96101 or 96118. The time spent interpreting tests administered by the technician may not be billed under these codes, as the interpretation of these reports/results should have already been completed and is included in the technician-administered code.

Codes 96101 and 96118 allow for circumstances where additional time is needed by the physician or psychologist to integrate other sources of clinical data, such as previously reported technician- or computer-administered tests, into the comprehensive report.

Prior to this clarification, it was unclear whether a physician/psychologist was required to administer at least some of the testing in order to use the professional code for billing purposes. This response from CMS clarifies that the professional code can be used when integrating separate test reports and writing a comprehensive report, even if the psychologist did not conduct the testing.

Further guidance on code descriptors and billing CPTs® can be found on the American Medical Association website or on the Centers for Medicare & Medicaid Services website.


Current Procedural Terminology (CPT®) copyright 2011 American Medical Association. All rights reserved.