CMS provides questions and answers on the testing codes

Online Q&As address lingering concerns about CPT coding for services administered by a technician or computer

by Government Relations Staff

July 17, 2008 — The Centers for Medicare and Medicaid Services (CMS) recently posted on its website questions and answers (Q&As) that clarify how the Current Procedural Terminology (CPT)® codes for psychological and neuropsychological testing should be used. The Q&As address when the 96101 and 96118 codes can be used to account for integrative interpretation and comprehensive report writing for services administered by a technician or computer.

The Practice Directorate asked for this information after a 2006 CMS transmittal resulted in confusion about Medicare's rules for billing multiple codes when testing is administered by a technician or computer. Assisted by APA Div. 40 (Clinical Neuropsychology), the National Academy of Neuropsychology and the Society of Personality Assessment, the APA Practice Directorate has been working for almost two years to address the uncertainty created by the CMS transmittal.

After months of work by the Practice Directorate and CMS, the CPT Editorial Panel agreed in February 2007 to add language to the CPT 2008 manual stating that codes 96101 and 96118 can be used for time spent integrating other sources of clinical data, including previously completed and reported technician and computer-administered tests.

Despite the new CPT language, psychologists and facility compliance officers still had reservations about the proper use of the codes based on the CMS transmittal. Knowing that only a statement from the federal agency would address those concerns, the Practice Directorate sought further action by CMS.

In an unusual step taken last summer, CMS agreed to consider publishing a series of Q&As that APA drafted about use of the codes. Having made some slight revisions, the agency posted the Q & As after completing a long clearance process. Psychologists should disregard Question 9178, which addresses testing by physical therapists, occupational therapists and speech language pathologists.

For additional assistance regarding the testing code Q&As, please contact the Practice Directorate's Government Relations Department at 202-336-5889.

Current Procedural Terminology (CPT®) copyright 2008 American Medical Association. All Rights Reserved.