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Reporting of psychotherapy with interactive complexity clarified

The 2013 overhaul of the psychiatry section of the American Medical Association’s Current Procedural Terminology (CPT) changes the way psychotherapy with interactive complexity is reported. A new add-on code, 90785 for Interactive Complexity, represents the difference in intensity of the work and is used in reporting communication factors that complicate the delivery of psychiatric services.

Add-on code 90785 is listed separately in addition to the applicable psychiatry service. However, the Centers for Medicare & Medicaid Services (CMS) states in the Federal Register that interactive complexity generally should not be reported solely for the purpose of translation or interpretation services. Billing for interactive complexity simply to identify the use of a translator or interpretation may be in violation of several federal laws (Rehabilitation Act of 1973, Americans with Disabilities Act or Title VI of the Civil Rights Act of 1964).

There are several reasons for reporting interactive complexity in addition to psychiatry services that appropriately represent the additional work performed by the behavioral health professional. In order to bill for interactive complexity at least one of the following must be present:

  • Maladaptive communication
  • Caregiver emotions/behavior that interfere with implementation of the treatment plan
  • Evidence/disclosure of a sentinel event and mandated report to a third party with initiation of discussion of the sentinel event and/or report with patient and other visit participants
  • Use of play equipment, other physical devices, interpreter or translator to communicate with the patient

These factors are used to communicate with the patient to overcome the barriers to therapeutic or diagnostic interaction between the behavioral health professional and patient who is not fluent in the same language as the professional, or has not developed, or has lost, either the expressive language communication skills to explain his/her symptoms and response to treatment, or the receptive communication skills to understand the professional if he/she were to use typical language for communication.

All behavioral health professionals including psychologists, psychiatrists, nurses and social workers delivering psychotherapy services will use this new code to report interactive complexity, when performed. In addition to interactive complexity, there are significant changes to how psychiatrists bill for other psychiatric services and medical services.

To ensure accurate reporting, maintain compliance and receive appropriate reimbursement, join Jen Cohrs, CPC, CPMA, CGIC, for the webinar E/M for Psychiatrists on April 3. Discussion will include using time as a factor for E/M code selection, psychotherapy and other psychiatry services. This specialty webinar also will focus on choosing the correct levels of service based on history, exam and medical decision making, using real-world examples to demonstrate proper documentation. For more information and to register, click here.

Back to March 28, 2013 Medigram