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Questions and Answers about the 2006 Revised CPT
Testing Codes
By: Federal Regulatory Affairs Staff
Source: www.apapractice.org
January 19, 2006 -- In our ongoing education campaign to help practitioners know about and
properly use the 2006 Current Procedural Terminology (CPT)® psychological and neuropsychological
testing codes, the APA Practice Directorate is offering this question-and-answer guide.
This guide is a compilation of information from articles posted on APApractice.org beginning in 2004,
when the American Medical Association’s (AMA) CPT Editorial Panel accepted the APA’s proposal to
develop an expanded set of testing codes to more accurately reflect psychological and
neuropsychological testing.
Note: At the end of this document, view Estimated Medicare Fee Increases for 2006 Testing
Services. A congressional legislative proposal pending as of late January would freeze Medicare
rates for 2006 at the 2005 level. See related article, 2006 Medicare Fee Schedule: Reversal of
4.4% Payment Reduction Expected Soon.
Q: What changes are there to the CPT psychological and neuropsychological
testing codes in 2006?
A: As of Jan. 1, 2006, the CPT codes for psychological and neuropsychological testing have been
revised. New code numbers have replaced the old CPT code numbers 96100, 96117 and 96115 for
psychological testing, neuropsychological testing and the neurobehavioral status exam.
The revised psychological and neuropsychological testing codes now reflect who does the testing: a
psychologist, a technician or a computer. The neurobehavioral status exam, which is typically not
conducted by a technician or a computer, has been replaced by a single new code.
The revised codes finally provide more appropriate reimbursement and recognition for psychologists
who administer psychological and neuropsychological tests. The Practice Directorate successfully
sought the revised codes as part of a persistent, multi-year effort to obtain a “professional work
value” for testing and assessment codes reflecting the time and effort expended by a psychologist in
providing these services. Previously, psychological testing codes had a work value of zero for the
psychologist’s effort.
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Q: Is there a grace period during which I may continue using the old codes?
A: No. Practitioners must use the revised codes as of Jan. 1, 2006. The CPT testing codes for 2005
are no longer being accepted.
Q: What are the new code numbers?
A: The code for psychological testing, interpretation and reporting, formerly known as 96100, is
now:
96101: for psychological testing, interpretation and reporting per hour by a psychologist
96102: for psychological testing per hour by a technician
96103: for psychological testing by a computer
The code for Neuropsychological testing, formerly known as 96117, is now:
96118: Neuropsychological Testing: per hour of psychologist's or physician's time, both face-toface time with the patient and time interpreting test results and preparing the report.
96119: Neuropsychological Testing: with qualified health care professional interpretation and
report, administered by a technician, per hour of technician time, face-to-face.
96120: Neuropsychological Testing: administered by computer, with qualified health care
professional interpretation and report.
The neurobehavioral status exam, formerly coded as 96115, is now coded as 96116.
96116: Neurobehavioral Status Exam: Clinical assessment of thinking, reasoning and judgment
(e.g., acquired knowledge, attention, language, memory, planning and problem solving, and visual
spatial abilities), per hour of qualified health care professionals time, both face-to-face time with the
patient and time interpreting test results and preparing the report. There is only a single code
reflecting the psychologist’s work in conducting the exam, which is typically not conducted by a
technician or a computer.
The new code numbers are published in CPT 2006©, which is available from the AMA at 1-800-6218335.
Q: How should I handle billing under the revised codes?
A: Billing under the revised codes is based on who administers a test and how long it takes. Testing
conducted by a psychologist is billed in hourly units, based on the number of hours the psychologist
spends administering a test and interpreting and reporting test results. Testing conducted by a
technician is based on the number of hours the technician spends administering a test. Testing
conducted by computer is billed at a flat rate using a single code. When billing the revised codes, it
is important to note in the client’s record who administered the test and for how long.
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The following scenarios offer examples for how to bill under the revised codes:
Billing example #1: If a psychologist conducts five hours of psychological or neuropsychological
testing and three hours of interpreting and reporting the test results, he or she would bill for eight
units of the psychologist-based code.
Billing example #2: If a technician conducts two hours of testing and a psychologist conducts 3.5
hours of testing and 2.5 hours of interpretation and reporting, he or she would bill for two units of
the technician-based code and six units of the psychologist-based code.
Billing example #3: If a patient completes two hours of computerized testing and a psychologist
conducts two hours of testing and one hour of interpretation and reporting, he or she would bill for
the computer-based code (which is a single, flat-payment rate that is not measured in units) and
three units of the psychologist-based code.
Q: What type of testing work by a technician is billable under the new technician-based
codes?
A: The time a technician is with the patient, administering tests, or supervising the patient as he or
she completes the tests, is considered billable under the technician-based code. The technician must
be with the patient, face-to-face, during the testing in order for the psychologist to be able to bill for
the time.
Q: Is the time that a technician spends scoring tests billable under the technician-based
codes?
A: Scoring is not a billable activity unless it is done while the technician is face-to-face with the
patient during the test administration.
Q: If a psychologist sits in an observation room and monitors a technician administering
a test, does the psychologist bill for this service under the psychologist code or the
technician code?
A: Since the technician is administering the test to the patient, the psychologist must bill using the
technician code. The code billed must reflect who is doing the test administration face-to-face with
the patient.
Q: If a patient takes a paper-and-pencil test, what code should be used?
A: It depends. If a psychologist is with the patient during the test, then that time is allocated to the
psychologist code. If a technician provides oversight during the test, then the technician-based code
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is used. If the patient is entirely on his or her own during
the test, that time is not billable.
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Q: When is the computer billing code used?
A: The computer code is only used when the patient is alone and taking a computer-based test.
Scoring by computer is not a billable activity.
Q: Can I bill the computer code if my patient takes a paper-and-pencil test, and I use a
computer to score it?
A: No. The codes are for identifying how test administration is done, not scoring. If the paper and
pencil test is self-administered (i.e., only the patient is involved in the testing) then the psychologist
may not bill for either the time the patient spends on the test or the computerized scoring of the
test. In this situation, the psychologist may only bill for the time spent on interpretation and
reporting.
Q: If a patient takes three computerized tests and no one is with him or her, does the
psychologist bill the computer code three times?
A: No. The computer code should be billed only once.
Q: Suppose a full battery of testing includes a single computer administered test like the
Continuous Performance Test, in addition to tests administered by either the
psychologist or a technician. Can the psychologist bill the computer code as well as the
psychologist or technician codes?
A: Yes. If a testing battery involves a computerized test, and the patient is completely alone during
that test, then the computer code (96103 or 96120) may be billed in addition to the technician and
psychologist codes.
Q. If I conduct an MMPI as part of neuropsychological testing, should I bill using the
psychological testing code during that portion of the battery?
A. No. Coding is not based on the tests that are conducted. It is based on the reason for testing. If
you are testing a patient for neuropsychological functions, then the neuropsychological testing codes
should be used no matter which tests are done.
Q. If I spend less than one hour on interpretation and reporting, after my technician has
conducted a test, can I bill for the full hour?
A. It depends on how much time you spend. If you spend 30 minutes or less, then you must bill the
code using the -52 modifier which indicates a reduced service. If you spend more than 30 minutes
then you may bill for the full hour. The same applies to billing the technician code if the technician
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spends less than one hour on testing.
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Q: What is the definition of “technician” under the revised codes?
A: The revised codes do not include a definition of a technician. The question of who can serve as a
technician for purposes of psychological or neuropsychological testing may be determined by state
law and/or coverage policies of third party payers. In addition, Division 40 of APA, the American
Academy of Clinical Neuropsychology, and the National Academy of Neuropsychology all have
policies on the use and training of technicians, and define administration and scoring as appropriate
roles for them. However, it should be noted that under the revised CPT codes, scoring is not a
billable activity, unless it is done while the technician is face-to-face with the patient during the test
administration.
Q: Do the revised codes allow for students or trainees to administer tests?
A: Yes. Because the codes do not contain a definition of the term “technician,” students’ and
trainees’ time spent conducting tests may be billed under the technician-based codes (96102 or
96119) so long as this does not conflict with any applicable laws or policies.
Q: Can students or other unlicensed individuals interpret and report test results?
A: No. Only a licensed psychologist or other licensed health care professional may bill for time spent
on interpretation and reporting psychological and neuropsychological tests.
Q: What should I do if a carrier tries to restrict my use of the psychologist-based code?
A: Some psychologists have expressed a concern that private insurance carriers could impose the
restriction that they will only pay for technicians to administer tests (thus only reimbursing
psychologists for interpreting tests and writing reports). If you become aware of such activity, please
alert the Practice Directorate’s Office of Legal & Regulatory Affairs at (202) 336-5886 or by email at
praclegal@apa.org. We will be ready to respond to such restrictions should there be any attempt
to impose them.
Q: Where can I get help with questions about or billing problems related to the revised
codes?
A: Anyone with questions or billing problems should call the Practice Directorate’s Government
Relations Department at (202) 336-5889 or email pracgovt@apa.org.
Current Procedural Terminology © 2006 American Medical Association. All Rights Reserved.
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Please note: All Sports Concussion Business Practice Tool forms are copyrighted and provided to you under license from ImPACT
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Practice Directorate Gains Increased Medicare Payments
for Testing Services in 2006
By: Federal Regulatory Affairs and Communications Staff
Source: www.apapractice.org
November 8, 2005 -- Medicare has just announced increased payments for psychological and
neuropsychological testing services, effective Jan. 1, 2006. The historic revision in the Medicare fee
schedule resulted from a decade of advocacy by the Practice Directorate.
Also, on Jan. 1, Medicare will require the use of an expanded set of testing service Current
Procedural Terminology (CPT)® codes that replace the existing codes in effect through Dec. 31,
2005. The revised psychological and neuropsychological testing codes will reflect whether a
psychologist, a technician or a computer does the testing.
The chart below reflects the estimated changes in payments as well as the revised code numbers
that apply to outpatient as well as hospital/facility settings. (See related article, "2006 Medicare
Fee Schedule: Reversal of 4.4% Payment Reduction Expected Soon.")
ESTIMATED MEDICARE FEE INCREASES AND CODE CHANGES FOR 2006
TESTING SERVICES
1. Outpatient Settings: 2006 Estimated Average Medicare Payments for Testing Services
PSYCHOLOGICAL ASSESSMENT:
New 2006 CPT Code Conducted by 2006 Code
Payment/Hr
96101
Psychologist
$92.61
96102
Technician
$42.33
$26.77 (flat
96103
Computer
fee)
2005
Code
96100
N/A
2005 Code
Payment/Hr
$73.52
N/A
N/A
N/A
2005
Code
2005 Code
Payment/Hr
96115
$73.52
96117
N/A
$73.52
N/A
N/A
N/A
NEUROPSYCHOLOGICAL ASSESSMENT:
New 2006 CPT Code Conducted by 2006 Code
Payment/Hr
Neurobehavioral
96116
$103.83
Status Exam
96118
Psychologist
$124.09
96119
Technician
$63.31
$45.94 (flat
96120
Computer
fee)
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2. Facility/Hospital Settings: 2006 Estimated Average Medicare Payments for Testing
Services
PSYCHOLOGICAL ASSESSMENT:
New 2006 CPT Code Conducted by 2006 Code
Payment/Hr
96101
Psychologist
$91.89
96102
Technician
$24.60
$23.52 (flat
96103
Computer
fee)
2005
Code
96100
N/A
2005 Code
Payment/Hr
$73.52
N/A
N/A
N/A
2005
Code
2005 Code
Payment/Hr
96115
$73.52
96117
N/A
$73.52
N/A
N/A
N/A
NEUROPSYCHOLOGICAL ASSESSMENT:
New 2006 CPT Code Conducted by 2006 Code
Payment/Hr
Neurobehavioral
96116
$96.95
Status Exam
96118
Psychologist
$96.59
96119
Technician
$33.28
$25.32 (flat
96120
Computer
fee)
(NOTE: All fees for 2006 reflect Medicare's scheduled payment reductions of 4.4 percent. See
related article, "2006 Medicare Fee Schedule: Reversal of 4.4% Payment Reduction
Expected Soon.")
The federal Centers for Medicare and Medicaid Services (CMS) sets the final fee schedule for all CPT
codes in Medicare. For the first time, CMS agreed with the Practice Directorate and the American
Medical Association (AMA)/Specialty Society Reimbursement Committee that psychologists’
reimbursement for testing services should include a “professional work value.” Until now, a
psychologist’s professional time and effort in providing testing services was not captured in the
Medicare fee schedule.
While the reimbursement committee also concurred with the Practice Directorate’s recommendation
that CMS assign higher work values for neuropsychological assessment services compared to
psychological assessment services, the federal agency did not accept the recommendation and
assigned the same work values for both psychological and neuropsychological assessment.
The revised code numbers and payment levels apply to Medicare effective Jan. 1. As they often do,
private insurance carriers may soon follow Medicare’s lead.
Practitioners must use the existing testing codes for Medicare through Dec. 31, 2005, and begin
using the revised codes starting Jan. 1, 2006. Psychologists, their office staffs and their billing
agents should be prepared in advance to make the switch to the revised codes on Jan. 1.
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Anyone with questions should call the Practice Directorate’s
government relations department at (202) 336-5889 or email pracgovt@apa.org. Additional
information about proper use of the testing codes is included in the article at APApractice.org,
“Questions and Answers About the 2006 Revised CPT Testing Codes.”
The new code numbers are published in CPT 2006©, which is now available from the AMA at 1-800621-8335.
Current Procedural Terminology ©2005 American Medical Association. All Rights Reserved.
2006 Medicare Fee Schedule: Reversal of 4.4% Payment
Reduction Expected Soon
by Federal Regulatory Affairs Staff
Source: www.apapractice.org
January 19, 2006 -- If you provide services to Medicare beneficiaries, you may already have received
lower reimbursement compared to 2005 for services that you delivered on or after January 1, 2006.
But those payments should increase soon if, as the APA Practice Organization expects, budget
reconciliation legislation now pending in Congress becomes law early this year.
With strong grassroots support from psychologists throughout the country, the APA Practice
Organization advocated throughout 2005 for Congress to adjust the Medicare fee schedule to avoid
a 4.4% payment reduction scheduled for January 1. Shortly before adjourning in December, both
the House of Representatives and the Senate voted in favor of budget reconciliation legislation that
would negate the 4.4% cutback and keep 2006 Medicare payment rates at 2005 levels.
But Senate amendments to the bill passed by the House necessitated another House vote that did
not happen by the end of the 2005 congressional session. Efforts by Congress to avert the cutback
were put on hold when the 2005 legislative year drew to a close.
Budget reconciliation is expected to resume shortly after Congress reconvenes late in January. Staff
for the APA Practice Organization anticipate a vote on the legislation in early to mid-February.
Congress could make any adjustment to the Medicare fee schedule retroactive to January 1, 2006.
In a January 6 letter to Rep. Bill Thomas, Chairman of the House Ways & Means Committee, the
Centers for Medicare and Medicaid Services (CMS) indicated that it is preparing to instruct local
carriers to implement any new update to the fee schedule in a manner that will be least disruptive to
providers and beneficiaries. CMS specified that it expects carriers to begin paying claims at the
adjusted rate within two days after the legislation is enacted.
The CMS letter also indicated that, if Congress makes payment adjustments retroactive to January 1,
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local Medicare carriers will be directed to automatically
reprocess any 2006 claims paid at the 4.4% lower rate. As a result, psychologists would not have to
resubmit any claims that were paid at the reduced rate.
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