CMS has delivered its usual voluminous description and explanation of benefit and coding changes for the coming year. CPT codes for neurocognitive testing and cognitive care planning have not been affected. Significantly however, the changes CMS made in 2021 regarding neurocognitive testing provided via telemedicine remain in effect for 2022.
Changes to Telemedicine CPT Codes for Neurocognitive Testing
CPT 96132, CPT 96136, CPT 96138 – Psychological and Neuropsychological Testing Services
Psychological testing services (96130-96133) and neuropsychological testing services (96136-96139) have been added as permanent telehealth codes as Category 3 codes that had been temporarily included during the PHE.
CPT 99483 – Cognitive Care Planning
Two significant changes have occurred regarding Cognitive Care Planning, CPT 99483. This code has been permanently included as a covered telehealth code. In addition, payment for Cognitive Care Planning has been increased to keep payments on par with a new patient level 5 E/M visit. CMS has increased the 2021 RVU to 3.50 from its 2020 value of 3.17. No other aspects of Cognitive Care Plan requirements have changed.
– Neurobehavioral Status Exams
For practitioners providing Neurobehavioral Status Exams (CPT 96116) via telehealth, the add-on code 96121 for each additional exam hour has been established as a covered telehealth code.
Impact of PHE Expiration on Telemedicine CPT Codes
The Public Health Emergency related to Covid-19 has added considerably to the complexity of the year’s policies. The time frame of the PHE has been extended through at least April 21, 2021. This is the fourth extension granted to date. And with the slow vaccine roll-out along with high rates of infection, hospitalizations, and deaths, we may see further extensions.
One significant impact of the expiration of the PHE will be on telehealth policy.
The inclusion of urban areas and home-based care was a significant and important expansion of Medicare telehealth policy. Currently, this expansion is limited to the duration of the PHE. At expiration of the PHE, Medicare will no longer cover telehealth where the home is the site of service or for urban areas, since both are excluded by statute.
With changes in administration and Congress, we will have to wait to see if these Medicare telehealth limitations will be addressed via new laws, since CMS is bound by existing law. Presumably, Congress will be weighing the benefits and costs of telehealth expansion.
Unprecedented adoption by both practitioners and individuals will likely play an important role and there will likely be considerable pressure to broaden Medicare’s current restrictions.