If you’re billing for neurocognitive testing in your practice, here’s what you need to know before January 1, 2019

This is the second of a two-part series on the 2019 CPT coding changes for psychological and neuropsychological testing services. In part one, we went over the new, deleted and revised CPT codes as they pertain to neurocognitive testing. In this post, we’ll provide recommendations on how to use the new codes, the reason for the changes, as well as help to prepare you for the transition.

Assessment visit prior to BrainCheck testing

If the decision to provide BrainCheck neurocognitive screening (in a subsequent visit) is made during an exam focused on a chief complaint of cognitive symptoms, the practitioner can code this visit as a Neurobehavioral Status Exam (CPT 96116), which is described as follows:

“Neurobehavioral status examination (clinical assessment of thinking, reasoning, and judgment, (e.g. acquired knowledge, attention, language, memory, planning and problem solving, and visual spatial abilities), by physician or other QHP, both face-to-face time with the patient and time interpreting test results and preparing report, first hour”

CPT code 96116 for neurobehavioral status examination has not changed for 2019. However, time spent beyond the initial hour should be reported using CPT code 96121, the add-on code associated with 96116. If the exam prior to BrainCheck is more widely focused on medical as well as cognitive complaints, this visit would be more accurately coded as an evaluation and management (E/M) visit, new or established patient.

BrainCheck in a clinical practice

Beginning January 1, clinicians using BrainCheck should report the administration of BrainCheck as a single unit of CPT code 96138, with the expected administration time under 30 minutes (minimum of 16 minutes). Integration of the test results with other clinical data, clinical decision making, and reporting results to the patient should be coded as a separate visit using CPT 96132. This is designated as one hour of activity, which does not necessarily have to be provided in a single day.

Professional time includes non-face-to-face activity such as review of other medical records, review of test results, and modification of treatment plan. CMS defines thirty minutes of activity as 16-30 minutes and an hour activity is defined as 31-60 minutes. Medical record documentation should reflect cognitive plus face-to-face time spent with the patient.

In the event that review, clinical decision making, and interactive feedback exceed one hour, each additional hour should be reported using add-on CPT code 96133. One likely scenario for billing 96133 is the provision of a follow up interactive feedback session with the patient/family/caregiver. This meeting must be face-to-face to qualify for additional billing.

The behavioral assessments provided on the BrainCheck platform (i.e., Generalized Anxiety Disorder 7, Patient Health Questionnaire 9, and Geriatric Depression Scale) may continue to be reported using CPT code 96127 (brief emotional/behavioral assessment), with a separate charge for each instrument.

Why did CMS make these changes?

In reviewing the historic codes for cognitive testing, CMS noted significant ambiguity about the coding of psychological and neuropsychological tests potentially leading to over-billing.

The new structure makes a clear distinction between the administration of the tests (96138) and the professional review and interpretation of results (96132 or 96116). The new coding structure provides separate billing events for each activity.

Prepare for the transition

We highly encourage you to do the following before December 31:

    • Advise and educate practice billing staff about the new billing codes that will become effective January 1.
    • Communicate with your EHR vendor and billing software vendor to confirm that the new codes will be in place on January 1.
    • Review and revise existing forms with the new CPT codes.
    • Discard existing forms that use the codes that will be obsolete January 1.
    • Carefully review test administrations beginning January 1 to confirm that new billing codes are active.
    • Review the coding summary below.

2019 CPT codes for neuropsychological tests and test interpretation

2019 CPT Definition Payment RVU
x Conversion
Factor @ $36.04
Comment Change from 2018
Assessment visit prior to formal testing
96116 Neurobehavioral status examination: Clinical assessment of thinking, reasoning, and judgment, (e.g. acquired knowledge, attention, language, memory, planning and problem solving, and visual spatial abilities), by physician or other QHP, both face-to-face time w/ the patient and time interpreting test results and preparing report, first hour RVU 2.70 x $36.04 = $97.31 Initial visit, focused specifically on cognitive status. Physician activity includes interview, reviewing medical history/tests & decision to administer BrainCheck on subsequent visit. No Change
96121 Add-on code to 96116, each additional hour RVU 2.32 x $36.04 = $83.61 ‘Add-on’ code for practitioner time that exceeds initial hour. Add on code for 96116
OR
99201-99205
OR 99211-99215
E & M: New patient office or other outpatient visits
OR
Established patient office or other outpatient visits
Use instead of 96116 if focus of visit includes management & assessment of medical conditions in addition to cognitive complaints/ status.
Test Administration
96138 Psychological or neuropsychological test administration & scoring by technician, two or more tests, any method, first 30 min RVU 1.08 x $36.04 = $38.92 BrainCheck is a composite screening battery consisting of 5 component tests. Administration & scoring aided by office technician. ‘Any method’ includes computerized testing. Replaces 96119, 96120
96139 Add-on code to 96138, each additional 30 min RVU 1.08 x $36.04 = $38.92 ‘Add-on’ code for additional testing that exceeds 30 min.
96127 Brief emotional /behavioral assessment w/scoring and interpretation, per standardized instrument $5.75 per test Examples: PHQ-9, GAD-7, Geriatric Depression Scale, available on BrainCheck platform No Change
OR
96146 Psychological or Neuropsychological testing administered by computer, single instrument, automated result only RVU 0.06 x $36.04 = $2.16 per test Replaces 96103 and 96120
Test Interpretation
96132 Neuropsychological testing evaluation services by physician or other qualified health professional, including integration of patient data, interpretation of standardized test results and clinical data, clinical decision-making, treatment planning and report and interactive feedback to the patient, family, or caregivers, when performed; first hour RVU 3.71 x $36.04 = $133.70 This code provides payment for the cognitive activity of the practitioner, including review of relevant medical history, interpretation of test results, and feedback to patient/family. Includes face-to-face as well as case review time spent by practitioner. Replaces 96118
96133 Add-on code to 96132, each additional hour RVU 2.83 x $36.04 = $101.99 ‘Add-on’ code for practitioner time that exceeds initial hour.
Likely Deployment of BrainCheck in Clinical Practice
Bill 1 unit of 96116 of Neurobehavioral Status Exam that results in decision to administer BrainCheck (If separate visit from routine E&M visit).
Bill 1 unit of 96138, BrainCheck Composite Battery, 30 min.
Bill 1 unit of 96132, Review & interpretation of BrainCheck results, review of history of other clinical data, integration of results, recommended additional tests/procedures, modification of treatment plan, and communication of results to patient/family.
Bill 1 unit of 96133, If activity associated with 96132 > one hour.
Note: May be billed if follow up visit to explain results to patient/family
Estimated Medicare Reimbursement without NBSE 96116: $38.92 + $133.70 = $172.62 Estimated Medicare Reimbursement with NBSE 96116: $97.31 + $38.92 + $133.70 = $269.93
Note: Adjust conversion factor as per your Medicare location to obtain expected rates for your practice

The information provided in this document was obtained from third-party sources and is subject to change without notice as a result of changes in reimbursement laws, regulations, rules, and policies. All content on this document is informational only, general in nature, and does not cover all situations or all payers’ rules and policies. This content is not intended to instruct medical providers on how to use or bill for healthcare procedures, including new technologies outside of Medicare national guidelines. A determination of medical necessity is a prerequisite that BrainCheck, Inc. assumes will have been made prior to assigning codes or requesting payments. Medical providers should consult with appropriate payers, including Medicare fiscal intermediaries and carriers, for specific information on proper coding, billing, and payment levels for healthcare procedures. This information represents no promise or guarantee by BrainCheck, Inc. concerning coverage, coding, billing, and payment levels. BrainCheck, Inc. specifically disclaims liability or responsibility for the results or consequences of any actions taken in reliance on this information.