Update on CMS Proposal for Telemental Health CPT Codes

CMS ProposalAs we reported last week, Telehealth Reimbursement Leaps Forward Again in CMS is proposing to add mental health procedure codes to Medicare’s list of telehealth services.

Psychotherapy Codes

Proposed codes include 90845 (psychoanalysis), 90846 (family psychotherapy without the patient), and 90847 (family psychotherapy with the patient). The agency stated in the proposed rule that these three services are similar to other psychiatric services that already qualify as telehealth.

Psychological Testing and Neuropsychological Testing

CMS rejected the idea of adding psychological testing (96101 and 96102) and neuropsychological testing (96118 and 96119) to telehealth because these services require close observation of how a patient responds while undergoing testing.

Telephone Communication by telephone does not qualify as telehealth according to CMS. (State statutes defining telehealth may define telehealth differently for regulatory issues, however.)

Other Requirements

Medicare’s specific telehealth requirements must be met in order to be reimbursed for telehealth services.For instance, sites of service delivery much be “designated” (approved) and practitioners in the mental health area include psychiatrists, psychologists and social workers. Senator mike Thompson from California has proposed a Bill to have LPC and MFT’s approved as designated providers as well. Medicare provider status legislation in the U.S. House of Representatives and on December 5, 2013, HR.3662 was introduced by our new sponsors Rep. Chris Gibson (R–NY) and Rep. Mike Thompson (D–CA). The House bill contains language identical to that used in the Senate version, S.562 (Wyden/Barrasso), which amends Medicare to add the outpatient services of licensed mental health counselors (“LMHCs”) and licensed marriage and family therapists (“LMFTs”) under part B of the Medicare program.

For more information about reimbursement for telehealth, see our 100% online Reimbursement Course.

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5 comments on “Update on CMS Proposal for Telemental Health CPT Codes

  1. what is the modifier that is needed for tele mental health. BCBS or medicare. I believe I use the usual CPT code of 90845 and then a modifier. I cannot find on line what the modifier is.

    • The telehealth modifier is “95” and the place of service code is “02”. Best of luck to you.

  2. Does CMS still require the first session to be in person (and not telemedicine) since the CMS rules have been relaxed by the Trump Administration?
    Jan Hembree
    May 1 2020

    • Jan, Since before COVID-19, CME does not typically require in-person intakes for telehealth. They had many other requirements, though. The list is actually extensive.
      For details, see our course listing: TBHI Course List if you need a 1- hour or a 3-hour course on telehealth billing basics for telebehavioral care.
      The 1-hour only mentions Medicare but the 3-hour has much more related to Medicare, including COVID updates.

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