December 29, 2022
Dr. Carlene MacMillan, MD
The new year can be a chaotic time for psychiatrists running busy outpatient practices.
Many patients change insurance plans or reset deductibles, impacting how much each visit costs. Also, the American Medical Association rolls out changes to CPT® codes, and Medicare changes some rules around how to use certain codes.
These—like death and taxes—are unavoidable. The good news for 2023 is these changes are relatively minor for most outpatient psychiatrists.
In 2021, the rules for using medical decision making (MDM) to determine the appropriate E/M code for outpatient visits changed. You needed specific documentation to use MDM as the deciding factor. The days of counting up elements in the history, physical and review of systems ended. So documentation requirements became less burdensome.
In 2023, these rules around changes in documentation are being expanded to other settings including:
If you don’t work in any of those settings, keep on coding the way you have been for the past two years with the codes 99202-99215.
Time spent on a patient's case on the same day, except in an emergency room setting, counts towards total time for billing purposes. Remember that if you use add-on psychotherapy codes, you must choose your E/M code based on MDM and not time!
In 2023, 68 CPT® codes are being eliminated. But, only 6 of these are likely to be relevant to most outpatient psychiatrists, if that.
CPT® is deleting prolonged codes 99354, 99355, 99356, and 99357. These were face-to-face prolonged care codes that could be used with office/outpatient codes or inpatient, observation or nursing facility.
CPT® is keeping non-face-to-face prolonged care codes 99358 and 99359 for when the services are performed on a date other than a face-to-face visit but many commercial payers and Medicare do not pay for those codes.
The deleted prolonged service codes were used by therapists conducting sessions longer than an hour for specialized types of psychotherapy such as ketamine-assisted psychotherapy.
Unfortunately, therapists cannot use the codes that should be used instead of prolonged service codes, but psychiatrists and psychiatric nurse practitioners can. For Medicare, the prolonged service code that should be used instead in the outpatient setting in 15-minute intervals is G2212.
The equivalent code for commercial pay is 99417, introduced in 2021.
Some payers have a limit on how many units of 99417 can be used in one day for a patient. So, be sure to ask the payer's policy when negotiating with a payer around your fees. When using time-based codes, make sure to document the exact start and end times of any face-to-face contact, as well as the details of any non-face-to-face clinical tasks completed on the same day.
The other codes eliminated in 2023 may be occasionally used by outpatient psychiatrists. These are 99421 and 99251, two low-level consult codes that were rarely used throughout the medical field.
Remote physiological monitoring (RPM) codes were introduced in 2019, but they've been refined in recent years as the field of RPM and digital health has developed. In 2022, the AMA introduced a series of new codes that went beyond remote physiological measurements like vital signs. These new codes include things like encompassed remote treatment monitoring (RTM). For mental health clinicians, this could include things like medication adherence and response, and participation in digital therapy programs through approved apps. The existing RTM codes that would be most relevant for a psychiatrist are 98980 and 98981.
In 2023, the new RTM code 98978 launches. It's designed to report cognitive therapy monitoring for a range of physical and mental health disorders. Companies like Pear Therapeutics launched digital therapeutics for issues such as substance use and insomnia that could fall under these codes.
Since this is such a new area, definitely check with any commercial payers you're contracted with to see if they can include these codes in your contract if you plan on offering RTM services.
And finally, it wouldn’t be a post on healthcare in 2023 without mentioning AI. Even the AMA is starting to grapple with how artificial intelligence will impact medical billing.
Embracing a spirit of innovation, the 2023 CPT® code set has an Appendix S which introduces a taxonomy that provides guidance for classifying augmented intelligence or AI-powered medical service applications. In other words, this coding isn't ready for prime time but folks at the AMA are starting to think about how it will be in the future.
Overall, the American Medical Association aims to make physicians' lives easier with coding changes. The goal is to keep up with the ever-evolving “language of medicine.”
Getting into the weeds on coding changes can be a little intimidating. But, if you narrow your focus to only the codes relevant to your specialty, it gets a lot less scary.
Luckily for psychiatrists, CPT® coding is relatively straightforward. The changes for 2023 for our specialty are quite minor compared with the major changes introduced in 2021.
We hope this overview helps you and your patients document and bill accurately and efficiently! A purpose-built psychiatry EHR also helps set your practice up for success.
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