Behavioral Health Billing Solutions, LLC
99354 and 99355 – Add Ons for Psychotherapy
There are two CPT code changes effective January 1, 2023 that will necessitate changes to your EHR billing structure. Both are the result of changes to the CPT code set announced by the AMA; the good news is that out of the many changes made to the code set, there are few that will impact behavioral health billing.
The bad news is that a major change will affect nearly all behavioral health agencies billing for Individual Psychotherapy and Assessments. The add-on codes 99354 and 99355 are being deleted entirely. These add-on codes represent prolonged psychotherapy time starting at 91 minutes and 135 minutes respectively. We have researched exhaustively on replacements and have added our voice to lobbying efforts directed to Ohio Medicaid to continue use of the codes or create new codes to fill this void. We understand the financial implications of eliminating this revenue and will continue to advocate on your behalf.
Without a replacement identified we are forced to end date billing of these add-ons as of December 31, 2022. This means Individual Psychotherapy will be limited to billing 90837 at 53 minutes regardless of the length of the session with your client. 90785 will still be available for billing Interactive Complexity. For our clients that currently bill 90837 for MH or SUD Assessments at 91 minutes, we will revise mapping for those activities to bill only the assessment code 90791 since there will be no additional revenue for the longer services.
Home E & M Visits – 99341-99350
The changes announced for Home E&M services build on the changes to office and outpatient E&M in 2021. Currently, there are separate codes for Home Visits versus Rest Homes and Domiciliary. In 2023 the Home Visit codes will cover all locations where clients reside: permanent and temporary. Code 99343 will be deleted.
Additionally, the choice of billing based on Medical Decision Making (MDM) or Time is applied to Home Visits, as is the elimination of history and exam to determine the code level (same as for office visits currently). The prolonged time code of 99417 will also apply to Home Visits if Time is selected for determining the code level.
Medicare Incident To Exception to Direct Supervision
The Medicare Physician Fee Schedule Proposed Final Rule includes an exception to the ‘incident to’ regulation to allow behavioral health services to be provided under the general supervision of a physician or non-physician practitioner rather than direct supervision. This would make greater use of the services of dependently licensed behavioral health professionals with LPC, LCDC, LSW and LMFT credentials. “General supervision” means the definition specified at 42 CFR 410.32(b)(3)(i), that is, the procedure or service is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. Services may be billed incident to a medical professional (MD/DO, CNP, PA, PSY) but not to an LISW.
Our updated Usual and Customary Rates (UCR) Recommendation for 2023 can be found here: 2023 Medicare Medicaid & UCR Recommendations
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