Now that 2024 has arrived, several notable changes in the Current Procedural Terminology (CPT) codes may affect psychiatrists and mental health professionals.

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These changes have implications for billing, telehealth services, and Medicare covered services. Understanding and implementing these changes is crucial for maintaining best practices and ensuring optimal patient care.

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Here's what we'll cover in this guide:

• Good News for Psychotherapy and HBAI Services

• Telehealth Services Continue to be Supported

• New Category III Codes for TMS and Psychedelics

• Medicare Beneficiary Access: More Therapists Can Bill Medicare!

• Caregivers and Social Determinants and Health Get New Codes

• Minor Change to Evaluation and Management (E/M) Services Time-Based Billing

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Professional Societies such as the American Psychiatric Association and the American Psychological Association are instrumental in advocating for many of the changes described below. The new year is also the time to renew your memberships in these organizations for all the work they do beyond the scenes for our field.

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Good News for Psychotherapy and HBAI Services

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The Center for Medicare and Medicaid Services (CMS) has announced a plan to increase the RVU work values for standalone and add-on psychotherapy and Health Behavior Assessment/Intervention services by 19.1% over four years. For 2024, this will result in an increase in payment for psychotherapy visits of between $3 and $6. This increase will apply to codes:

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• Psychotherapy: 90832, 90833, 90834, 90836, 90837,  90838, 90839, 90840, 90845, 90846, 90847, 90849, and 90853

• HBAI: 96156, 96158, 96159, 96164, 96165, 96167, and 96168

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Actionable Steps:

• Mental health professionals who take Medicare and Medicaid should review their fee schedules and adjust these codes to reflect the 2024 increase. Keep in mind other changes to the Medicare Fee schedules to keep the overall budget neutral could mean that the overall change to a code combination could mean it is reimbursed less than a prior year.

• Each year, make a habit of checking the codes frequently used in your practice for changes to the medicare rates.

• If patients do not have supplemental/secondary medical coverage it is advisable to inform these patients about potential changes in billing for these services although the amounts are relatively small.

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Telehealth Services Continue to be Supported

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CMS will continue reimbursing telehealth services at the in-person rate. It is important to accurately note the place of service where the telehealth took place as the rate differs based on whether it is in a patient’s home or outside their home:

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• Claims for telehealth services provided at the patient’s home (POS 10) will be paid at the non-facility rate.

• Services at locations other than the patient’s home (POS 02) will be reimbursed at the facility rate. Use modifier 95 in addition to POS 02 as the location.

• Virtual supervision of residents delivering telehealth has been a high priority for the APA, and CMS extended reimbursement for virtual supervision through 2024.

• CMS payment for audio-only periodic assessments in opioid treatment programs is extended through 2024.

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Actionable Steps:

• Ensure your billing department uses the correct place of service (POS) codes and modifiers for telehealth services.

• Note that commercial payers may not follow the same standards as CMS so check with your commercial payers for any changes to their telehealth policies for 2024.

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New Category III Codes for TMS and Psychedelics

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The introduction by the American Medical Association of new Category III codes starting in 2024, including those for psychedelic therapy and Neuro-navigated accelerated Transcranial Magnetic Stimulation (TMS), marks a pivotal moment in psychiatry. These codes reflect the evolving landscape of psychiatric treatments and the inclusion of innovative therapeutic modalities. Keep in mind that Category III codes are considered provisional and experimental and are unlikely to automatically be covered by most payers.

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Actionable Steps:

• If you practice psychedelic-assisted therapy with FDA approved substances like Ketamine or medical cannabis, you may be able to start using the new psychedelic-assisted therapy CPT codes. Contact the insurance companies you work with to initiate a discussion of what coverage could look like for these. These codes were primarily designed to be used when medications such a MDMA gain FDA approval but are not specific to certain medications so other forms of psychedelic-assisted therapy may be eligible now.

• If you practice any form of neuro-navigated (e.g uses an fMRI to guide treatment planning) accelerated TMS consisting of 10 sessions per day, starting July 1, 2024, the new CPT codes for this form of TMS will be available. We recommend initiating discussions with the insurance plans you work with now to see if they would be willing to cover this form of TMS. SAINT TMS is one example of this type of TMS. Accelerated TMS without fMRI-guided neuronavigation unfortunately does not fall within the scope of these new codes.

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Read more about what at Category III code is and about the new Psychedelic Therapy codes here.

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Medicare Beneficiary Access: More Therapists Can Bill Medicare!

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Significant strides have been made to increase Medicare beneficiary access to behavioral health services:

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• Therapists such as MFTs and MHCs who were previously unable to directly contract with CMS will now be able to directly bill Medicare.

• New HCPCS codes G0017 and G0018 for psychotherapy for crisis services which may be useful for therapists who are unable to use the regular CPT codes for psychotherapy for crisis.

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Actionable Steps:

• Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) should enroll for Medicare billing as soon as possible if interested in servicing the Medicare population.

• MFTs and MHCs should use the tools Medicare has created to look up the fee schedules for codes they commonly below for their geographic region to determine if they would like to begin accepting Medicare.

• If you are a therapist or employee therapists, incorporate the new HCPCS codes into your billing system for appropriate reimbursement for crisis services.

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Caregivers and Social Determinants and Health Get New Codes

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New codes have been introduced, and changes have been made to existing ones to better serve patients with complex systems needs who have caregivers involved:

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• Adoption of active payment status for CPT codes for Group Caregiver Behavior Management services without the patient present:  96202 (first 60 minutes) and 96203 (each additional 15 minutes).

• Introduction of new codes for community health integration services and principal illness navigation when a clinician has identified that there are Social Determinants of Health (SDOH) impacting care or if there are significant care navigation needs. Note that these codes can reflect services provided by trained auxillary personnel rather than clinicians directly: G0019, G0022, G0023, and G0024.

• CMS finalized coding and payment for a new stand-alone G code, now assigned as HCPCS code G0136, Administration of a standardized, evidence-based SDOH risk assessment, 5–15 minutes, not more often than every 6 months.

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Actionable Steps:

• Check with the payers you work with to see if your contracts cover these codes and if not, request to have them added to your contracts if they could be useful to your practice.

• If the payers you work with cover these codes and your practice offers these type of services, update your practice management software to reflect these new codes.

• Train your staff on these updates to ensure they are applied correctly.

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Minor Change to Evaluation and Management (E/M) Services Time-Based Billing

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While the spirit of E/M billing based on time remains the same, the time ranges we are familiar with have been discarded in favor of a single time that must be met or exceeded.

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2023 Guidelines vs. 2024 Guidelines:

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• Code 99202: Previously 15-29 minutes, now at least 15 minutes

• Code 99203: Previously 30-44 minutes, now  at least 30 minutes

• Code 99204: Previously 44-59 minutes, now at least 45 minutes

• Code 99205: Previously 60-74 minutes, now at least 60 minutes

• Code 99212: Previously 10-19 minutes, now at least 10 minutes

• Code 99213: Previously 20-29 minutes, now at least 20 minutes

• Code 99214: Previously 30-39 minutes, now at least 30 minutes

• Code 99215: Previously 40-54 minutes, now at least 40 minutes

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Actionable Step:

• Psychiatrists should update any note templates and billing code descriptions that reference these time ranges for the E/M codes.

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Conclusion

The CPT code changes for 2024 provide opportunities for improved billing of services previously not covered or covered inadequately and can improve patient access to care. Psychiatrists and mental health professionals should take proactive steps to integrate these changes into their practice to maintain compliance and optimize patient services. Keeping abreast of these updates is key to a successful transition into the new year.