Interactive Complexity 90785 – Clarification

As most of us are still learning about the 2013 Psychiatry coding changes, we know that the Interactive Complexity 90785 is used in reporting communication factors that complicate the delivery of psychiatric services.  Interactive Complexity represents the difference in intensity of the work.  The time of this service is captured in the time of the primary procedure it is billed with.

Interactive complexity is an add-on code when performed with psychotherapy, and is listed separately in addition to the primary procedure of psychotherapy.

There are four factors of at least one must be present in order to bill for interactive complexity:

  1. Maladaptive communication
  2. Caregiver emotions/behavior that interfere with implementation of the treatment plan
  3. Evidence/disclosure of a sentinel event and mandated report to a third party with initiation of discussion of the sentinel event and/or report with patient and other visit participants
  4. Use of play equipment, other physical devices, interpreter or translator to communicate with the patient

These factors are used to communicate with the patient to overcome the barriers to therapeutic or diagnostic interaction between the prescriber/provider and patient who is not fluent in the same language as the provider, or has not developed, or has lost, either the expressive language communication skills to explain his/her symptoms and response to treatment, or the receptive communication skills to understand the prescriber/provider if he/she were to use typical language for communication

However, Centers for Medicare and Medicaid Services (CMS) states in the Federal Register that, interactive complexity (CPT Code 90785) generally should not be billed solely for the purpose of translation or interpretation services.  They see that billing for interactive complexity just for the use of a translator or interpretation due to a patient’s disability could be in violation of federal laws (Rehabilitation Act of 1973, Americans with Disabilities Act or Title VI of the Civil Rights Act of 1964).

This would also go for those carriers that follow Medicare rules and regulations, along with all federally funded programs.