Question Interactive Complexity- When it is okay to bill clarification


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I have an MHP who is certified in Play Therapy, which would normally be considered a component of interactive complexity, and uses this as a standard means of communication with their clients. Since they are certified in this practice and use this often with clients, would we still be able to bill 90785 in addition to the psychotherapy session? Or since this is part of their typical approach, would it be considered a normal, non-complex session?


Grantsville, UT
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I found this under the lay terms for 90785. Hopefully this is helpful.
Lay Terms
This add–on code represents increased work intensity of psychotherapy services that adds difficulty to delivery of service.

Clinical Responsibility
This add–on code represents communication factors that add to the difficulty of service delivery and increase the intensity of effort required of the provider in a particular treatment session. There are various factors that make the psychotherapy session more intensive in effort like high reactivity or disagreement among family members, emotions or behavior of the caregiver that hinder execution of the treatment plan, situations involving abuse or neglect that the provider must legally report, use of play equipment or other objects to assist communication, or the need for an interpreter or translator because of the patient’s lack of fluency or undeveloped verbal skills.

Because +90785 is an add–on code, payers will not reimburse you if you report it without an appropriate primary psychotherapy or evaluation and management services code: 90791, 90792, 9083290834, 9083690838, 90853, 9920199205, 9921199215, 9921799226, 9923199236, 99238, 99239, 9924199245, 9925199255, 9930499310, 99315, 99316, 99318, 9932499328, 9933499337, 9934199345, 9934799350.

Range specific guidelines:
Interactive complexity refers to specific communication factors that complicate the delivery of a psychiatric procedure. Common factors include more difficult communication with discordant or emotional family members and engagement of young and verbally undeveloped or impaired patients. Typical patients are those who have third parties, such as parents, guardians, other family members, interpreters, language translators, agencies, court officers, or schools involved in their psychiatric care.

These factors are typically present with patients who:

Have other individuals legally responsible for their care, such as minors or adults with guardians, or

Request others to be involved in their care during the visit, such as adults accompanied by one or more participating family members or interpreter or language translator, or

Require the involvement of other third parties, such as child welfare agencies, parole or probation officers, or schools.

Psychiatric procedures may be reported "with interactive complexity" when at least one of the following is present:

1. The need to manage maladaptive communication (related to, eg, high anxiety, high reactivity, repeated questions, or disagreement) among participants that complicates delivery of care.

2. Caregiver emotions or behavior that interferes with the caregiver's understanding and ability to assist in the implementation of the treatment plan.

3. Evidence or disclosure of a sentinel event and mandated report to third party (eg, abuse or neglect with report to state agency) 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 to overcome barriers to therapeutic or diagnostic interaction between the physician or other qualified health care professional and a patient who:

Is not fluent in the same language as the physician or other qualified health care professional, 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 physician or other qualified health care professional if he/she were to use typical language for communication.

When provided in conjunction with the psychotherapy services (90832-90838), the amount of time spent by a physician or other qualified health care professional providing interactive complexity services should be reflected in the timed service code for psychotherapy (90832, 90834, 90837) or the psychotherapy add-on code performed with an evaluation and management service (90833, 90836, 90838) and must relate to the psychotherapy service only. Interactive complexity is not a factor for evaluation and management services selection (99201-99255, 99281-99285, 99304-99337, 99341-99350), except as it directly affects key components as defined in the Evaluation and Management Services Guidelines (ie, history, examination, and medical decision making).
Pendleton, OR
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I have the same question and a similar situation... Play therapy is documented in there psychotherapy notes, I view this as a modality used during the session.... Therefore, I am struggling with additional supporting information to give to the clinician whom is asking this question.