90785: Gain Clarity Regarding the Interactive Complexity CPT Code

Kym Tolson, LCSW, Boss Biller, Traveling Therapist

Uses For Interactive Complexity in Private Practice

Your experience and success as a therapist rests on your ability to communicate with your clients. Yet, sometimes the connection you want to make with a hurting or troubled person is hindered or difficult for any number of reasons. It often takes time to parse out what to do and how to do it. Helping them is built on the cornerstone of communication.

Have you ever wondered how you would charge for such an interaction? As you work through situations like these, you don’t want to be worried or distracted. Thoughts about whether your income will be affected by clients with whom you are slow to connect aren’t helpful to your process or for the client.

Fortunately, there is a billing code that covers conversations that don’t happen easily. Nearly a decade ago, The American Medical Association (AMA) created the interactive complexity code (90785).

Exchanges that are tense or stilted, or interactions that require more people in the room for support, safety, and care, may benefit from this code. Therefore, let’s explore the ins and outs of using this code below:

So, What Exactly Defines Interactive Complexity for Insurance Companies

Good question! First, understand that the interactive complexity code is a code used in conjunction with primary service codes on the same date of the session. Thus, code 90785 cannot stand alone and is referred to as an “add-on” code. 

 Appropriate use of the interactive complexity code involves circumstances where your services are complicated by communication barriers with a client, during your session. Also, it’s important to note that billing code 90785 reflects the elevated intensity of the interaction, not how much time it takes you to interact with the client.

Interactive Complexity
90875 Interactive Complexity

To be clear, here are the billing code's do’s and dont's of the interactive complexity code:

 Do use code 90785 with these CPT codes:

  • Psychiatric diagnostic evaluation, 90791, 90792  
  • Psychotherapy, 90832, 90834, 90837  
  • Group psychotherapy, 90853

Do Not use code 90785 with these CPT codes:

  • Psychotherapy for crisis (90839, 90840)   
  • Family psychotherapy (90846, 90847, 90849)
  • E/M (evaluation and management) service where no psychotherapy service is reported
  • Only for translation or interpretation services. (This can be construed as discrimination based on the client’s disability or ethnicity.)

Okay…So What Does A Code 90785 Situation Look Like?

Another great question! To apply the code correctly, ask yourself several key questions:

  • Are other people (parents, guardians) legally responsible for my client’s care?
  • Does my client ask that others, such as an interpreter or a loved one, remain involved in their care during the session?
  • Is third-party involvement, such as a child welfare agency, school official, or a probation officer, required?
  • Is care complicated by the client’s maladaptive communication (extreme anxiety, reactivity, combative or disruptive language, etc)?
  • Are you unable to execute a treatment plan because a caregiver’s emotions or behaviors interfere with your service?
  • Do you need to discuss making reports to a third-party agency like Child Services/Elder Abuse Services?
  • Does your client need devices, interpreters, or translators to work overcome barriers to your ability to diagnose or provide therapeutic interaction?

“Yes” to one or more of these questions means the code applies. Your situation is compliant with the interactive complexity assessment as outlined in the Current Procedural Terminology manual.

*2022 UPDATE on Interactive Complexity Code* (source)

"According to CPT guidelines, psychologists can report interactive complexity in conjunction with diagnostic evaluation (CPT code 90791), individual psychotherapy (CPT codes 90832, 90834, 90837) or group psychotherapy (90853) services, if at least one of the following complicating factors are  present and documented in the patient record:

  1. The need to manage maladaptive communication (e.g., related to high anxiety, high reactivity, repeated questions, or disagreement) among participants that complicate delivery of care.
  1. Caregiver emotions or behaviors that interfere with the caregiver’s understanding and ability to assist in the implementation of the treatment plan.
  2. Evidence or disclosure of a sentinel event and mandated reporting to a third party (e.g., abuse or neglect with report to state agency) with the initiation of discussion of the sentinel event and/or report with a patient and other visit participants.
  3. Use of play equipment or other physical devices 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 has not developed, or has lost, either the expressive language communication skills to explain his or her symptoms and respond to treatment; or a patient who lacks the receptive communication skills to understand the physician or other qualified health care professional if he/she were to use typical language for communication."

Great! Now, How Do I Bill for Interactive Complexity When Necessary?

Now that you know the do’s and don’ts, how to bill likely won’t seem so hard. Here are a few pointers to keep in mind for your billing form:

  • Be sure to apply the same date to both codes and describe in detail the nature of the interactive complexity.
  • Again, remember that 90785 is an add-on code. On your billing form, the interactive complexity code will directly follow the primary service code. 
  • Also, add your usual provider information.

That’s all there is to it! Still if you feel unsure or need someone to walk you through the process before you go solo, there’s no shame in that.  Moreover, the point is to help you recognize interactive complexity when it happens. And feel that you can appropriately bill for it. 

Finally, please know we’re here to help! Don’t be afraid to reach out for support and guidance. We’ve got tools and resources to build your billing confidence in no time.

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