How to report interprofessional telephone/internet/electronic health record consultations (2024)

Psychologists now have a mechanism to provide and report interprofessional telephone/internet/electronic health record consultations. In these consultations, psychologists and other providers may use phone, written, or internet communications to ask other health care professionals for advice in diagnosing and treating their patient’s condition. Face-to-face engagement with a patient is not required.

Effective in January 2023, CPT^® codes 99446–99449 and 99451 have been revised to include “other qualified health care professionals” in the code descriptors, guidelines, and instructional parenthetical language, where previously it had only specified “physician.” These revisions were made to provide clarity on the types of providers who are eligible to report these services.

There is an unprecedented growing mental health crisis among all ages across the country. One in five adults experience a diagnosable mental health disorder and two out of five report symptoms of anxiety and depression (NAMI, June 2022). It is critical that those who struggle with mental health problems receive medically necessary care; however, less than half of those who need care are receiving the help they need. Timely access to mental and behavioral health services is often limited by resources, especially in rural and underserved, uninsured, and ethnically diverse patient populations.

Interprofessional consultation services offer several key benefits, including timely access to mental and behavioral specialty care, decreased need for in-person referral or visit, shortened wait times, and an opportunity to support providers in a team-based approach to care. Non-face-to-face consultations are a way to get patients rapid access to specialty psychology expertise that benefits both the patient and the provider.

Interprofessional telephone/internet/electronic health record consultations are assessment and management services in which “a patient’s treating (e.g., attending or primary) physician or other qualified health care professional (QHP) requests the opinion and/or treatment advice of a physician or other QHP with specific specialty expertise (the consultant) to assist in the diagnosis and/or management of the patient’s problem without patient face-to-face contact with the consultant” (2023 CPT Manual, p. 59).

Codes (99446–99451) are reported by consulting providers who communicate with, and provide expert advice to, treating providers regarding a diagnosis or management of a patient’s problem. These services do not include face-to-face interaction with the patient. Consultation services can be provided to either a new patient, or an established patient with a new problem or an exacerbation of an existing condition. Because the type and/or severity of the problem is not specifically defined, any condition may qualify for consultative services; however, the codes are typically reported when a patient presents with a new problem or when an existing condition is exacerbated or not well managed.

There are two types of interprofessional consultation services via communications technology.

Consultation Services with Discussion, Verbal and Written Report Required (CPT codes 99446, 99447, 99448, 99449)

Psychologists can report CPT codes 99446–99449 if more than half of total/cumulative service time is devoted to the consultative verbal or internet discussion with the treating/requesting provider. If greater than 50% of the time for the service is devoted to data review and/or analysis, CPT codes 99446–99449 should not be reported. Additionally, the service concludes with the consulting psychologist providing both a verbal opinion report and a written report to the treating/requesting provider.

Consultation Services without Discussion, Only Written Report Required (CPT code 99451)

CPT code 99451 is reported for the total time spent by the consulting psychologist to access data/information via the electronic health record (EHR), telephone, or internet, performing data review and/or analysis, and interprofessional communication. While a verbal opinion report is not a required component when reporting code 99451, the psychologist must provide a written report to the treating/requesting provider for inclusion in the patient record.

Another core component of the interprofessional consultation services is the acquisition of advance patient consent. The treating/requesting provider must obtain advanced consent from the patient prior to a psychologist providing consultative services, as it will require a separate copay. APA strongly recommends that psychologists always check the patient’s record to confirm consent has been obtained and documented prior to providing your expert advice.

Case 1

A primary care physician (PCP) consults a psychologist by telephone conversation. The PCP states that consultative services are needed for a 20-year-old Latinx female patient who presents with flat affect, weight gain, and significant fatigue. The patient reports that she has been staying up until 3 or 4 a.m. and sleeping all day. She failed two of her classes and will have to attend summer school to make up the credits. Her PHQ-9A is elevated (14) and she reports having thoughts of harming herself on item 9.

The psychologist consultant reviews the case and verbally provides the PCP with assessment and management recommendations which include the need to complete a risk assessment and safety plan prior to leaving the clinic, a plan to conduct ongoing safety checks, and referral to a community therapist. Also, recommendations on sleep hygiene, behavioral activation, and lifestyle issues related to weight management. The psychologist then writes up the assessment and management recommendations and transmits the report to the treating/requesting provider for inclusion in the patient medical record.

Billing: Report one unit of CPT code 99449, indicating the psychologist spent a total of 35 minutes of consultative services, including 20 minutes of verbal discussion with the patient’s treating provider, and 15 additional minutes reviewing the patient’s medical record, doing research review, creating and sending the written report of findings, and expert advice.

Case 2

A pediatrician consults a psychologist electronically through the EHR. The pediatrician states reason for consult: “Patient is 4-year-old child with speech delay that is exhibiting impulsive behaviors that include tantrums and aggression towards siblings. Pediatrician indicates they are looking for guidance on typical development, differentiating ADHD from other disruptive behavior problems, and possible non-medication treatment options.”

The psychologist consultant reviews the case and provides assessment and management recommendations which includes information regarding differential diagnosis of ADHD or disruptive behavior disorders, including discussion of diagnostic criteria and patient’s symptom presentation. Psychologist consultant recommends evidence-based behavioral therapy interventions for disruptive behavior particularly those emphasizing the increase in positive attachment/warmth and decreasing harsh/coercive parenting.

Time: 16 minutes total time. (10 minutes of responding to the patient’s treating provider via EHR about the case and giving recommendations and six additional minutes of chart review and documentation).

Billing: Report one unit of CPT code 99451, indicating the psychologist spent a total of 16 minutes: 5 minutes performing consultative services, and 10 minutes responding to the patient’s treating provider via EHR about the case and creating and sending the written report of recommendations to treating provider (all communication was electronic).

Interprofessional consultations are time-based services; therefore, psychologists are required to document the start and stop times and/or total time spent providing consultation services. When reporting consultation services that require both a verbal and written report (codes 99446–99449), code selection is based on cumulative, even if that time occurs on multiple days.

• Do not report codes 99446, 99447, 99448, 99449, or 99451 more than once for the same patient in a 7-day period.
• When performed on the same date of service as….
• Do not report 99446, 99447, 99448, or 99449, if greater than 50% of time is spent in data review and/or analysis, do not bill those codes.
• Do not bill 99451 for services that last less than five minutes of consultative service.

Treating providers can request the opinion and/or treatment advice of a physician or other QHP, such as a psychologist, that has specific specialty expertise, to assist in diagnosis and/or management of the patient’s problem, without the consulting provider ever seeing the patient.

When consultative services are requested, the patient can be a new or an established patient to the consultant, and the condition for which the consultation is being requested can be a new or existing problem.

Proper reporting of interprofessional consultation services can occur as long as:

• The psychologist consultant has not had a face-to-face visit with the patient within the last 14 days, and/or

• The consultation services provided by the psychologist does not result in a face-to-face service with the patient within the next 14 days.

The following are examples of situations where it would not be appropriate to report interprofessional consultation services:

• If an in-person visit with the psychologist consultant has occurred within the previous 14 days or will occur within the next 14 days.
• If the sole purpose of the communication with a treating provider is to arrange transfer of care or an in-person consultation with the psychologist consultant.

Additionally, interprofessional consultation services cannot be reported more than once, for the same patient, in a 7-day period.

The following are required items to be documented in the patient medical record when these services are provided:

• Verbal consent was obtained by the treating/requesting provider for the interprofessional consultation from the patient/family.
• The treating/requesting provider’s written or verbal request, as well as the reason the request was made, for the consult.
• The amount of time spent providing the interprofessional consultation services, and should be reported based on cumulative time spent, even if that time occurs on subsequent days.

APA recommends that, in order to reduce the risk of your claim(s) being denied for reporting noncovered/noncontracted codes, you should check each payer policy, as well as the list of codes included in your contract with each payer, to determine which codes are covered/reimbursed. Additionally, please refer to APA’s Payers Guide: Utilizing Interprofessional Telephone/Internet/Electronic Health Record Consultations CPT® Codes for Psychologists for further information on advocating for coverage of these services.

NCCI has specifically indicated that you cannot provide psychotherapy services and interprofessional consultation services, for the same patient, on the same date of service.

It is important to note however, that while specific NCCI edits do not exist for code(s)/service(s) typically provided and reported by psychologists, the psychologist consultant cannot report interprofessional consultation services if:

• they had a face-to-face visit with the patient within the last 14 days, and/or
• the consultation services provided by the psychologist results in a face-to-face visit with the patient within the next 14 days.

Psychologists should bill interprofessional consultation services based on whether the consult was with or without discussion and the time spent providing the consultation.

If the consult was with discussion, the psychologist will bill codes 99446–99449, based on the total/cumulative time devoted to performing the service. Code selection is then based on the specified time frames stated in the CPT code descriptors (99446: 5–10 minutes, 99447: 11–20 minutes, 99448: 21–30 minutes, and 99449: 31+ minutes).

If the consult was without discussion and greater than five minutes, 99451 is billed.

The patient for whom the interprofessional telephone/internet/electronic health record consultation is requested may be either a new patient to the consultant or an established patient with a new problem or an exacerbation of an existing problem. The consulting provider, however, cannot have a face-to-face encounter with the patient 14 days before or after offering treatment recommendations to the attending provider.

• APA Payers Guide: Utilizing Interprofessional Telephone/Internet/Electronic Health Record Consultations CPT® Codes for Psychologists
• National Alliance on Mental Illness: Mental Health By the Numbers (last updated June 2022)
• Centers for Medicare and Medicaid Services: National Correct Coding Initiative Edits webpage
• American Psychiatric Association: Payment Non-Face-to-Face Services: A Guide for the Psychiatric Consultant (PDF, 139KB)
• American Academy of Pediatrics: AAP News: 2 New Codes Developed for Interprofessional Consultations (PDF, 529KB)