A new Current Procedural Terminology (CPT®) code for cognitive function intervention will go into effect on January 1, 2018, and will replace the current CPT code 97532—Development of cognitive skills to improve attention, memory, problem solving (includes compensatory training), direct (one-on-one) patient contact, each 15 minutes.
The new code will be published in the CPT code book as:
97127 Therapeutic interventions that focus on cognitive function (eg, attention, memory, reasoning, executive function, problem solving, and/or pragmatic functioning) and compensatory strategies to manage the performance of an activity (eg, managing time or schedules, initiating, organizing and sequencing tasks), direct (one-on-one) patient contact.
(Report 97127 only once per day)
(Do not report 97127 in conjunction with 0364T, 0365T, 0368T, 0369T)
As noted in the descriptor, 97127 may be reported only once per day—regardless of the amount of time spent—because it is an untimed code. Most CPT codes used to report speech-language and swallowing related services (e.g., CPT code 92526 for treatment of swallowing and feeding disorders) are untimed.
Medicare Will Not Accept 97127
The Centers for Medicare & Medicaid Services (CMS) will not recognize CPT code 97127 for Medicare payment. Instead, CMS created the following G-code to report cognitive treatment services, also effective January 1, 2018.
G0515 Development of cognitive skills to improve attention, memory, problem solving (includes compensatory training), direct (one-on-one) patient contact, each 15 minutes
G-codes are developed by Medicare for specific programmatic needs that cannot be met using existing codes, such as the G-codes used for functional outcomes reporting. However, G0515 has no connection to the functional outcomes reporting system and should be reported the same way as a CPT code on the claim form.
G0515 contains the same descriptor as former CPT code 97532, and the payment rate is very similar. If speech-language pathologists provide cognitive treatment services to Medicare patients, they should report them with G0515 in the same manner that 97532 was reported.
The change in code number has not changed standing Medicare policies regarding the provision of and payment for cognitive therapy services. For example, like former code 97532, speech-language pathologists should not bill G0515 on the same day as CPT code 92507 (speech, language, voice, communication treatment). The National Correct Coding Initiative (NCCI) provides further detail on CMS rules regarding same-day billing of CPT codes. NCCI edits related to speech-language pathology services are published on ASHA’s website and updated quarterly.
Additional information regarding G0515 and 97127 is also available on ASHA’s webpage for new and revised CPT codes.
Work with Payers to Ensure Appropriate Implementation
If speech-language pathologists bill cognitive treatment services to patients with a non-Medicare payer (i.e., Medicaid, Medicare Advantage or Part C, or private health insurance), they should check with each payer to verify whether they should submit CPT code 97127 or G0515 on the claim form.
Speech-language pathologists should also carefully review the payment rate associated with CPT code 97127 to ensure that payers are not reimbursing it at the same rate as a single 15-minute unit similar to former CPT code 97532.
ASHA is contacting state Medicaid agencies and other major payers to inform them of the coding change. Speech-language pathologists may also customize the template letter [DOC] developed by ASHA to inform the payers they work with directly.
Contact ASHA at email@example.com, if it appears that a payer is not appropriately implementing the new cognitive therapy code as an untimed service.
This coding change came about due to pressure from CMS to revise the entire Physical Medicine & Rehabilitative (PMR) family of codes, which arose from concerns regarding overutilization and issues with the time-based component of the codes. The PMR family includes the 97000 series of codes, typically billed by physical therapy and occupational therapy, and 97532, which is primarily billed by speech-language pathologists and psychologists for outpatient Medicare Part B services. Occupational therapists also use CPT code 97532, though to a much lesser degree, in outpatient settings. ASHA worked with the American Psychological Association (APA) and the American Occupational Therapy Association (AOTA) to develop the new code for cognitive function intervention.
ASHA will provide speech-language pathologists with updates on the use of these new codes through The ASHA Leader, ASHA Headlines, and ASHA’s billing & reimbursement website.
For questions, please contact ASHA’s health care economics and advocacy team at firstname.lastname@example.org.