When You Can (And Can’t) Bill for Interactive Complexity CPT 90785

By Barbara Griswold, LMFT (updated December 19, 2024)

In January, Magellan Health plan reported their audits showed some “excessive and improper use” of the Interactive Complexity CPT add-on code 90785.

Therapists are often confused about when they can use this code.  Some don’t use it when they could.  Others are using it when they shouldn’t.  If used appropriately, it can be an ethical way to get the health plan to cough up a few more dollars for your hard work.

What is this code all about?

The add-on code 90785 is meant to be used to give the provider a bit of extra reimbursement when there are certain types of communication difficulties during client sessions.

This code can be separately billed with a psychotherapy code WHEN AT LEAST ONE OF THE FOLLOWING IS PRESENT:

• When delivery of care is complicated due to managing maladaptive communication among involved parties (e.g. high anxiety, high reactivity, repeated questions, or disagreement)
• In a case where the implementation of the treatment plan is hindered due to caregiver emotions or behaviors.
• When a discussion of a sentinel event and/or mandated report to a third party is initiated with the patient and any other participants (e.g. abuse or neglect)
• When the use of play equipment or other physical devices is needed to communicate with the client, to overcome barriers to therapeutic interaction or diagnostic assessment. This might be needed for
  • clients who have not developed or have lost the expressive language communication skills to explain his/her symptoms and response to treatment
  • clients who have lost receptive language skills and are unable to understand the therapist if he/she were to use typical language communication
  • clients who are not fluent in the same language as the therapist

When is this code typically used? 

I know, the definition is a bit vague.  But according to the CPT manual and Magellan, interactive complexity is really meant primarily to be used with

• young and verbally undeveloped or impaired clients
• clients who have other individuals legally responsible for their care [e.g. children]
• clients who request to have others be involved in their care, such as an interpreter or family member
• clients who require involvement of other third parties such as child welfare agencies or parole officers.

This code is probably most often used by play therapists or those who work with young children.  The client’s inability to articulately express emotions and the need for intermediary devices would likely make 90785 appropriate.  In this case, it could be billed for each session where play devices are used.

But you can also use the code with clients of any age.  I used it when working with a mute adolescent, who needed to write all the answers to my questions, adding to the session complexity.

It is also clearly appropriate in a situation where something needs to be reported to officials, such as abuse, though in that case, it would be unlikely to be used repeatedly.

When SHOULDN’T you bill for 90785?

• While this code can be used with the CPT codes for Diagnostic Assessment (90791), Psychotherapy (90832, 90834, 90837), and Group Therapy (90853), you cannot use it for Couples or Family Therapy (90846, 90847), Psychotherapy for Crisis (90839, 90840), or for Psychological or Neuropsychological Testing.
• Don’t use it just because you did a longer session. 90785 is meant to reflect increased intensity of service, NOT increased session time.  (But as always, document in the session note the ACTUAL therapy start and stop time of the session).
• Don’t use it every time just because you have a client who isn’t good at expressing emotions.
• According to the Center for Medicare Services (CMS), “90785 generally should not be billed solely for the purpose of translation or interpretation services.”

Can you use this code for EMDR sessions?  Some therapists I know argue that they use this add on code for all their EMDR sessions.  They may do this because they do longer sessions, and incorrectly think this code is for longer sessions.  Or they may think that EMDR fits the fourth criteria of potential usage, namely “when the use of play equipment or other physical devices is needed to communicate with the client, to overcome barriers to therapeutic interaction or diagnostic assessment.”  I think using this code for EMDR is risky.  Used regularly, the 90785 code could increase your audit risk.  And in an audit, the health plan may ask for their money back, since they may decide that EMDR is not truly necessary to communicate with the client.

Billing tips

• You may want to check to be sure this code is covered by the client’s health plan. Also, check your health plan contract to be sure it is one of the codes on your fee schedule.
• 90785 is an “add-on code,” which means it cannot be billed alone – it needs to be billed along with a code for the session itself.
• You can choose your own fee to charge for the add-on charge. Each health plan will put a cap on what they will pay for this code, if reimbursed.
• While you will sometimes see this code written as +90785, do not use the plus sign on the claim form or superbill. This sign just indicates it is an add-on code.
• On the claim form or superbill, for each date of service, you would have two lines, such as the example below:

Documentation tips

Your documentation should clearly indicate the type of interactive methods used, such as sand tray, games, physical device, puppets, etc., and that the client did not have the ability to fully communicate through normal verbal means.  Or if the code was used for a crisis event, describe the event, and the steps you took to intervene.

Final thoughts

Using this code regularly and for many clients can mean a lot of extra money.  However, remember:  Even if an insurance plan pays for this code, using this code regularly could slightly elevate your risk of an audit.  And in an audit situation where your notes are requested, the health plan could ask for the money back if they feel you used this code inappropriately.