Using code 90785 responsibly: A guide for mental health providers
Code 90785 represents “interactive complexity.” But what does that mean?
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At a Glance
- Code 90785 applies when providers must use extraordinary interventions due to client-specific factors.
- Documentation for interactive complexity should clearly explain why standard therapeutic approaches weren’t sufficient.
- Bill 90785 sparingly — it’s for exceptional circumstances, not just challenging therapy sessions.
Proper billing of Current Procedural Terminology (CPT) codes is essential for successful private practice operations. Developed and registered by the American Medical Association (AMA), CPT codes streamline the billing process for both providers and payors by assigning specific codes to healthcare services and their timeframes. Mental health providers commonly use codes such as 90791 (diagnostic evaluation/intake assessment); 90832, 90834, and 90837 (psychotherapy lasting for 16–37 minutes, 38–52 minutes, and 53 minutes or more, respectively); and 90853 (group psychotherapy).
One frequently misunderstood code is 90785, which represents “interactive complexity.” The vague terminology has led to both overuse and underuse among practitioners. Providers who shouldn’t bill for this code do so, while others who should tack it onto an insurance claim do not. So where did this code originate? What is its purpose? And how can you know when it’s acceptable to use?
What is interactive complexity?
Near the close of 2012, code 90785 was created to properly bill sessions involving exceptional circumstances that require providers to perform additional work to sufficiently treat their clients. This code allows practitioners to collect additional dollars for these unique situations.
Examples of circumstances that warrant using code 90785 include when providers must:
- Address disruptive behavioral or emotional reactions from the client’s caregivers that would otherwise hinder treatment progress
- Use physical resources or play supplies to adequately engage with or assess the client
- Report safety-related matters to outside parties, such as making a Child Protective Services (CPS) call upon learning of a minor client’s abuse
- Manage negative communication from the client or others that interferes with service delivery
A simple framework for using code 90785
The professional guidelines for using code 90785 give some clarity to this puzzling designator, significant room remains for subjective decision-making. A straightforward approach is to ask yourself, Was it necessary to provide out-of-the-ordinary interventions during this session to successfully treat your client?
“A straightforward approach is to ask yourself, Was it necessary to provide out-of-the-ordinary interventions during this session to successfully treat your client?”
The key distinction lies in necessity. You may want to be financially compensated when you offer advanced services, like eye movement desensitization and reprocessing (EMDR), or go over the hour mark while politely listening to your client’s overtalkative parent, but the hard line established by code 90785 involves your need to respond in these ways. For example:
- Did you have to offer EMDR because your client would otherwise become mute and mentally disengage from treatment?
- Did you have to meet at length with a parent because their severe anxiety prevented you from finalizing their child’s treatment plan?
These examples represent the difference between a tough appointment and one with interactive complexity.
Rather than signifying that additional time was required, code 90785 indicates that more was necessitated from the provider than during a typical appointment due to client-related factors. It alerts payors that the session warranted non-routine or special adaptations to adequately meet the client’s needs.
Remember: This code can’t be billed on its own. It must accompany a standard service code, such as psychotherapy (90832, 90834, or 90837), initial evaluations (90791), or group psychotherapy (90853).
When to bill code 90785 (and when to resist)
The prospect of securing extra dollars for challenging sessions is appealing. Many in the healthcare field don’t believe we’re adequately paid, so charging for code 90785 seems extra enticing.
Thoughtful consideration, though, is essential to uphold professional integrity. Otherwise, we risk overcharging clients, misreporting to insurance companies, and downgrading the quality of our work.
To better assess the suitability for billing interactive complexity, consider the following scenarios that provide solid grounds for using code 90785. Remember that these events are the exception, not the rule; their sporadic occurrence justifies the potential use of this code:
- An adolescent discloses abuse during their appointment, requiring you to make a CPS report and discuss safety planning with the minor and their non-offending guardian.
- An adult client enters their session crying about a non-emergency matter and continues sobbing excessively throughout the clinical hour, making substantial therapeutic conversation impossible.
- You’re providing parent-child interaction therapy (PCIT), which requires vigorous coaching of the parent throughout sessions and reliance on multiple electronic devices.
- An adult client admits to substance use that violates their parole requirements, requiring you to contact their parole officer and discuss consequences.
- During a conjoint session with a child client and divorcing parents, both parents begin yelling at each other, requiring you to focus on de-escalation rather than reviewing their child’s treatment progress.
When to resist billing code 90785
Occasions that do not justify the use of code 90785 include:
- Incorporating simple activities, like a drawing assignment or interactive game, to build rapport
- Providing couples or family therapy (use codes 90846 or 90847 instead)
- Allowing a session to run over its scheduled timeframe
Furthermore, you can’t bill code 90785 just because a client presents with symptoms that are difficult to manage. Mild to moderate emotional dysregulation (crying, raised voices, shutting down) is expected in therapy, and clinicians are trained to address these reactions. Unless these responses become so pronounced that treatment plan goals become unworkable, they don’t qualify for interactive complexity.
If you find yourself performing crisis counseling, don’t bill code 90785; use the following codes instead:
- 90839 for the first 60 minutes of psychotherapy addressing a crisis
- 90840 for each additional 30 minutes spent resolving the crisis
These codes alert payors that an emergency situation unfolded, not just typical challenges.
Questions to consider before billing for interactive complexity
Keep in mind that payors may deny payment for this code, and that it must be billed alongside a standard service code. Consider these questions when preparing insurance claims:
- Does my documentation clearly explain why code 90785 was appropriate? If audited, your progress notes should support the charges. Expect that payors will read your notes and document with their perspective in mind.
- How would it affect my client to know their session had interactive complexity? Be prepared to explain code 90785 if it appears on their explanation of benefits (EOB). Your ability to clearly, confidently, and correctly articulate why you applied this code diminish the chances that you’ll be accused of overcharging or inappropriate billing.
- In what ways did I provide care that was out of the ordinary? Identify the exact circumstances that required non-standard interventions. Addressing clients’ emotional outbursts and complex concerns are standard. Outliers form the rationale for code 90785.
- Were these exceptional interventions necessary? Clients who are self-controlled, mentally stable, and eager to learn coping skills don’t require complex interventions. Save code 90785 for clients whose need more intense assistance, like the child whose violent tantrums left a hole in your office wall or the adult whose multiple panic attacks derailed their last session.
- Does my client’s health plan cover code 90785? Your client’s insurance company might not include reimbursement for this code. Check with the health plan before submitting claims.
- How often do I bill code 90785? Code 90785 provides a small ($5–$15) surplus that can quickly add up. But regular use raises red flags for payors and increases audit risk. Meticulously monitor how often you bill for this code.
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Reaping the benefits
The guidelines for using code 90785 are just vague enough for providers to interweave their subjective experiences with objective standards. When used appropriately, this code offers fair compensation for sessions requiring extraordinary interventions. Exercise caution when billing this code and enjoy its provisions for a job well done.
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