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What Pain Physicians Must Know (CPT 96136–96139)

10/28/2025

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CMS Compliance for Psychological Test Administration Codes: What Pain Physicians Must Know (CPT CODES 96136–96139)
1) Scope & Intent (What these codes are)

What:
Standardized test administration and scoring to evaluate cognitive and behavioral effects of central nervous system (CNS) impairment — diagnostic, not therapy.
​

Why:
Testing must inform diagnosis, prognosis, and treatment planning in a medically necessary pain management strategy.


Current (valid) CPT® codes only:
  • 96136 – QHP* administration & scoring, first 30 min (≥31 min)
  • 96137 – QHP add-on, each additional 30 min
  • 96138 – Technician administration & scoring, first 30 min → requires direct supervision
  • 96139 – Technician add-on, each additional 30 min → requires direct supervision
* QHP = Psychologist / Physician / NP / PA acting within Medicare scope
These services must produce actionable findings that change the pain plan.​
2) Medical Necessity (WHEN you may test)

Covered only when results directly change pain management decisions such as:
  • Neuromodulation (SCS/PNS/pump) candidacy & safety
  • Opioid-related cognitive impairment affecting risk/compliance
  • CRPS / chronic pain with psychological overlay
  • Post-TBI or neurological disease affecting rehab performance
  • Cognitive impact of CNS-acting medications requiring plan modification
CMS standard: If testing does not change care → NOT covered

Not medically necessary (do not bill):
  • Screening tools alone: MMSE / MoCA / PHQ-9
  • Educational/vocational evaluations
  • Routine Alzheimer’s follow-up with no plan change
  • Patient cannot validly participate (incl. intoxication)
  • Repeat testing without new clinical justification
    ​
3) Time & Billing Rules (HOW to code)
31-minute rule: Minimum 31 minutes required per unit of service
Multi-day testing: Total all minutes → bill on final DOS
Add-on codes:
  • 96137 requires 96136
  • 96139 requires 96138
    → Only after full additional 30 min is met


Technician codes require:
  • Direct supervision
  • QHP on-site & immediately available

Only administration & scoring included
→ Interpretation/report writing = separate code family

Standard test batteries are NOT automatically covered
→ Each test must be individually justified


4) Documentation Requirements (WHAT the chart must show)
Your documentation MUST include:
  • Clear clinical findings supporting suspected CNS impairment
  • Medical necessity: why testing is needed now
  • Named standardized tests administered (not generic references)
  • Exact time per CPT and per date
  • Patient behavior & test validity observations
  • Functional implications (adherence, decision-making, safety)
  • Specific treatment changes based on results
  • Prior testing reviewed — duplication avoided
  • Report sent to ordering/referring provider
If >8 hours → add written justification

Audit Pro-Tip:
Include management change:

“Findings support proceed with SCS trial”
“Adjust opioid plan due to cognitive risk”
“Defer high-risk procedures pending cognitive improvement”


5) Compliance Guardrails (avoid denials)
  • Must be diagnostic — NOT psychotherapy
  • Do NOT bill screening inventories alone
  • Must document direct supervision for 96138/96139
  • Remove deleted legacy codes:
    96101–96120, 96111
  • Results must be tied to medical decision-making
  • Only licensed, Medicare-enrolled QHPs can bill
If medical necessity or supervision is unclear → denial likely

6) EMR Smart-Phrases:
Medical Necessity (MDM)
Neuropsychological test administration and scoring were medically necessary to evaluate cognitive and behavioral factors materially impacting neuromodulation suitability and/or opioid medication safety. Results will directly inform treatment selection, adherence strategies, and clinical risk mitigation in the pain plan.
Time & Tests Block
Standardized tests administered and scored: [LIST TESTS]. Total face-to-face administration/scoring time: [MINUTES]. Time from multiple days combined and billed on the final date of service. Final report provided to referring provider.

✅ ADDITIONAL SECTIONS (as promised)

7) Utilization Safeguards
  • Repeat testing only with new clinical indication
  • Extended testing (>8 hrs) requires rationale
  • Medical records must reflect integration of prior tests
​
8) Ordering & Supervision
Picture
9) Denial Prevention Checklist

✅
Before billing → Confirm ALL:
✔ 31+ minutes documented per code
✔ Named standardized tests
✔ Treatment plan change explicitly stated
✔ Direct supervision (if Tech)
✔ Report sent to ordering provider


✅ CMS References and Sources:

1️⃣ Local Coverage Determination
LCD L34646 – Psychological and Neuropsychological Testing
Centers for Medicare & Medicaid Services (CMS)
🔗 https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdid=34646

2️⃣ Billing & Coding Article
Billing and Coding: Psychological and Neuropsychological Testing (A57481)
Centers for Medicare & Medicaid Services (CMS)
🔗 https://www.cms.gov/medicare-coverage-database/view/article.aspx?articleid=57481


​

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