Behavioral Health – Interactive Complexity GuidelinesBy: Sheila Haynes, Manager Coding & Compliance

Defining Interactive Complexity +90785:

  • Interactive Complexity (+90785) is an add-on code utilized for office visits with a psychologist or other mental health professional that are complicated by language, behavior, emotions, mandated reporting requirements or trauma.
  • +90785 is utilized in addition to one of the following primary service codes 90791-90792, 90832-90834, 90836-90838, 90853 (Add-on codes may only be reported in conjunction with other codes, never alone.)

Guidelines for Appropriate Use and Documentation: 

  • Interactive Complexity is used when there are specific communication difficulties present with patients who typically:
      1. Have other individuals legally responsible for their care, such as minors or adults with guardians, or
      2. Request others to be involved in their care during the visit, such as adults accompanied by one or more participating family members or interpreter or language translator, or
      3. Require the involvement of other third parties, such as child welfare agencies, parole or probation officers, or schools.
  • Interactive complexity may be reported with psychiatric procedures when at least one of the following communication difficulties is present:
      1. The need to manage maladaptive communication (related to, e.g., high anxiety, high reactivity, repeated questions, or disagreement) among participants that complicates delivery of care.

      2. Caregiver emotions/behavior that interfere with implementation of the treatment plan.

      3. Evidence/disclosure of a sentinel event and mandated report to a third party (e.g., abuse or neglect with report to state agency) with initiation of discussion of the sentinel event and/or report with patient and other visit participants.

      4. Use of play equipment, physical devices, interpreter, or translator to overcome significant language barriers.

  • Documentation should clearly indicate the type of interactive methods used such as interpreter, use of play, or physical device used, and that the patient did not have the ability to communicate through normal verbal means.

  • Coverage also includes interactive examinations of patients with primary psychiatric diagnoses (excluding dementias and sleep disorders), and one of the following conditions: developmental speech or language disorders conductive hearing loss (total), mixed conductive and sensorineural hearing loss (total), deaf mutism, aphasia, voice disturbance, aphonia, and other speech disturbance such as dysarthria or dysphasia. The conditions must be clearly and concisely recorded in the medical record.

  • Other catatonic states may be covered if documentation is submitted with the claim.

When NOT to use Interactive Complexity:

  • Do not report the +90785 add-on code for Interactive Complexity in conjunction with Psychotherapy for crisis codes or in conjunction with E/M services when no psychotherapy service is also reported.

  • The +90785 code cannot be used in conjunction with:

      • Psychotherapy for crisis codes (90839-90840)

      • Family psychotherapy codes (90846, 90849, 90847)

      • E/M (evaluation and management) service where no psychotherapy service is reported

  • Interactive Complexity should not be billed solely for the purpose of translation or interpretation services. This is because, according to the Centers for Medicare and Medicaid Services (CMS), federal laws prohibit discrimination, “which in this case would take the form of higher beneficiary payments and copayments for the same service, based on disability or ethnicity.” Discernment is advised when billing for translation or interpretation services.