The NPI Taxonomy Codes for Psychology: APA Practice Organization Offers Guidance, Advocates for Change
by Legal/Regulatory Affairs and Communications Staff
June 19, 2006 -– APA members have raised questions and concerns about choosing a “taxonomy code” in applying for a National Provider Identifier (NPI), as required by the Health Insurance Portability and Accountability Act. This article provides information and guidance about the NPI taxonomy codes that pertain to psychology and summarizes continuing efforts by the APA Practice Organization to advocate for changes to these codes.
The National Provider Identifier (NPI)
The NPI is a unique 10-digit number assigned to every health care provider or entity that applies for it. This number will replace other numbers that have been assigned to health care professionals by government and private insurers for use in billing for services.
Once a health professional receives an NPI, the number is assigned to that health professional for his or her entire career, regardless of whether the health professional relocates, changes employers or even changes health professions. As of May 23, 2007, all health care professionals will be required to use their NPI when billing electronically any government or private health insurer.
Even if a health professional is not subject to HIPAA, for example, because he or she submits claims using a paper format instead of electronically, it is likely that private health insurers will require that all claims include an NPI. For that reason, all health professionals should obtain an NPI if they intend to bill a private insurer.
The Taxonomy Codes
The NPI application process requires applicants to provide certain information, similar to what private insurers or the government typically request when a health professional applies to be part of a provider panel. As part of the application process, the Centers for Medicare and Medicaid Services (CMS) requires that all types of health practitioners list a “taxonomy code” or codes that describe(s) their profession, and, when applicable, their specialty.
The taxonomy codes were originally developed before the passage of HIPAA for the purpose of developing a national identification system. Since 2001, the taxonomy codes have been maintained and updated by an organization known as the National Uniform Claims Committee (NUCC). The NUCC replaced the committee that developed the first uniform paper claim form, known as the CMS-1500. The Committee’s current objective is to develop a uniform electronic claim “form” to be used by health care practitioners other than institutions.
The taxonomy codes held little relevance for psychologists until 2004, when CMS authorized their use in connection with the NPI. This meant that, for the first time, the codes would be used by psychologists to identify their practices.
Unfortunately, despite the new importance of the taxonomy codes, the NUCC did not attempt to update the codes nor did the organization consult with APA to determine whether its list appropriately represented the field of psychology. It appears that the list must have been created some time ago, as the NUCC is currently unable to tell us how or when the codes for psychology were developed.
The NUCC’s current code list includes two general codes related to psychology: “psychologist” and “neuropsychologist.” In addition to these two codes, there are 19 specialty codes, such as addiction, forensic and psychoanalysis. To obtain an NPI, psychologists must choose at least one taxonomy code.
Psychologists Raise Concerns About the Codes
APA members have raised several questions and concerns about the taxonomy codes. Since most of the codes are not accompanied by definitions and since psychologists typically practice in several different areas, many practitioners are unclear about which and how many codes to choose.
CMS has offered no written guidance on these issues, stating to our staff only that psychologists should select the code that most closely describes the provider, but not necessarily all the taxonomy codes that apply. This advice has left many APA members uncertain as to whether they should choose a specialty code(s).
In addition, practitioners are concerned that health insurers will have access to the information listed in the NPI application, such as the taxonomy codes, and will use that information in ways that may affect psychologists’ reimbursement. Based on communications with government officials, the APA Practice Organization staff expects taxonomy code and other information on the NPI application to be accessible to health insurers. Health plans are requesting such information to help ensure that providers who apply for their networks are not fraudulently using other health professionals’ NPI.
As a result, even though the NPI on its face does not expressly convey information about the professional's areas of practice, the availability of the underlying materials which do reference practice areas is a cause for concern of potential use of the information by payers in a manner not intended by the creators of the NPI and accompanying taxonomy codes.
The APA Practice Organization has expressed the concern to CMS representatives that access to the taxonomy codes chosen by individual providers might be used inappropriately by health insurers -- for example, to restrict the kinds of services that a health professional may bill and be reimbursed for providing. CMS officials have assured us that the agency does not intend for the Medicare or Medicaid programs to use the codes in such a manner.
Even so, the APA Practice Organization remains wary that, at the very least, private health insurance payers could use taxonomy code information to limit or deny payment for services. For example, if a psychologist selected the specialty taxonomy code for “Child, Youth and Family,” would a private insurer refuse to reimburse this health professional for psychological services not involving children or adolescents? Or, if a psychologist selects multiple specialty taxonomy codes, will insurers consider the practice so broad that they would question that practitioner’s expertise in any one of the specialty areas chosen?
A Thorny Issue for Neuropsychology
Based on communication with representatives of APA Division 40 (Clinical Neuropsychology), the APA Practice Organization is concerned with the inclusion of “neuropsychologist” among the taxonomy codes for the same reasons we are concerned about the inclusion of the codes identified by the NUCC as “specialty codes.”
The specialty designations are not suitable for psychology in that practicing psychologists typically do not limit themselves to practice in a certified specialty or specialties. At any point in time, a psychologist may have expertise in and practice in one or more of the categories listed among the designated specialty codes (or in a certification that is not listed among the codes). But psychologists generally do not consider themselves as limited to practicing in those categories and may readily add or discontinue areas of practice over time.
This situation applies to some neuropsychologists, whose practices may also include providing other professional services such as psychotherapy, feedback and cognitive rehabilitation.
Yet the fact remains that the taxonomy code list currently includes “neuropsychologist” along with “psychologist” as the two general codes pertaining to psychology. Therefore, to guard against the potential risk of having certain health insurers restrict reimbursement for their professional services based on the provider’s choice of taxonomy codes, neuropsychologists whose practices consist entirely of delivering neuropsychological services might appropriately choose the “neuropsychologist” taxonomy code. On the other hand, qualified neuropsychologists are encouraged to consider choosing both the “psychologist” and “neuropsychologist” codes if providing other services makes up a substantial portion of their practice.
More Concerns About the Specialty Codes
The APA Practice Organization’s additional concerns about the specialty codes include:
These codes are inappropriate in that they do not generally represent recognized specialties in the field of psychology. Most of the NPI specialty codes for psychology do not correspond with any nationwide certifications for psychology that are approved by a professional board. One example involves the taxonomy code, “Men and Masculinity.” While this is a well recognized area of interest, study and activity in the field of psychology, there is no certification or credential available to identify psychologists who might work in this area.
In addition, several national certifications that do exist are not reflected on the specialty code list. Since the specialty codes do not correspond to certifications within the field, psychologists will interpret these codes in different ways. Use of the specialty codes by psychologists therefore will not be uniform and will not provide meaningful information about a psychologist’s practice.
There is no standard against which psychologists can determine whether a practice fits within a given specialty. Only one of the 19 specialty codes – psychoanalysis – is presently accompanied by a definition provided by NUCC. The other 18 codes indicate “definition to come.”
For such reasons, in an April 2006 letter to the NUCC chair, APA Executive Director for Professional Practice Russ Newman, PHD, JD, urged the committee to remove the entire list of 19 specialty codes. At the same time, the APA Practice Organization is encouraging removal of the “neuropsychologist” code insofar as its inclusion may generate inaccurate information through the NPI application process.
In essence, according to Dr. Newman, the list of taxonomy codes in its current form is inconsistent with the way psychology is practiced and the use of these codes will create more confusion than clarity.
Guidance for Practicing Psychologists in Choosing a Taxonomy Code
This conclusion has led the APA Practice Organization to recommend that licensed APA members choose only the general “psychologist” taxonomy code (103T00000X) if they apply for an NPI at this time.
One exception to this guidance applies to qualified neuropsychologists. (The definition of “neuropsychologist” as provided by NUCC in the taxonomy code list is: an individual with a doctorate degree, licensure in clinical psychology and specialized training or board certification in neuropsychology who practices or adheres to the principles of neuropsychology; a specialty within the field of psychology focusing primarily on neurobehavioral functioning.)
Qualified neuropsychologists should consider choosing two codes -- the “neuropsychologist” code (103G000000X) as well as the “psychologist” code (103T00000X) – if, in addition to neuropsychological services, the psychologist is providing services such as psychotherapy, feedback, and/or cognitive rehabilitation and these services constitute a substantial portion of their practice. On the other hand, qualified practitioners who provide only neuropsychological services may wish to choose just the neuropsychologist code.
If you determine that you would like to choose a specialty code, you should be aware of related information we received from CMS. Specialty codes are intended to reflect how you spend a substantial portion of your professional time. The codes are not intended to capture every type of service that you may offer or with which you have experience. Therefore, if you do choose to use a specialty code, you should choose the code(s) that most closely describe(s) your practice, but not necessarily all the codes that apply.
Our guidance on this issue would change if the NUCC concurs with the APA Practice Organization’s recommendations and revises the code list pertaining to psychology by deleting all codes except the general “psychologist’ code. If this ultimately happens, the APA Practice Organization anticipates that anyone who selected “neuropsychologist” or the 19 specialty taxonomy codes under “psychologist” would be reassigned to the general “psychologist” code. Practitioners are not required to check periodically to see if the taxonomy codes related to psychology have been changed, and they are not required to reapply for an NPI should such a change occur.
Pressing Psychology’s Concerns
The early initial feedback from NUCC to Dr. Newman’s letter was generally unreceptive and indicated that the more detail that is provided in the taxonomy code system, the better it is for the NPI’s purpose of distinguishing individual providers. Further, the communication from NUCC indicated that deleting codes would be problematic in light of the fact that many providers already have applied for and received their NPI. The Practice Organization, however, continues to pursue this matter.
Additional information and practical guidance about applying for an NPI appears in the companion article, “Applying for a National Provider Identifier: Information and Guidance for Psychologists.”
 |
|
|
The_NPI_Taxonomy_Codes_for_Psychology.pdf 63 Kb |
