Who Can Bill TMS or ECT? Physician-Only Procedures
Title: Who Can Bill TMS or ECT? Physician-Only Procedures
SEO Title: Who Can Bill TMS or ECT Procedures?
Meta Description: Learn who can bill TMS and ECT, what prior authorization and place-of-service checks involve, and how to reduce preventable claim problems.
Category: Coding & Reimbursement
Author: MCM South Billing Team
Publish Date: TBD — angle: credentialing/physician-only scope
TMS, or transcranial magnetic stimulation, and ECT, or electroconvulsive therapy, are physician-level procedures with billing rules that differ from routine psychotherapy. Their CPT codes are 90867–90869 for TMS and 90870 for ECT. Confirm code details against the current AMA CPT code set and the specific payer’s policies before submitting a claim.
For billing purposes, the key checks are who performed or supervised the service, whether prior authorization applies, and whether the claim reports the correct place of service. These are billing and credentialing considerations, not clinical guidance.
TMS Billing Codes (90867–90869)
The TMS code set separates the initial treatment from later treatment sessions and certain motor-threshold services. The exact code depends on what happened during the billed service. Do not select a code based only on the patient’s place in a treatment course or on a recurring appointment schedule. Match the documented service to the current CPT descriptor and payer instructions.
Payers commonly require prior authorization for TMS. The review may involve a request from the ordering or treating clinician, supporting records, the proposed service, and the provider or location information. Requirements vary by plan. An authorization is not a guarantee of payment, and it may apply only to specified dates, codes, providers, or locations.
Before the first billed session, check whether authorization is required, what records the plan requests, and how it wants the authorization linked to claims. Track approved dates and any extension or renewal requirements. MCM South’s overview of TMS and ECT procedure billing for psychiatric practices offers additional billing context.
ECT Billing Code (90870)
CPT 90870 is the procedure code for ECT. Confirm the current code descriptor and payer billing instructions before use. The claim should identify the physician responsible for the service and accurately reflect where the procedure took place.
Place of service (POS) is the code on a claim that identifies the setting where a service was provided. ECT may involve a facility setting, so do not assume the office POS applies. Confirm the correct POS for the actual service location and whether professional and facility billing are handled separately. Payers can have specific instructions for how the claim should be submitted. See place-of-service rules for TMS and ECT billing for more on matching the claim to the setting.
Why These Claims Get Extra Scrutiny
TMS and ECT claims can involve several checks beyond those used for a routine psychotherapy claim:
- Prior authorization: The payer may compare the submitted code, service dates, provider, and location with the authorization on file.
- Provider credentials: The payer may check whether the rendering or supervising physician is enrolled and credentialed for the billed procedure.
- Documentation: The record should support the service reported, the date, and the responsible clinician. Follow the payer’s documentation requirements and retain authorization records.
- Code and claim details: A mismatch between the documented service and CPT code, or between the claim and authorization, can delay or prevent payment.
- Place of service: The claim must reflect the setting where the service occurred and follow the payer’s instructions for professional and facility claims.
These checks do not mean a claim is automatically at risk. They mean the billing workflow should capture authorization, provider, code, and location details before the claim goes out. MCM South’s guide to documentation requirements for mental health CPT codes explains why clear, complete records matter across behavioral health billing.
Who Can Bill and Perform These Procedures
TMS and ECT are physician-only procedures for billing purposes. A psychiatrist (MD or DO) must perform or directly supervise the treatment as required by the applicable payer and state rules. A psychologist, therapist, or other non-physician provider should not bill these procedure codes under their own credential.
Credentialing is more than having a clinical license. Check that the physician is enrolled with the plan, has the required specialty and procedure privileges, and is linked correctly to the practice and service location. Also confirm who the payer expects to appear as the rendering, supervising, or billing provider.
The billing distinction is not the same as the difference between psychiatric diagnostic services and psychotherapy. There is no non-physician substitute code for TMS or ECT. For a broader overview of mental health billing codes, including psychotherapy and evaluation services, review the applicable code guidance. For physician-versus-psychologist credential questions, confirm the specific state scope rules and payer policy; do not infer procedure billing eligibility from a provider’s role elsewhere in the patient’s care.
Nurse practitioner and physician assistant participation needs a separate check. State supervision rules and payer policy can differ. Do not assume that a non-physician clinician may bill or supervise either procedure simply because they participate in care.
Can a psychologist bill for TMS or ECT?
No. For these physician-only procedure codes, a psychologist or other non-physician provider should not bill under their own credential. Confirm the responsible psychiatrist’s enrollment, role, and payer-specific requirements before filing the claim.
FAQ
Can a psychologist bill for TMS or ECT?
No. These are physician-only procedures for billing purposes. A psychiatrist must perform or directly supervise the service as required by applicable payer and state rules.
Does a nurse practitioner or PA ever bill TMS or ECT?
Do not assume so. Rules can depend on the state, the clinician’s scope, and the payer’s policy. Verify all three before assigning a billing or supervising role.
What happens if a non-physician’s credential is on a TMS or ECT claim?
The payer may deny or pend the claim if the provider credential does not meet its requirements. An incorrect provider assignment can also prompt additional review. Check the rendering and supervising provider fields against the authorization and payer instructions before submission.
Does prior authorization guarantee payment?
No. Authorization confirms that the payer approved a request under its stated terms. The claim still has to meet eligibility, coding, credentialing, place-of-service, and timely filing requirements.
Which place-of-service code should I use for ECT?
Use the POS that matches where the service occurred, following the payer’s instructions. Verify whether professional and facility claims require separate submissions or different billing details.
The Takeaway
TMS and ECT do not have a lower-credential billing alternative. Before filing, confirm the physician’s credential and role, the authorization details, the code that matches the documented service, and the actual place of service. MCM South focuses exclusively on mental and behavioral health billing, where these procedure-specific checks sit alongside routine eligibility, claims, and denial follow-up.
Quick Action Checklist
- Confirm a psychiatrist performed or directly supervised the procedure as required by state rules and payer policy.
- Match the CPT code and service date to the record and the authorization on file.
- Verify the rendering provider, service location, and POS before submitting the claim.
Images (2)
Watch
MCM South Medical Billing Service — YouTube Channel
MCM South Medical Billing Service, LLC has specialized in mental and behavioral health billing since 2010. We serve practices in Georgia, Massachusetts, Connecticut, Texas, Florida, and New York, with billing experience across all 50 states.
Related topics for a future post
- Psychiatrist vs. Psychologist: Credentials, Scope & Billing Differences
- TMS & ECT Procedure Billing for Psychiatric Practices
- Documentation Requirements for TMS and ECT Claims
