Recently I posted on this subject, and I felt it was also worthy of a blog!! CPT code 90785—Interactive Complexity. Yes, the one that pops up like a bad habit in psychotherapy claims. And yes, the one that’s often used way too often without documentation that actually backs it up.

I get it. The description is vague. The rules feel murky. And honestly, the phrase “factors complicating communication” opens the door wide for misuse, even when intentions are good.

But if you’re billing this code every time a kid walks in the room with their mom and a stuffed animal, you’re doing it wrong.

Let’s clear this up!!

What Is Interactive Complexity (CPT 90785)?

CPT 90785 is not a standalone service. It’s an add-on code used only when specific communication complexities occur during psychotherapy, group psychotherapy or psychiatric diagnostic evaluations.

It’s not a “because it was a tough session” code. It’s a “because there was a clinical barrier to communication that required extra intervention” code.

Common Misconceptions: What It’s Not

• Using a playroom or art supplies with kids = Not enough. That’s a treatment approach, not complexity.
• Having an interpreter present = Not enough. Federal law requires you to provide one. You only bill 90785 if the interpreter makes communication more difficult, not just because they’re there.
• Mom and dad arguing in the lobby = Not enough. Disruptive? Yes. Interactive complexity? Nope.

What Actually Supports Billing 90785

You need documentation that explicitly shows the complexity. Here’s what does meet the mark:

• A child who is nonverbal or has limited verbal communication and requires alternative methods, causing delays in the session.
• The presence of a third party (e.g., CPS, guardian, probation officer) who complicates the communication.
• Multiple people in the session who are offering conflicting narratives or who argue, requiring redirection to stay on track.
• Disruptive or unsafe behaviors during the session impact the provider's ability to effectively engage in psychotherapy.

What Documentation Should Look Like

Here’s a real-world style note that supports 90785:

“Today’s session included the patient’s biological mother and court-appointed guardian. Each offered conflicting accounts of the patient’s history and attempted to redirect the conversation toward custody disputes, which disrupted the clinical focus. Therapist repeatedly intervened to maintain structure and redirect communication toward the patient’s treatment goals.”

Billing Tips

90785 is an add-on—never bill it by itself.

It can be billed with:

• 90791 (psych diagnostic evaluation)
• 90832, 90834, 90837 (individual psychotherapy)
• 90853 (group therapy—rare, but it happens)

Final Advice: Use It When It Counts

I’m not saying never bill 90785, just bill it correctly. It’s a powerful code when used the right way, but it’s also a red flag in audits if you’re using it every time someone brings a parent into the room or every time a kid has ADHD.

Remember: just because a session was challenging doesn’t mean it was complex in the way CPT defines it.

If you’re struggling to teach this to your team or feel like everyone has a different understanding, it might be time for a quick refresher training. Reach out to see if having an expert come in for documentation training is the right fit!! We love working with organizations who take a proactive approach!