Behavioral Health Provider Types
October 3rd, 2017 - Raquel
In the behavioral health profession there are a several different types of providers with varying degrees and credentials. Third party payer coverage, billing requirements, and reimbursement vary depending on the practitioner’s professional type or specialty. Also, it is important to be aware of individual state scope of practice laws.
This information presented here is based on the official Medicare definitions of providers, along with coverage information from a variety of sources such as Local Coverage Determinations (LCDs). It is important to note that many payers utilize similar guidelines.
Behavioral Health Care Manager<<Do you want the shading? Or just underlined and bolded.
Qualifications
The Behavioral health care manager must have formal education or specialized training in behavioral health. The CPT code book states that it refers to “clinical staff with a master-/doctoral-level education or specialized training in behavioral health.” CMS recognizes the following as acceptable disciplines:
- social work,
- nursing
- psychology
https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/Downloads/Behavioral-Health-Integration-Fact-Sheet.pdf
Role/Responsibilities
The Behavioral Health Care Manager works under the oversight and direction of the billing provider to perform proactive, systematic follow-up using validated rating scales and a registry (where applicable). According to CMS, they perform the following (required for CoCM; optional for General BHI):
<<This following is originally included in a medicare box, but I changed it a little before I found the description. So I’ll let you decide which way you want it?? The blue is from another portion of the document and is not word for word like medicare>>
- Provides assessment and care management services, in consultation with the psychiatric consultant, including
o the administration of validated rating scales
o assess adherence, tolerability and clinical response of beneficiary to treatment
o behavioral health care planning in relation to behavioral/psychiatric health problems, including revision for patients who are not progressing or whose status changes;
o provision of brief evidence-based psychosocial interventions
o ongoing collaboration with the billing practitioner
o maintenance of the registry
- Available to provide services face-to-face with the beneficiary; has a continuous relationship with the beneficiary and a collaborative, integrated relationship with the rest of the care team.
- Able to engage the beneficiary outside of regular clinic hours as necessary to perform the behavioral health care manager’s duties.
- May or may not be a professional who meets all the requirements to independently furnish and report services to Medicare.
- Does not include administrative or clerical staff; time spent in strictly administrative or clerical duties is not counted towards the time threshold to bill the BHI codes.
- Provides assessment and care management services, including the administration of validated rating scales; behavioral health care planning in relation to behavioral/psychiatric health problems, including revision for patients who are not progressing or whose status changes; provision of brief psychosocial interventions; ongoing collaboration with the billing practitioner; maintenance of the registry; al in consultation with the psychiatric consultant.
- Available to provide services face-to-face with the beneficiary; has a continuous relationship with the beneficiary and a collaborative, integrated relationship with the rest of the care team.
- Able to engage the beneficiary outside of regular clinic hours as necessary to perform the behavioral health care manager’s duties.
- May or may not be a professional who meets all the requirements to independently furnish and report services to Medicare.
- Does not include administrative or clerical staff; time spent in strictly administrative or clerical duties is not counted towards the time threshold to bill the BHI codes.
Reimbursement
Reimbursement is based on the “incident to” rules and regulations as well as state law, licensure, and scope of practice. The “incident to” regulation was revised to allow general supervision (rather than the more stringent direct supervision standard in place for most “incident to” services) for the CoCM and general BHI codes as well as the non-face-to-face portion of other designated care management services such as complex chronic care management.<<Have not seen anything in relationship to reimbursement, It does say the following: >>
Medicare will make separate payments to physicians and non-physician practitioners for BHI services they furnish to beneficiaries over a calendar month service period, using four new Medicare Part B billing codes
G0502; G0503; G0504 Psychiatric Collaborative Care Services (CoCM):
G0507 BHI Services other than CoCM
This code may be used to report models of care that do not involve a psychiatric consultant, nor designated behavioral healthcare manager. This code may be updated as more information is available regarding other types of BHI care models that are used.
Clinical Nurse Specialist (CNS)
Qualifications
Coverage <<see https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.pdf>>
A clinical nurse specialist (CNS) must meet the applicable state requirements governing the qualifications for CNSs and meet all of the following requirements:
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The collaborating physician does not need to be present with the CNS when services are furnished or to make an independent evaluation of each patient seen by the CNS.
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Coverage
State law or regulations governing a CNS’ scope of practice in the State in which the services are furnished applies. The provider must develop a list of covered services based on the State scope of practice. Examples of the types of services that a CNS may furnish include services that traditionally have been reserved for physicians, such as:
- physical examinations
- minor surgery
- setting casts for simple fractures
- interpreting x-rays
- other activities that involve an independent evaluation or treatment of the patient’s condition.
- services billed under all levels of evaluation and management codes and diagnostic tests if furnished in collaboration with a physician and if authorized under the scope of his or her State license.
As a Qualified Professional they may under certain circumstances:
QUALIFIED PERSONNEL means staff (auxiliary personnel) who have been educated and trained as therapists and qualify to furnish therapy services only under direct supervision incident to a physician or NPP. See §230.5 of this chapter. Qualified personnel may or may not be licensed as therapists but meet all of the requirements for therapists with the exception of licensure. |
- If licensed by the state, they may appropriately furnish therapy services
- He or she may personally perform diagnostic psychological and neuropsychological tests in collaboration with a physician as required under the NP benefit and to the extent permitted under State law;
Psychological Tests and Neuropsychological Tests Under the diagnostic tests provision, all diagnostic tests are assigned a certain level of supervision. Generally, regulations governing the diagnostic tests provision require that only physicians can provide the assigned level of supervision for diagnostic tests. However, there is a regulatory exception to the supervision requirement for diagnostic psychological and neuropsychological tests in terms of who can provide the supervision. That is, regulations allow a clinical psychologist (CP) or a physician to perform the general supervision assigned to diagnostic psychological and neuropsychological tests. In addition, nonphysician practitioners such as nurse practitioners (NPs), clinical nurse specialists (CNSs) and physician assistants (PAs) who personally perform diagnostic psychological and neuropsychological tests are excluded from having to perform these tests under the general supervision of a physician or a CP. Rather, NPs and CNSs must perform such tests under the requirements of their respective benefit instead of the requirements for diagnostic psychological and neuropsychological tests. Accordingly, NPs and CNSs must perform tests in collaboration (as defined under Medicare law at section 1861(aa)(6) of the Act) with a physician. PAs perform tests under the general supervision of a physician as required for services furnished under the PA benefit. |
Reimbursement
CNSs are paid at 85% of the Medicare Physician Fee Schedule (MFPS) for most services. For assistant-at-surgery servicess, CNSs are paid at 85% of 16% of the amount paid a physician under the MPFS for assistant-at-surgery services.
A CNS may bill directly and receive direct payment for their services.
Assignment
Assignment is required for Medicare.
Clinical Psychologist (PsyD, PhD)
Qualifications
A Clinical Psychologist (CP) must meet the following requirements: <<Medicare boxes info checked>>
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Coverage
CPs are treated the same as physicians as long as state licensing requirements are satisfied. They are classified as “Allied Health Professionals/Nonphysician Practitioners” by Medicare.This was included here, but I’ve not found anything about it. If you do not qualify as a Clinical Psychologist, see the instructions under Independently Practicing Psychologist.
See Resource 209 to review the complete Medicare Benefit Policy Manual.
Diagnostic and therapeutic services that the CP is legally authorized to perform in accordance with State law and/or regulation. Carriers pay all qualified CPs based on the physician fee schedule for the diagnostic and therapeutic services. (Psychological tests by practitioners who do not meet the requirements for a CP may be covered under the provisions for diagnostic tests as described in §80.2. Services and supplies furnished incident to a CP’s services are covered if the requirements that apply to services incident to a physician’s services, as described in §60 are met. These services must be:
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TIP: This “reasonable and necessary” requirement is practiced by all insurance carriers and can vary from state to state.
If the patient assents to the consultation, the CP must attempt to consult with the patient’s physician within a reasonable time after receiving the consent. If the CP’s attempts to consult directly with the physician are not successful, the CP must notify the physician within a reasonable time that he or she is furnishing services to the patient. Additionally, the CP must document, in the patient’s medical record, the date the patient consented or declined consent to consultations, the date of consultation, or, if attempts to consult did not succeed, that date and manner of notification to the physician. The only exception to the consultation requirement for CPs is in cases where the patient’s primary care or attending physician refers the patient to the CP. Also, neither a CP nor a primary care nor attending physician may bill Medicare or the patient for this required consultation
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Psychological Tests and Neuropsychological Tests: Under the diagnostic tests provision, all diagnostic tests are assigned a certain level of supervision. Generally, regulations governing the diagnostic tests provision require that only physicians can provide the assigned level of supervision for diagnostic tests. However, there is a regulatory exception to the supervision requirement for diagnostic psychological and neuropsychological tests in terms of who can provide the supervision. That is, regulations allow a clinical psychologist (CP) or a physician to perform the general supervision assigned to diagnostic psychological and neuropsychological tests. |
Note:
- CPs should typically bill with modifier “AH”. See the Behavioral Health DeskBook Reimbursement Guide for Behavioral Health for information on completing the 1500 Claim Form and more information about modifier usage. It is available in the online store. See https://instacode.com/store/2018-reimbursement-guide-behavorial-health <<Do you want to refer them to the website?>>
- The provider’s NPI must be on the claim form. See Chapter 3.2 — HIPAA Compliance in the Behavioral Health DeskBook for more information on the NPI.<<You asked if this is still relevant?>>
Reimbursement
Services are paid at 100% of the amount a physician is paid under the Medicare Physician Fee Schedule (MPFS).
Assignment
Assignment is required for Medicare.
Clinical Social Worker (CSW)
Qualifications <<Medicare boxes info checked>>
Medicare classifies CSWs as “Allied Health Professionals/Nonphysician Practitioners.” They must meet the following requirements:
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Coverage
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TIP: State laws or other regulatory agencies may differ in your area. Be aware of services that are within your state scope of practice.
Reimbursement
Payment is made only on an assignment basis and are paid at 75% of the amount paid a CP under the Medicare Physician Fee Schedule (MPFS).
Assignment
Assignment is required for Medicare.
Independently Practicing Psychologist (IPP)
Qualifications
Independently Practicing Psychologists (IPP) must meet the following qualifications:
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Psychologists are practicing independently when:
A psychologist practicing in an office located in an institution may be considered an independently- practicing psychologist when both of the following conditions exist:
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Coverage
IPPs can perform diagnostic psychological and neuropsychological testing (CPT codes 96101-96120) in an office setting when a physician orders such testing, and are covered if medically necessary. No therapeutic services are covered by Medicare Part B<<I haven’t found this one>>. Psychologist services provided in a Medicare certified Community Mental Health Center (CMHC) must be billed to the fiscal intermediary.
Assignment
For Medicare, Independent psychologists are not required by law to accept assignment when performing psychological tests. However, regardless of whether the psychologist accepts assignment, he or she must report on the claim form the name and address of the physician who ordered the test.
Note: The provider’s NPI must be on the claim form. See Chapter 3 — Compliance Essentials in the Reimbursement Guide for Behavioral Health for more information on the NPI. <<is it still there?>>
Master’s Level Psychologist<<didn’t find anything more on this one.
Medicare does not have a specific category for this level of psychologist.
Qualifications
A master level psychologist must meet the applicable State Requirements governing the qualifications for non-doctorate psychologists for the state in which they will be practicing. Check with the Division of Occupational and Professional Licensing of the applicable state to ensure that all current qualifications are met.
Coverage
Coverage will vary from one insurance payer to another. It is always wise to verify coverage through the carrier before seeing the client. This is even more crucial to the Masters Level Psychologist because further limitations may apply. For legal purposes, it might be wise to adopt a policy to have a percentage of your cases reviewed by a doctoral level psychologist or psychiatrist on an annual basis. This demonstrates concern for optimal quality of care for clients. Your malpractice insurance carrier may also have guidelines that would be beneficial for you to follow.
Nurse Practitioner (NP)
Qualifications
A Nurse Practitioner (NP) must meet all of the following conditions for Medicare:
The NPs applying for a Medicare billing number for the first time on or after January 1, 2001, must meet the requirements as follows:
The NPs applying for a Medicare billing number for the first time on or after January 1, 2003, must meet the requirements as follows:
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Coverage
The collaborating physician does not need to be present with the NP when the services are furnished or to make an independent evaluation of each patient who is seen by the NP. |
As a Qualified Professional they may under certain circumstances:
QUALIFIED PERSONNEL means staff (auxiliary personnel) who have been educated and trained as therapists and qualify to furnish therapy services only under direct supervision incident to a physician or NPP. See §230.5 of this chapter. Qualified personnel may or may not be licensed as therapists but meet all of the requirements for therapists with the exception of licensure. |
- If licensed by the state, they may appropriately furnish therapy services
- He or she may personally perform diagnostic psychological and neuropsychological tests in collaboration with a physician as required under the NP benefit and to the extent permitted under State law;
Under the diagnostic tests provision, all diagnostic tests are assigned a certain level of supervision. Generally, regulations governing the diagnostic tests provision require that only physicians can provide the assigned level of supervision for diagnostic tests. However, there is a regulatory exception to the supervision requirement for diagnostic psychological and neuropsychological tests in terms of who can provide the supervision. That is, regulations allow a clinical psychologist (CP) or a physician to perform the general supervision assigned to diagnostic psychological and neuropsychological tests. In addition, nonphysician practitioners such as nurse practitioners (NPs), clinical nurse specialists (CNSs) and physician assistants (PAs) who personally perform diagnostic psychological and neuropsychological tests are excluded from having to perform these tests under the general supervision of a physician or a CP. Rather, NPs and CNSs must perform such tests under the requirements of their respective benefit instead of the requirements for diagnostic psychological and neuropsychological tests. Accordingly, NPs and CNSs must perform tests in collaboration (as defined under Medicare law at section 1861(aa)(6) of the Act) with a physician. PAs perform tests under the general supervision of a physician as required for services furnished under the PA benefit. |
- Assistant-at-surgery services furnished by a NP are covered; <<I couldn’t find anything stating this, although above it does say they can perform minor surgery. #1 under C.>>
Reimbursement
NPs are paid at 85 percent of the Medicare Physician Fee Schedule for most services. For assistant-at-surgery services, NPs are paid at 85% of 16% of the amount paid a physician under the Medicare PFS for assist and-at-surgery services.
Direct billing and payment for NP services may be made to the NP.
Assignment
Assignment is required for Medicare
Psychiatric Consultant
Qualifications
A Psychiatric Consultant: must be a medical professional (e.g., a psychiatrist or an NP with psychiatry board-certification) trained in psychiatry and qualified to prescribe the full range of medications.
Role/Responsibilities
The psychiatric consultant advises and makes psychiatric and other medical care recommendations that are communicated to the treating physician, typically through the Behavioral Health Care Manager. The psychiatric consultant does not typically see the beneficiary or prescribe medications, except in rare circumstances, but should facilitate referral for direct psychiatric care when clinically indicated.
According to Medicare, the Psychiatric Consultant’s responsibilities include the following:
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Reimbursement
Reimbursement based on the “incident to” rules and regulations as well as state law, licensure, and scope of practice. The “incident to” regulation was revised to allow general supervision (rather than the more stringent direct supervision standard in place for most “incident to” services) for the CoCM and general BHI codes as well as the non-face-to-face portion of other designated care management services such as complex chronic care management.
Psychiatric Nurse Practitioner (PNP)
Psychiatric Nurse Practitioners must meet all the qualifications for NPs. See Page 7 for coverage and assignment requirements. In addition, they must also:
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Physicians (MD, DO)
Qualifications
A physician must meet the following requirements:
- Holds a medical doctorate degree.
- Meets licensing standards as a physician in the state(s) in which he/she practices.
Coverage
Physician coverage includes Evaluation and Management (E/M) services, pharmacological management, psychiatric interview procedures, individual and group psychotherapy, and other psychiatric therapy provided in any setting (e.g., office, institution, patient’s home). Services can either be personally performed by the physician or by an employee under the physician’s direct supervision as an “incident to” service.
Reimbursement
Payment is based on the Physician Fee Schedule (PFS). Some services are based on the Medicare Physician Fee Schedule (MPFS).
Assignment
Assignment for Medicare is not required, unless the physician has entered into a participating agreement.
Physicians must acquire and use their National Provider Identifier (NPI) to submit claims.
Store: See the Reimbursement Guide for Behavioral Health for more information on Evaluation and Management coding, Medicare participation, and NPIs. It is available in the online store.
<<Do you want this here?>>
Physician Assistant (PA)
Qualifications <<Medicare boxes info checked>>
A Physician Assistant (PA) must meet the following conditions:
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Coverage
Examples of the types of services that PAs may provide include services that traditionally have been reserved to physicians, such as physical examinations, minor surgery, setting casts for simple fractures, interpreting x-rays, and other activities that involve an independent evaluation or treatment of the patient’s condition. See §60.2 for coverage of services performed by PAs incident to the services of physicians |
Note: “Incident To” information is included in the Reimbursement Guide for Behavioral Health available in the online store.<<Do you want the link here>>
Reimbursement
PAs are paid at 85% of the Medicare Physician Fee Schedule (MFPS) for most services. For assistant-at-surgery servicess, PAs are paid at 85% of 16% of the amount paid a physician under the MFPS for assistant-at-surgery services.
Additionally, payments may be made only to the PA’s qualified employer who is eligible to enroll in the Medicare Program under existing provider/supplier categories; or contractor.
Assignment
Assignment is required for Medicare.
Treating (Billing) Practitioner
A Treating Practitioner is one of the following:
- physician and/or non-physician practitioner (PA, NP, CNS, CNM)
- Typically primary care, but may be of another specialty (e.g., cardiology, oncology, psychiatry)
- He or she is legally authorized and qualified to furnish the services in the State where they are performed;
- Performs the initial visit required to establish the relationship with the beneficiary as the the billing practitioner. Assuring the assessment of the beneficiary prior to initiating BHI services
- Directs behavioral health care manager or clinical staff.
- Oversees care of the beneficiary, including: prescribing medications; providing treatments for medical conditions; making referrals for specialty care as needed.
- Remains involved through ongoing oversight, management, collaboration and reassessment.
- May provide General BHI services in its entirety.
Qualifications:
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