In a letter to HGSAdministrators, a Medicare fiscal intermediary, dated September 9, PCPA requested clarification and expressed concern about a new interpretation of "incident to" billing for psychotherapy services. On October 22 HGSAdministrators' (HGSA) medical director Andrew Bloschichak's response identifies interpretations the Centers for Medicare and Medicaid Services (CMS) is making in relation to incident to billing.
Dr. Bloschichak states,
"Medicare defines incident to services as those services and supplies furnished as an integral, although incidental, part of the physician's personal professional services in the course of diagnosis or treatment of an injury or illness. In other words, these services do not represent the major portion of the overall service provided to a beneficiary by the physician."
Dr. Bloschichak goes on to cite a letter from CMS:
"What is relatively new is information found in a letter dated February 1, 1999, from the Centers for Medicare and Medicaid Services (CMS). The CMS clarification states, 'We contend that in most if not all cases, a reasonable interpretation of national 'incident to' rules is that psychotherapy services are self-contained and too significant to be considered an incidental service.'"
Currently, HGSA is updating the Medicare Part B Reference Manual, Chapter 13.3 to reflect changes made by CMS to the Medicare Carriers Manual (MCM) § 2050 via Transmittal Number 1764. The updated Medicare Part B Reference Manual is to be published in the December 2002 Medicare Report. PCPA will alert members when the report is released.
PCPA is very concerned about the limitations on incident to billing for psychotherapy services and will be developing follow-up strategies.
For more information, contact Rebecca May Cole at the Association.