HGSAdministrators has published their final update on psychotherapy services and “incident to” billing on their web site. The update, included on page 17 of the December 2003 Medicare Report states “Psychotherapy services provided ‘incident to’ are eligible for Medicare coverage, but must be in keeping with the … ‘incident to’ guidelines as well as all national regulations, Local Medical Review Policies (e.g. LMRP V-41 on Psychiatric Therapeutic Procedures), and CMS directives, to include the CMS Transmittal, AB-03-037, Change Request 2520. There is no need to document that the psychotherapy service is being provided ‘incident to’ due to access to care issues or concerns.” (emphasis added). PCPA appreciates the efforts of Dr. Bloschichak and HGSAdministrators to find a beneficial resolution ensuring that Medicare recipients have necessary access to psychotherapy services.
Dr. Bloschichak, medical director of HGSAdministrators, attended the November 18 Mental Health Committee meeting and provided clarification on the following items relating to “incident to” services.Practitioners for whom services may be provided “incident to”
Dr. Bloschichak indicated that practitioners who meet the qualification requirements of Medicare may have services provided “incident to” their services. Thus, psychiatrists, clinical psychologists, clinical social workers and others may have psychotherapy services provided “incident to” as long as the service is within the practitioner’s scope of practice. (See the March 28 article Medicare Payments for Part B Mental Health Services in the Medicare Newsroom of the HGSA web site for a complete list of such practitioners.)Types of Supervision
Medicare divides supervision into three types: personal, direct, and general. Personal supervision requires that the supervising practitioner be in the same room as the patient at the time the service is being provided. Direct supervision does not require the supervising practitioner to be present in the room with the patient, however he or she must be “in the suite.” “In the suite was defined as allowing the supervising practitioner to traverse from their current location to the location of the patient without entering 'the public domain.'” Therefore, if a clinic is located on the third floor of an office building, the practitioner may not be on any floor other than the third floor and may not be on a public elevator or stairwell. Adversely, if the clinic is located in the entire building, the practitioner may be anywhere in the building. Finally, general supervision may occur when the practitioner is not on site where the service is being rendered.Use of Appropriate Practitioner Billing Number
When a service is being rendered “incident to” the services of an approved practitioner, providers must use the billing number of the practitioner who is in the suite during the time of service. This practitioner may or may not be the practitioner who initiated the care of the recipient.Contact Rebecca May Cole at PCPA with any questions.