In an April 10 meeting with HGSAdministrators (a Medicare Part B Carrier), PCPA learned that HGSA will be publishing an "update" to the segment published in the December 2002 Medicare Report regarding the provision of psychotherapy as "incident to."
Discussions with HGSA indicate that as an interim measure, this update will allow for the provision and billing of psychotherapy services "incident to" psychiatrists or clinical psychologists. PCPA had argued that the December interpretation would have created significant problems with access to care. While it is likely that assessing and documenting access problems will be necessary, the provision of psychotherapy as "incident to" will be permitted. The individual furnishing these incidental services must either be licensed OR provide the services as part of a licensed outpatient clinic (such as but not limited to psychiatric outpatient clinics licensed under DPW's 5200 regulations). All guidelines for "incident to" services must be met in order to be billed.
This update will be effective retroactively to December 1, 2002 and will remain in effect until a resolution is reached with CMS regarding the ability of psychotherapy to be provided "incident to."
HGSA also reiterated that if a psychotherapy service is provided that does not meet all "incident to" guidelines, this should be billed with a "GY" modifier in order to receive a denial.
PCPA does not recommend taking any action until the final "update" is published. The update is expected soon. More information will be shared as soon as it is available. Contact Rebecca May Cole with any questions.