PCPA has been working diligently with the Centers for Medicare and Medicaid Services (CMS) and HGSAdministrators (HGSA) to resolve continued concerns related to the provision of psychotherapy services provided “incident to.” In a discussion August 29 with HGSAdministrator’s medical director, Dr. Bloschichak, HGSA has agreed to allow psychotherapy services to be provided “incident to.”
HGSA’s discussions with CMS, as well as PCPA’s, have confirmed that the decision of how to implement the provision of psychotherapy services “incident to” is a local carrier decision, as was documented in a recent program memorandum (change request 2520).
The language included in the June 2003 Medicare Report stated that if the practitioner believes that “Medicare non-coverage of such services would limit access to ‘reasonable and necessary’ care of the Medicare patient(s), [the practitioner] should clearly document their concerns and rationale in the patients’ medical records…” Many providers raised questions regarding “access” – what it is and how to document it.
In response to these questions, HGSA has agreed to publish their decision that psychotherapy services may be provided “incident to” IF the services are provided by individuals in accordance with LMRP V-41D AND all “incident to” requirements are met, removing the statement regarding access.
PCPA also understands that the interpretation regarding LMRP V-41D as stated in the Medicare Report remains in effect, therefore psychotherapy services must be performed by a person licensed by the state. HGSA (for Medicare Part B in Pennsylvania) interprets “licensed by the state” to include both individuals and facilities licensed or authorized by the State of Pennsylvania to perform such services.
HGSA will publish an update with the above information on their web site and will include it in the December 2003 Medicare Report. PCPA wanted to ensure that its members were aware of these developments, however PCPA recommends that members not change their current practices until the formal update is published by HGSA. PCPA will alert members as soon as the information is available.
The elimination of the “access” issue and clearly permitting the provision of psychotherapy by Pennsylvania Department of Public Welfare licensed facilities will assure that the community-based provider can continue to serve the most needy and complex consumers who are frequently not served anywhere else. PCPA sincerely appreciates Dr. Bloschichak’s willingness to work with providers and his continued dedication to ensuring that Medicare recipients receive these much-needed services. For more information, contact Rebecca May Cole at the Association.
Dr. Bloschichak will be attending the September 16 Mental Health Committee meeting. All members are welcome to attend.