PCPA along with the PA Psychological Association met with HGSAdministrators (HGSA), a Medicare Part B carrier on March 24. The primary topic of the meeting was to discuss the interpretation of "incident to" requirements for psychotherapy services. PCPA was encouraged by this initial meeting where HGSA exhibited a genuine concern regarding access to care for Medicare recipients.
HGSA decided that within two weeks it would provide preliminary clarification that would allow psychotherapy services provided "incident to" to continue. In order to continue the provision of these services, the provider will likely need to document where access to care is or is perceived to be an issue. It was stressed that documentation will be key to the provision of these services should an audit occur.
PCPA is working with HGSA to draft the aforementioned clarification and will alert providers when it has been completed.
Following this initial clarification, HGSA has committed to work on developing a solution that would meet all Medicare requirements. The potential options for next steps are to work with the central office of CMS to rescind or clarify the "incident to" interpretation prohibiting psychotherapy services from being provided "incident to," or to develop a local medical review policy for Pennsylvania allowing for the provision of these services.
The Association will request more information from selected members in order to build a case for a permanent and favorable resolution to this issue. If a member receives such a request, a timely turnaround will be crucial. For more information, contact Rebecca May Cole at the Association.