Medicare billing can be a perilous, low-return, high-risk endeavor, with rules that sometimes seem less than logical and can readily trap the uninformed.
Take, for example, the question of whether Medicare will reimburse post-doctoral clinical psychologists for psychotherapy services. Psychotherapy is a reimbursed service when it is provided by clinical psychologists. These “Psy. D’s,” as they are known, are required by many states to practice for a year under the supervision of a licensed clinical psychologist (also the holder of a Psy. D. degree) before they are fully licensed themselves. Nonetheless, they may provide psychotherapy services to patents in that year of supervision.
Medicare takes the position that because they are not fully licensed it will not directly reimburse for the services they provide. Fair enough, you might say, since they are not actually licensed by the state in which they practice. The illogic, however, can be seen when one considers that licensed clinical social workers, whose degrees requires less education and clinical experience than Psy. D’s, are allowed to bill Medicare for their services.
What about billing for the services of the Psy. D’s under the “incident to” billing provision, which allows providers to bill for necessary auxiliary staff services provided under their supervision? At least one Medicare regional contractor (the contractors administer the Medicare program and issue interpretations of Medicare rules) has said they can’t. Does this make sense? Recipients are therefore denied important mental health services by professionals approved by their state licensing authorities to provide those services.
An important step in training clinical psychologists, supervision, may be difficult to obtain as those services will not be reimbursed by Medicare and, since private insurers often track Medicare rules, perhaps not by private insurance companies, either. Attempts to bill for those services under the “incident” to provision can even subject providers to claims of fraud and liability under the False Claims Act, that can be expensive and time-consuming to resolve.
Is it any surprise that more and more providers are opting out of Medicare? And where does that leave us Boomers in a few years?
