Medicare Barriers To Billing
From CFHA Member David Bauman:
Specifically, there are a few barriers to billing Medicare:
1. Under current billing for IBH, we utilize psychotherapy codes:
a. 90791 – Psych initial evaluation
b. 90832-90837 – Psychotherapy codes
i. The first and obvious problem of utilizing these codes is that we are not completing traditional psychotherapy; however, we literally do not have other codes to utilize.
ii. The second and less subtle problem is that all of the codes above require a treatment plan, which is a leftover relic of the specialty mental health world. These plans require SIGNIFICANT documentation that is unworkable in our IBH setting, as well as do not actually reflect what we do as BHCs.
1. Now, there is a workaround, if the BHC does not anticipate to see the patient long-term, they can indicate that the patient will not likely need care beyond three visits, thus, no treatment plan is needed
a. This should work for about 80-90% of our patients; however, 10-20% of our patients do see us more long-term, so we will need to complete to receive billing. Bridget and I, while not happy about it, can concede on this point; HOWEVER, it is not something we should concede on as it truly does not reflect what we do.
iii. An additional point of concern is the requirements of the psych initial evaluation. While we meet the MAJORITY of the requirements for the psych eval (i.e., family, social, work, substances, presenting problem, mental status), we DO NOT get a comprehensive history of their psych concerns. Due to not having this, we will not receive reimbursement for the billing code.
1. We can get billing for the 90832-90837 codes, which prompts the question, why worry about the 90791:
a. 90971 – 3.0 RVUs
b. 90832 (30 minute visit) – 1.5 RVUs
c. 90834 (45 minute visit) – 2.0 RVUs
d. 90837 (60 minute visit) – 3.0 RVUS
2. The second major barrier is who can bill for these codes. Medicare says only licensed psychologists and clinical social workers can, leaving out all other master providers. Further, there is not a clear avenue for our trainees to bill, such as the psych interns and fellows.
Neftali Serrano, PsyD
Executive Director, CFHA &
Fan of All Things Integrated Care