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Pandemic Update: Emergency and Temporary Regulations

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, March 31, 2020

I am posting the most up to date information I have regularly on the many, ongoing changes which are affecting our practice. These changes are quickly emerging from the insurance industry, the Center for Medicare and Medicaid Services, the State of Ohio, and our federal government.  My updates are posted here on this listserv, are being blast emailed to all Ohio psychologists, and may be found on the OPA website here:

https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

I am making every effort to keep this as up to date as possible, and it may be helpful to take a few minutes to read through the five most recent posts (starting from 3/16/20).  Guidance on many of the issues discussed on this thread may be found there.

APA is also presently offering a resource page on similar issues: https://www.apaservices.org/practice/clinic/

A very brief summary: many insurance companies have issued emergency, temporary regulations for the provision of teletherapy.  Many former guidelines which were stricter have been relaxed.  Teletherapy sessions are billed using the same CPT Codes as face to face therapy, using the place of service code "02" (teletherapy) and a modifier, either "GT" or "95."  Most companies have temporarily relaxed the restriction which requires teletherapy connection be both video and audio.  As of the time of this email, Medicare has not, and continues to require our connections to be both video and audio.  Medicaid, which is administered through the State of Ohio, has created new rules which do allow for audio connection (phone) only.

As I am sure you are aware, we are living in very tumultuous times.  As part of my role with OPA, I am spending hours and days connecting with multiple information sources tracking and organizing the most recent, useful information for you.  If you obtain newer, recently issued information, I urge to carefully vet it before disseminating.  To do otherwise could add to the current confusion (which is considerable).  However, the best strategy would be to email me the newer information directly, and I will help ascertain its accuracy and usefulness.


Jim Broyles, PhD
Director of Professional Affairs, Ohio Psychological Association

 

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Pandemic Update: HIPAA Compliant Technology for Communication

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, March 24, 2020

This is an update of my messages to you regarding the ongoing changes occurring on the insurance/healthcare regulation world in response to the COVID-19 crisis.  This is a continuation of my previous updates which can be found here: https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

A more general crisis resource page can be found here: https://ohpsych.org/page/PandemicResources

The Ohio Governor has issued a stay at home for Ohio residents.  Individuals are still permitted to leave their homes to visit health care professionals.  Our work as mental health and substance use providers is considered an essential activity and is permitted to continue to operate.

I am seeing many questions and requests regarding HIPAA compliant technology for communication with clients who are homebound.  In a previous update, I reported the Department of Health and Human Services website states right now it “will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency.”   The best advice we are receiving from APA in on interpreting this statement is 1) make a good faith effort to secure a HIPAA compliant means of communication and 2) if none is available connect with your client via other available means.  I believe at this point the best direction we are being given is to make the well being of our clients be our highest priority.

While some definitions of teletherapy include audio only means of interacting with clients, many insurance company regulations have typically required the connection to be both visual and audio.  Due to the circumstance of so many individuals having more sophisticated electronic communications unavailable to them and being reachable only by phone, many insurance companies have been adapting their regulations, allowing audio only (cell/telephone) connections to conduct therapy.  In past updates I have documented companies who have made these revisions in their regulations and am including more here.

MEDICAID

The Ohio Department of Medicaid recently passed temporary, emergency rules. (It will also be made available on OPA’s resource webpage).  The rules make allowance for the audio only connection as well give specific definitions for the patient site and practitioner site.

CIGNA

Cigna has also issued a recent revision of their policy:

As a general requirement, Cigna-participating outpatient providers must complete an attestation to deliver telehealth sessions. During this interim period, however, telehealth attestations are not required. Please note that regardless of your attestation status, it is expected that you use a secure platform to deliver services and follow all Health Insurance Portability and Accountability Act (HIPAA) requirements.

While telephonic sessions are not typically covered in accordance with our Medical Necessity Criteria, we are making an exception during this interim period. You may provide telephonic sessions to patients who do not have access to technology to participate in telehealth sessions, as appropriate.

MEDICARE

As of this posting I have received no update on changes to Medicare beyond those in my 3.20.20 update.  Many of you have expressed concern regarding Medicare recipients who reachable only by phone.  I have heard that many of you have reached to your current members of Congress to advocate for a change with this issue.  My hope is that this proves effective.

EMERGENCY LICENSURE

 Many of asked about reaching client who are quarantined in other states.  Clearly, only psychologists who are licensed to practice in other states are permitted to provide psychological services there.  At this point, many states have created emergency orders and procedures for allowing temporary licensure in those states.  ASPPB is doing a good job of tracking those states who have made such provisions, and that information may be obtained here: https://www.asppb.net/page/covid19

The Ohio Board of Psychology also has created similar emergency rules and procedures for psychologists licensed in other states.  They may be found here:
https://psychology.ohio.gov/Applicants/Nonresident-Temporary-Permission-to-Practice

I will continue these updates as information becomes available to me.

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Pandemic Update: HIPAA Compliant Technology for Communication

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, March 24, 2020

This is an update of my messages to you regarding the ongoing changes occurring on the insurance/healthcare regulation world in response to the COVID-19 crisis.  This is a continuation of my previous updates which can be found here: https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

A more general crisis resource page can be found here: https://ohpsych.org/page/PandemicResources

The Ohio Governor has issued a stay at home for Ohio residents.  Individuals are still permitted to leave their homes to visit health care professionals.  Our work as mental health and substance use providers is considered an essential activity and is permitted to continue to operate.

I am seeing many questions and requests regarding HIPAA compliant technology for communication with clients who are homebound.  In a previous update, I reported the Department of Health and Human Services website states right now it “will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency.”   The best advice we are receiving from APA in on interpreting this statement is 1) make a good faith effort to secure a HIPAA compliant means of communication and 2) if none is available connect with your client via other available means.  I believe at this point the best direction we are being given is to make the well being of our clients be our highest priority.

While some definitions of teletherapy include audio only means of interacting with clients, many insurance company regulations have typically required the connection to be both visual and audio.  Due to the circumstance of so many individuals having more sophisticated electronic communications unavailable to them and being reachable only by phone, many insurance companies have been adapting their regulations, allowing audio only (cell/telephone) connections to conduct therapy.  In past updates I have documented companies who have made these revisions in their regulations and am including more here.

MEDICAID

The Ohio Department of Medicaid recently passed temporary, emergency rules. (It will also be made available on OPA’s resource webpage).  The rules make allowance for the audio only connection as well give specific definitions for the patient site and practitioner site.

CIGNA

Cigna has also issued a recent revision of their policy:

As a general requirement, Cigna-participating outpatient providers must complete an attestation to deliver telehealth sessions. During this interim period, however, telehealth attestations are not required. Please note that regardless of your attestation status, it is expected that you use a secure platform to deliver services and follow all Health Insurance Portability and Accountability Act (HIPAA) requirements.

While telephonic sessions are not typically covered in accordance with our Medical Necessity Criteria, we are making an exception during this interim period. You may provide telephonic sessions to patients who do not have access to technology to participate in telehealth sessions, as appropriate.

MEDICARE

As of this posting I have received no update on changes to Medicare beyond those in my 3.20.20 update.  Many of you have expressed concern regarding Medicare recipients who reachable only by phone.  I have heard that many of you have reached to your current members of Congress to advocate for a change with this issue.  My hope is that this proves effective.

EMERGENCY LICENSURE

 Many of asked about reaching client who are quarantined in other states.  Clearly, only psychologists who are licensed to practice in other states are permitted to provide psychological services there.  At this point, many states have created emergency orders and procedures for allowing temporary licensure in those states.  ASPPB is doing a good job of tracking those states who have made such provisions, and that information may be obtained here: https://www.asppb.net/page/covid19

The Ohio Board of Psychology also has created similar emergency rules and procedures for psychologists licensed in other states.  They may be found here:
https://psychology.ohio.gov/Applicants/Nonresident-Temporary-Permission-to-Practice

I will continue these updates as information becomes available to me.

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Pandemic Update: Telephone (Audio Only) Psychotherapy Sessions

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Friday, March 20, 2020

I want to give an update on the latest information I have as a continuation of my updates from 3/15 and 3/17. OPA now has a Pandemic resource page on our website: https://ohpsych.org/page/PandemicResources

All past my past updates are located here:
https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

One of the most significant questions on everyone’s mind is the use if telephone (audio only) to conduct psychotherapy sessions.  As I mentioned previously, our regulations come from a variety of sources.  Some definitions of teletherapy may include audio only, but typically regulations from insurance entities do not.  In the last few days I have seen the insurance companies working quickly to revise many of their policies regarding teletherapy, and some are including telephone sessions in their definitions, at least temporarily.  My hope is that more insurance entities will follow suit in the coming days.

As I reported previously, Medicare has lifted some restrictions on teletherapy, allowing more recipients to receive services via teletherapy (see my last update).  However, they continue to require the connection used to be audio as well as video.  APA and NASW very recently sent a letter to CMS imploring them to relax this restriction to permit audio only.  Also, many are aware of the Medicare requirements for supervised services. CMS stipulates that for services billed to Medicare which are delivered using a supervisee, the supervisor must be physically present in the office suite for help if needed.  This requirement has not changed.  

I have been able to make contact directly with a Medical Mutual representative who was able to supply me with their policy.  They do cover teletherapy, and there are no other specific requirements other than the billing procedures (below).  Audio only sessions are not considered a part of their teletherapy definition.  

Anthem Blue Cross/Blue Shield recently issued this update, which permits audio only sessions.  From their FAQ document:
Anthem covers telehealth (i.e., video + audio) services for providers who have access to those platforms/capabilities today.

Effective March 17, 2020, Anthem’s affiliated health plans will waive member cost share for telehealth (video + audio) visits, including visits for mental health, for our fully insured employer plans, Individual plans, Medicare plans and Medicaid plans where permissible for 90 days. Cost sharing will be waived for members using Anthem’s telemedicine service, LiveHealth Online, as well as care received from other providers delivering virtual care through internet video + audio services. Self-insured plan sponsors may opt out of this program.
 
Will Anthem cover telephone only services in addition to telehealth via video + audio?
Anthem does not cover these services today (with limited state exceptions) but we are providing this coverage for 90 days effective March 19, 2020, to reflect the concerns we have heard from providers about the need to support continuity of care for Plan members during extended periods of social distancing. Anthem will cover telephone-only medical and behavioral health services from in-network providers and out-of-network providers when required by state law. Anthem will waive associated cost shares for in-network providers only except where a broader waiver is required by law.

Aetna continues to be difficult for me to contact.  Fortunately, the Directors of Professional Affairs throughout the country maintain a good network of interconnection.  My counterpart in Utah was able to forward information she received from her contact with the company.  I received the following:

Aetna – Aetna has waived the requirement for patients to use their preferred vendor, TelADoc. All contracted providers are eligible to provide virtual visits for Commercial Plan members for the next 90 days. Self-insured plans do have the option to opt-out of this program so we will still want to verify policies prior to rendering service. 

At one point, there was a question about their teletherapy provider requirement, which was restricted to one platform, TelaDoc.  It would appear at this point that restriction has been lifted, and all providers are being made eligible to provide teletherapy services.

As mentioned in my last updates, when billing teletherapy services, the procedure remains the same for all entities: the CPT Code continues to be the same as that used for face to face therapy.  However, the claim must report place of service as “02” and include the modifier “95” or “GT.” 

APA is offering some great teletherapy resources:

OPA resource page:
https://ohpsych.org/general/custom.asp?page=PandemicResources

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Pandemic Update: Telepsychology, HIPAA and Medicare

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Wednesday, March 18, 2020

This is my effort to keep you updated with my work on your behalf, as promised during my last message on 3/15/20.  Most of my day today has been spent gathering information from members, my insurance contacts, the Ohio Board of Psychology, and APA. As I am sure most of you are aware, our circumstance is changing very quickly, and the messages I receive are often conflicting and confusing. My strategy at this point is to tell you what I know for sure, what I think could be coming, and what we do not know. My thought is if I continue to this process frequently, the confusion may eventually clear.

I ask you to keep in mind the rules and restrictions which govern the delivery of our services come from multiple sources, including state law, federal law, and insurance company policy and regulation. Each of these can interact with one another in a complex way which adds to the confusion. This means that, as the circumstances evolve, few are completely clear on the full implications for our work.

At this point, as far as I know, all rules governing psychologists as telepsychology providers remain in place. We have received word (as many of you have heard) that Governor DeWine has issued an emergency order to “reduce restrictions on telehealth.” This could have implications for our board rules or might also have implications for insurance company restrictions. Dr. Ron Ross of the Ohio Board of Psychology and I have been in communication regarding this and unfortunately have been able to obtain very little information on the details of this order. (I’m sure they are very busy right now).

It would also appear that that federal entities have relaxed HIPAA restrictions during the crisis. The Health and Human Services website states it “will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency.”  Presently the APA Department of Legal and Regulatory Affairs are at work on defining the implications of this for psychologists, and we hope to have an update tomorrow. This may mean that HIPAA compliant platforms are not necessary for connecting with your client during the crisis. 

In my last message I mentioned that Medicare enforces strict regulations on the delivery of teletherapy services, and that an emergency law was passed by Congress to allow the Secretary of Health and Human Services to relax these standards, and the change was awaiting his approval. That approval has been granted. According to the CMS website: “Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.” 

https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

Stay tuned for more guidance from APA on this also. 

Optum’s (UHC/UBH) website is now stating: Telephonic Care: For members or providers who do not have access to HIPAA-approved technology required to conduct a video-enabled virtual session, we will now accept telephonic sessions.”  My hope is that other insurance companies may follow this lead, but no other has created a similar policy as far as I know. 

Cigna has confirmed that teletherapy is permitted for many of their plans, and an attestation is required. Click here to view a flier that I received from their medical director. Many members have verified that Medical Mutual is covering teletherapy session, but my efforts to contact them have received no response. (Again, I’m sure they are very busy).  As I receive more details from these companies, I will share with you. 

If any of you have more information to add, please email me directly and I will do my best to verify the information and keep you updated.

Jim Broyles, PhD
Director of Professional Affairs
Ohio Psychological Association
395 E. Broad St. Suite 310 | Columbus, Ohio  43215 | 614-266-1301

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Pandemic Update: Telepsychology

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Monday, March 16, 2020

In response to the current, evolving pandemic situation, many of you have been asking about the use of telepsychology and related insurance regulations. Dr. Jim Broyles, OPA Director of Professional Affairs, has spent considerable time gathering information for you and will undoubtedly continue to do so over the course of the next several days and weeks. His intention is to give you as much information as is available at this time. He asks that you understand that additional and updated information is highly likely given the fact that circumstances are evolving very quickly. OPA and Dr. Broyles will work to provide updates on a regular basis.

TELEPSYCHOLOGY TRAINING

Please consider that offering psychotherapy via an electronic platform (telepsychology) is considered a specialty area by our Ohio Board of Psychology and should be undertaken by those psychologists who have completed the training requirements and are legally and ethically competent to deliver these services. We are aware of a very recent news story stating, “. . . Ohio Governor Mike DeWine announced he has filed emergency rules for complete mental health telehealth coverage.” We do not know the implication of this for these Board of Psychology requirements nor for insurance entities. Information on this will be one of the updates provided as it becomes available. For those interested in getting up to speed on telepsychology training, a number of training resources are available online. While it is very difficult here to be definitive regarding which sources of training suffice to make one competent in this area, our OPA telepsychology experts offer guidelines in what good training should cover. Click on the following links to access summary documents from APA and OPA.

Dr. Ron Ross of the Ohio Board of Psychology recently issued a statement regarding contact with clients which falls outside the parameters of treatment defined as telepsychology:

“[Ohio rules give] . . . license holders authority to use their judgment about when a client requires extra support between appointments without having to document all the processes in the telepsychology rules. Therefore, the rule authorizes inter-session telecommunications to manage crises even by license holders who do not necessarily “practice” telepsychology. With the evolving landscape of illness, social distancing, quarantines, and the risk of increased anxiety and other psychological symptoms, it is reasonable for license holders to interpret “ensuring client welfare” broadly, given our dramatic shift in context. Specifically, license holders may judge, on a case-by-case basis, that client welfare and continuity of care requires temporary, judicious use of telephone sessions when the client and license holder are prohibited from meeting in-person because of efforts to contain COVID-19. This temporary leeway is rooted in a specific context and is not to be used as a basis to undertake routine use of telecommunications by exemption from the telepsychology rules for reasons unrelated to the COVID-19 crisis. License holders who 2 wish to routinely deliver services via telecommunications must establish and maintain telepsychology competence and practice in accord with the telepsychology rules.”

MEDICARE AND MEDICAID

Until recently Medicare has maintained strict rules regarding the use of telepsychotherapy, including limiting service recipients to those individuals located in specific geographic regions as well as requiring that the client be present at their primary care physician’s office to receive the service. Last week, an emergency temporary bill was passed by Congress to lift those restrictions. This bill authorizes the present Secretary of Health and Human Services to lift those restrictions. As of this writing that has not occurred and there may be specific requirement accompanying that change, and OPA will update you as that information becomes available. Also, be aware that Medicare Advantage plans are authorized to provide services that the federal Medicare program does not. Clients who participate in these plans may well be eligible to receive tele-services. At this time, we have no information specific to these plans, but we suspect the allowances are congruent with the company’s non-Medicare plans.

Current rules governing Medicaid allow for “telehealth.” The rules may be found here: http://codes.ohio.gov/oac/5160-1-18v1. Psychotherapy is identified as a covered service within the parameters identified by the rules. Our contact with the Ohio Department of Medicaid has indicated that these rules are currently under revision and that a more definitive guide (which may include a lifting of certain restrictions) will be forthcoming soon. We will pass this along as soon as it is received. Similar to Medicare, Medicaid Managed Care Organizations have more latitude in terms of what they offer than the state program, and our contact with CareSource has assured us that telepsychology services are covered. Unfortunately, we have not received informaton from other Medicaid companies.

PRIVATE INSURANCE

Optum (UHC/UBH) has assured OPA that they encourage telehealth services and even offer an electronic platform for “virtual visits.” Participants in the delivery of these services are asked to sign an attestation. Their policy and directions for complying with requirements may be found here:

https://www.providerexpress.com/content/ope-provexpr/us/en/Important-upates.html

Anthem Blue Cross Blue Shield has stated that telehealth services are allowed with guidelines:

The Provider can utilize their own interface for Telehealth service and are not required to use Live Health Online or any other specific vendor

  • The tool used to provide Telehealth must include both audio and visual connection capabilities, i.e. the physician and patient must both see and hear each other during the interaction.
  • The Provider can bill using their current TINs/NPIs.
  • There is a broad list of services available to be billed via Telehealth, and we follow the Medicare Learning Network (MLN) publication to determine those services.
  • E-consults between physicians are NOT covered via the Telehealth policy. Only member to physician interactions are included.
  • Claims must be billed using POS “02” for Telehealth and using modifiers “GQ”, “GT” or “95”. This requirement is consistent with Medicare. Not using this POS or modifiers will result in post-pay audits and recoveries.
  • Telehealth services will reimburse at rates equivalent to our facility based professional rates (not office based).

The above mentioned MLN publication includes our most used psychotherapy codes.

We are hearing from some very good sources that Medical Mutual allows for telepsychotherapy as a service. We have yet to verify that or know about any specific parameters required by them. Dr. Broyles has a call in to them and will share information as it becomes available. Also, remember when billing telepsychology for any insurance entity, the basic billing procedure is the same: as stated above, the claim must report place of service as “02” and include the modifier “95” or “GT.” These trigger the insurance entity’s system to recognize your claim as being for the telepsychology service. Otherwise, the CPT Code and other information is the same as for face to face services.

Preesently, OPA has no other information about other companies, but we hope to get this soon. If any of you receive information to add to what has been presented here, please reach out to Dr. Jim Broyles directly, especially with a contact person if possible. Keep in mind Dr. Broyles' work with this issue and the information  gathered would not be possible without our staff at APA; an entire network of DPA’s across the country; Dr. Leslie McClure, Christine Taylor, and our other OPA Insurance Committee members, as well as, Dr. Mark Babula, one of OPA’s Telepsychology leads.

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New Parity Bill Introduced - SB 254 / HB 443

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Wednesday, February 19, 2020

I have had many discussions over time with OPA members who express frustrations with insurance companies and their negative impact on psychologists’ ability to practice effectively. I often hear about issues such as plans which require excessive deductibles and copays, limitations on allowed diagnoses or number of sessions, or reimbursement rates which make operating a mental health practice financially inviable. At the same time, our association can be quite restricted, for variety reasons, in the avenues available to it for effectively pushing back against these barriers and challenges. However, one potential immediate vehicle for change currently on our horizon is the parity bill recently introduced in our legislature. Parity laws are those which require insurance companies to offer benefits for behavioral health treatment comparable to physical health care. This means that a number of factors, including the quantity and kinds of treatment allowed, required out of pocket expenses, and panel participation adequacy (which is directly associated with reimbursement rates) must be comparable to similar factors on the physical health side of the plans. 

Presently, both federal and state parity laws exist which affect insurance companies providing health plans here in Ohio. Unfortunately, weaknesses exist in the current laws which allow the above difficulties to continue. The current bill (SB 254/HB 443) will establish new standards for those companies who provide health insurance here in Ohio, as well as effective means of measuring compliance with these standards. This bill, should it become law, will be one more step toward a more balanced health care system which recognizes and supports the delivery adequate behavioral healthcare services in our state. 

I often remind our members that the passage of such bills which do not favor our insurance companies can often be an uphill battle. A primary reason for this is the resources available to insurance companies to lobby against such legislation which have no counterpart in our professional association. That means that a bill such as this is far more dependent on grassroot support from individuals. My purpose in writing here is to help OPA members understand the potential impact of this legislation on their professional lives. The next step, however, will be up to individual professionals and Ohio citizens. At the right time, you will receive an Action Alert email from OPA with sample letters asking you to contact your legislature to support this piece of legislation. Please be on the lookout and willing to make our voice heard! 

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New Health Behavior Assessment and Intervention CPT Codes Coming

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Thursday, December 19, 2019

For those psychologists who provide Health Behavior Assessment and Intervention (HBAI) services, a new set of CPT Codes will be implemented beginning January 1, 2020.  All HBAI services billed on or after that day should use these new codes. Information and documents regarding the new codes has been made available from APA: https://www.apaservices.org/practice/reimbursement/health-codes/health-behavior.  

In addition, click here for a billing and coding guide developed by APA which gives more detailed information about the codes and how they are to be used when billing for HBAI services.  This helpful document gives essential information, including:

  • Description of services and factors which determine when they are considered medically necessary
  • A list and description of the new codes
  • Documentation and reporting guidelines
  • Guidelines for correct use of the codes

Please feel free to contact me for questions or support. Unfortunately, many insurance companies may experience confusion during the initial implementation period about code definition or their correct usage. I encourage you to bring these issues to my attention, also. (jbroyles@ohpsych.org).  

A presentation on this topic will be offered at the 2020 OPA Convention on Friday, April 24, 2020 at 10:15 am. Detailed information about the convention will be available in early 2020... visit https://ohpsych.org/page/convention for the most up-to-date.

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New member Benefit: OPA Insurance Audit Toolkit

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, February 19, 2019

Among the many insurance issues OPA members contact me about, the most distressing for most is experiencing an audit or threat of audit from an insurance company. The vast majority of OPA members bill many of their services to insurance companies. However, documentation and record keeping requirements are not always clearly understood by these same clinicians. In their effort to clear the confusion, many psychologists attempt to learn about what is required of them. Unfortunately, this effort can lead to more confusion as they learn there are multiple sources for these requirements.  Requirements and guidelines emerge from federal law, state law, ethical principles of the American Psychological Association, and other sources. These requirements consider the array of services which can be offered by a psychologist and attempt to identify what information should be kept as part of the record, at what level of detail, for how long, as well as many other standards.

In an effort to shed light on this very confusing issue, OPA’s Insurance Committee has created an Audit Toolkit. This tool kit is free to all members (and may be purchased by non-members) and offers a checklist of clinical record details considered critical by most insurance companies. While individual companies may vary somewhat in terms of their requirements, most follow an industry standard which is set by the Centers for Medicare and Medicaid Services. These standards require that testing and psychotherapy services must be medically necessary if they are to be reimbursed by health insurance companies, and that the record of these services must include certain details to document this medical necessity. The record itself must establish a consistent connection between symptoms present, diagnosis, treatment plan goals, and tasks of psychotherapy sessions. (This connection is sometimes referred to as the “Golden Thread.”)  During audits, insurance companies often look for documentation of these details to establish medical necessity, and have been known to reclaim funds paid for services when this necessity is not established to their satisfaction. 

OPA’s Insurance Committee has taken all these factors into consideration in creating their toolkit checklist. It is quite likely that its use when creating clinical records will help any clinician face an insurance company audit with confidence. OPA members may click here to access their FREE toolkit. My hope is that members will find this member benefit useful. As always, please feel free to reach out to me with question and suggestions.

Jim Broyles, PhD
Director of Professional Affairs, Ohio Psychological Association
jbroyles@ohpsych.org

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CPT Codes for Testing Services Change in January 2019

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, December 4, 2018

No doubt by this time many OPA members are aware that the CPT Codes commonly used to bill testing services are changing. This means that those testing codes familiar to us can only be used to bill testing services to insurance companies until December 31, 2018. On January 1, 2019, the new codes will be required. The newer codes are more complex and take into account a number of factors the old codes do not capture, and are able to more accurately describe the work required when multiple hours of technical and professional services are performed. In many ways the new coding structure will more greatly benefit psychologists for services provided in this area. However, due to their complex nature, there is not a simple crosswalk from the old codes to the new. It is therefore imperative that psychologist get training on the use of the new codes to ensure their correct use as well as to be fully reimbursed for all their work. 

APA has provided resources to educate psychologists on the use of the new codes. Presently, the most accessible is a webinar available on YouTube entitled “Getting Reimbursed: Testing Code Changes are Here” by Antonio Puente, PhD and Neil H. Pliskin, PhD. 

View webinar here: https://www.youtube.com/watch?v=Q1kAZEgih2w

This 1 hour webinar gives a good overview of the use of the new codes and should help any psychologist feel more prepared for the coming change.

OPA members should also stay aware of the timing of their billing. While your APA and OPA leadership has been working to ensure that insurance companies are aware of and ready for the coming changes, unfortunately there is no guarantee that all individual companies will be fully prepared. Typically, big changes such as this require them to make significant systems changes. History has demonstrated that sometimes these changes are executed smoothly but sometimes not. Billers of psychological testing services will maximize their chances of avoiding confusion and unnecessary reimbursement delays by paying very care attention to the timing of their billing. All psychological testing services rendered in 2018 should be billed by December 31, 2018, so that all billing sent in 2019 will be for testing service provided January 1, 2019 and beyond. This approach may circumvent some issues with readiness the respective insurance companies may experience.

Please feel free to email me with questions or for additional resources.

Tags:  cpt codes 

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