Billing and Collections

Ask the Experts: Behavioral Health Billing

February 20, 2019 2:21 pm

We want to offer an intensive outpatient program (IOP) that provides group psychotherapy to patients who require a higher intensity of treatment than our outpatient setting provides. We need a thorough understanding of the billing process for the state of Indiana and the Centers for Medicare & Medicaid Services (CMS), as well as the requirement for social workers. Can licensed social workers perform this therapy or must a licensed clinical social worker do it?

We also have a licensed mental health counselor who would perform these services. We planned to list the attending physician on the bill. Because therapy and charge entry are performed and documented by staff performing the services, not physicians listed on claims, what else should we understand about this type of billing?


Answer: My understanding is that for Part B professional billing, CMS only pays for a clinical social worker, not a regular social worker. We don’t bill a hospital charge in these circumstances, only professional, so I’m not sure what the hospital requirements would be. We are not located in Indiana, so I am not familiar with any specific state requirements for your facility.

This question was answered by: Ruth Landé, senior vice president, patient revenues, Memorial Sloan-Kettering Cancer Center, and a member of HFMA’s Metropolitan New York Chapter.

The information provided through the Forum’s Ask the Expert service does not constitute legal advice, even when the advice is provided by lawyers. You need to obtain your own legal counsel for legal advice and consider the laws and regulations that govern your state. The content and opinions expressed are those of the Forum experts, and not that of their employers or of HFMA. HFMA does not endorse the material or warrant or guarantee its accuracy. The responses are based only on the specific facts or circumstances provided. Forum experts cannot be held liable for outcomes related to any information provided.

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