Q: As a counselor in private practice, am I mandated to inform the client’s primary care physician of my treatment of the client?
A: The short answer is no, you are not required to inform the primary care physician (PCP) of your treatment of the client. However, you may be required to ask the client if you can inform the PCP; the client is empowered to consent or refuse. We recommend that a release of information for the PCP be embedded in your informed consent document. The client can then accept or decline the disclosure and “sign off” that you asked. We recommend this for a number of reasons.
First, if you are a participating provider in managed health care, most contracts require that you ask the client to inform the PCP of your treatment. It’s called coordination of treatment between you and the PCP. Whether the client consents or declines the disclosure, it needs to be documented in case your records are ever reviewed.
Second, your state’s practice law may require you to ask the client to inform the PCP. In Illinois, where we practice, we are mandated to ask and document in writing the client’s consent or refusal. So you need to check the practice laws in your state.
Third, if the client consents to the disclosure, it is an opportunity to market your practice to the physician. On average, physicians spend seven minutes with the patient per office visit. Physicians are always looking for mental health professionals to whom they can refer their patients. A short letter to the physician containing the diagnosis, treatment approach and your willingness to provide progress updates is most welcome. In addition to the letter, you can include business cards or a brochure. Some counselors follow up with a phone call. Physicians can be an excellent referral source. (For more on “cross-pollination” and expanding a referral base, see last month’s column.)
One final reason — it is the right thing to do. It is important that the PCP be aware of your treatment of the client, as it may affect how the PCP treats the client for other conditions. Counselors need to be seen by the medical community as the mental health provider of choice.
Q: Do we need to get a National Provider Identifier (NPI) number if we file our claims in the mail (not electronically)?
A: We have answered questions about the NPI before, but it is worth repeating since the deadline to use it is fast approaching. You should get the NPI even if you file insurance claims by mail. According to HIPAA rules, if you are a health care provider, the NPI is your standard unique identifier.
Obtaining your NPI is relatively easy to do. Go to https://nppes.cms.hhs.gov/NPPES/Welcome.do and follow the directions.
Several American Counseling Association members have forwarded concerns to the Private Practice in Counseling column. A private company that handles billing for private practice counselors, ProMedical Billing of Chicago, originated the concerns. ProMedical Billing reports difficulty with many of the managed care and insurance companies. The issues they cite include:
1) Insurance companies have stopped using Social Security numbers and have assigned a special number found on
the insurance card. ProMedical reports that mental health insurance and managed care only accept a Social Security number.
We have found this to be true but in only a few companies. The answer: Collect both the insurance card ID number and the Social Security number. Always copy the insurance card and send it in with your HCFA billing. Copy and send the authorization letter (if there is one) with the bill as well. We have always received a notice of such changes from insurance companies. The more documentation you send with your bill, the better.
2) ProMedical reports that insurance and managed care companies have been changing telephone numbers and addresses without notifying the provider.
This was not true for any of the counselors that I have asked. The problem could be that a billing service is not getting this information if it goes directly to the provider. Any mergers or splits of managed care companies have been sent to me promptly with all change of information.
3) There is a report by ProMedical that it takes three calls to authorize benefits.
We find that most managed care and insurance companies have websites where authorization can be verified if the clinician has the information on the client and the insured as cited above. The larger insurance companies have automated touch or voice recognition systems that work well.
4) ProMedical writes that reimbursement rates are poor and that client co-pays are going up. We suggest that you contact the provider relations department, which is usually easy to do, and ask for higher reimbursement. Every time I have done so, I have been given a raise. Also check the ACA website (www.counseling.org) for our list of 55 managed care and insurance companies, including direct hyperlinks to provider relations. The reimbursement rates are listed, so you can avoid the ones that pay poorly.
5) Another issue ProMedical reports is chronic denials.
This has not been a major problem for me, and several other counselors have verified my experience. Regardless, it’s always wise to have the informed consent document notify clients that they are responsible first for any payments, but you will, as a courtesy, bill their insurance or collect from the client and have them file the claim.
As a service to members, ACA also has a “three-part response” template of letters that can be used with denials. The clinician and the client send these letters. They can be found on the members-only section of ACA’s website under “Private Practice Pointers.”
We have worked on many of these problems over the years, and as part of the Private Practice Initiative, we invite you to enlist our help with any of these issues. We are here so you don’t have to reinvent the wheel.
We always encourage counselors to be persistent with managed care. Usually, once you solve a problem, you learn how to keep that problem from repeating itself. Managed care can be your friend, and contrary to some reports, it is getting easier and more user-friendly. I personally don’t believe that any of the major companies are involved in a “conspiracy” to defraud the public or us as providers.
Please send us your feedback on any of these issues via e-mail at firstname.lastname@example.org. If you are having difficulty, we want to know.
If you are going to Detroit to attend the ACA Convention in March, consider attending our preconference Learning Institute on private practice. Also stop by our booth, Walsh and Dasenbrook Consulting, at the Exposition Center and preview our book, The Complete Guide to Private Practice for Licensed Mental Health Professionals. We will also be in the Career Center throughout the conference. Hope to see you there!
Robert J. Walsh and Norman C. Dasenbrook are the co-authors of The Complete Guide to Private Practice for Licensed Mental Health Professionals (www.counseling-privatepractice.com). ACA members can e-mail their questions to email@example.com and access a series of “Private Practice Pointers” on the ACA website at www.counseling.org. Letters to the editor: firstname.lastname@example.org