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Billing for lcsw

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PMRNC:
The reason I don't get involved in setting up entities or even answering questions is because there are many variables including IRS guidelines, Stark guidelines, and general legal issues. Especially in the medical industry where the wrong setup could land a practice in hot water. Oh and also because my attorney says it best to stay out of that part. (my favorite reason)  I also do NOT involve myself with the practice marketing of patients for  similar reasons.

Healthy:
Richard thank you very much for all your help, this forum needs more people like you. God bless you.
PMRNC, I don't know why you assumed that I am asking you a legal aspect of entity, all I asked was how to bill?
Also I did not force you to answer my question, it was a humble request to all members of forum that "please answer me".it does not say that urgent answer is requested.

PMRNC:

--- Quote ---PMRNC, I don't know why you assumed that I am asking you a legal aspect of entity, all I asked was how to bill?

--- End quote ---

I did NOT assume you asked any such thing, I know you did NOT, it was brought up as a response to your question on how to bill. I agree you did not ask about groups or legal entities. Richard did however go above and beyond in his answer I was responding to that as I did not want to confuse you further with What if scenario's since you did only ask about the billing. With credentialing and mental health there most certainly is a difference in how it's done to accommodate the MANY TPA's that major carriers use.


--- Quote ---Also I did not force you to answer my question, it was a humble request to all members of forum that "please answer me".it does not say that urgent answer is requested.
--- End quote ---

I apologize as it did look like an air of impatience, so I just wanted to clarify the positions here. 

Healthy:
PMRNC, thank you. I love you all.

RichardP:
Healthy, this post is for you - but others may benefit from it.  And thank you for your kind words.

I don't know mental health billing.  But I know about regular medical billing.  My thought on reading your initial post was, if mental health billing is anything like regular medical billing, I see some confusing statements in your initial post.

You mention provider, lcsw, and Group all together in your initial post.  You state that provider has hired lcsw.  So I think we are talking about the requirements of a solo practitioner.  But the inclusion of the word Group makes me think that you are actually talking about a Group.  It will either be a collection of medical workers who have no rules imposed on them by CMS, and you just called them a group.  Or it will be a collection of workers who meet the CMS definition of a Group.  If it truely is a CMS-defined Group, then certain requirements are imposed by CMS that the Group must meet in order to be considered a Group by CMS.  One of those requirements is that the Group must do the hiring and paying, not the individual provider who is a member of the Group.  So the fact that you said the provider hired the lcsw, but they were part of a Group, told me that I needed some clarification of your setup before I could address your question.  Plus, the fact that a solo practitioner can be classified as a Group by CMS further confuses the issue.

A biller cannot possibly bill regular medical correctly when dealing with a collection of workers unless they know what requirements distinguish a CMS-defined Group from a collection of workers who call themselves a group but don't meet the CMS requirements to be a CMS-defined Group.  I don't know mental health billing, but I'm willing to bet that this paragraph is as true for mental health billing as it is for regular medical billing.  Linda's comments brought up the issue of legal structure and whether any biller ever needs to be involved in determining that.  That is not the issue.  CMS imposes requirements on a CMS-defined Group that it does not impose on an arbitrary collection of workers who do not meet CMS requirements to be called a Group.  When someone asks questions about billing, and uses the term Group, whoever is answering the question had better be interested in what type of Group the questioner is talking about.  Elsewise, any answers given may be incorrect.

Healthy, hopefully you found an answer to your question somewhere in all of this.  If not, or if you are still unclear on anything, come back with more questions.

[Edit] CMS imposes certain requirements on solo practitioners and Groups when they bill for Medicare patients.  The State of California imposes those same requirements on California providers regardless of what Insurance Carrier they bill.  Specifically, California also has adopted the CMS definition of Group, and makes the same distinction between solo practitioner and CMS-defined Group that CMS makes - regardless of what Insurance Carrier they bill (whereas CMS only makes that distinction for billing Medicare patients).  That is why I use the phrase CMS-defined Group above.  In California, we have to be mindful of the definitions and requirements set out by CMS, regardless of what Insurance Carrier we bill.  For us, in certain situations, how we bill depends on whether we are dealing with a solo practitioner or a CMS-defined Group; this is required by the California Code.  A health-care attorney can tell you whether anything like this exists in your state. [/Edit]

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