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NARHC-News
Experience adding behavioral health
Page 1 of 1
1/1/2021 @ 4:52:00 PM
Post 1 of 8

Contributor: Brad Ashby, South Main Clinic

Does anyone have experience adding behavioral health to the mix of an already operating RHC? We have added opioid addiction to our practice and have outsourced behavioral health. It would work so much better having this service in-house. I just don't know where to start to add this service. We are located in Kentucky so if anyone in Kentucky has experience it would be best, but I never shy away from any advice.

 

Thanks!

 

Brad

1/4/2021 @ 11:50:00 AM
Post 2 of 8

Contributor: Charles James, North American Healthcare Management Services

The best place to start with "in-house" behavioral health is with an LCSW providing counseling services. Kentucky Medicaid has an expanded provider list which includes addiction counselors. (Most Medicaid agencies do). Medicare covers LCSWs - not this expanded state list. It is certainly possible to start with one of the therapists listed below, but they would only be bill claims for non-Medicare patients.

The trick with addiction therapy in our RHC is we have to ensure that 51% of our total provider hours are primary care. We cannot be "primarily mental health centers". It is imperative that we treat the whole patient - not just their addiction. Document that all patients conditions have been treated - not just their behavioral health issues. Then get them engaged with the behavioral health providers. This is also a wonderful opportunity to provide care management services. Look at Option B for G0511 and Psychiatric Coordinate of Care G0512.

Kentucky Approved RHC Providers
Physician
Licensed Clinical Social Worker
Osteopathic Physician
Psychologist
Podiatrist
Marriage And Family Therapist
Optometrist
Licensed Professional Clinical Counselor
Advanced Practice Registered Nurse
Licensed Psychological Practitioner
Licensed Dentist/ Oral Surgeon
Certified Psychologist With Autonomous Functioning
Physician Assistant


Charles A. James, Jr.
President and CEO
888.968.0076 Office
314.560.0098 Cell
www.northamericanhms.com

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1/4/2021 @ 1:08:00 PM
Post 3 of 8

Contributor: Becky Corson, Mid-Valley Medical Group

In our research, we have learned that LCSW have a Master's degree in social work, and in the State of Washington, also have 4000 hours or two years of supervised training under a LSW. Is it the case that only LSW can bill for provider mental health services? We were thinking of adding a social worker that may not have the 4000 hours of supervised training in order to serve as our behavioral health manager and bill out for CoCM services. Can we bill out for CoCM services with this licensure?

Becky Corson, MBA
Mid-Valley Clinic
Omak, WA 98841
509-861-2461
corsonr@mvhealth.org

1/4/2021 @ 2:24:00 PM
Post 4 of 8

Contributor: Charles James, North American Healthcare Management Services

For Medicare, LCSW and Clinical Psychologist (PhD) may bill behavioral health services in the RHC. Relative to the LSW who does not meet the state requirement billing for care management services, here is what the Care Management FAQ has to say:



For the CCM codes describing time spent per calendar month by "clinical staff," who qualifies as "clinical staff"? If the billing physician (or other billing practitioner) furnishes services directly, can their time count towards the clinical staff time required to bill ?

Practitioners should consult the CPT definition of the term "clinical staff." In addition, time spent by clinical staff may only be counted if Medicare's applicable "incident to" rules are met such as supervision, applicable State law, licensure and scope of practice. Of course, other staff may help facilitate CCM services, but only time spent by clinical staff can be counted. If the billing practitioner performs CCM services themselves, the time of the billing practitioner may be counted as clinical staff time or, alternatively, applied towards reporting professional CCM (CPT code 99491).



For the CCM codes describing time spent per calendar month by "clinical staff," do the times listed for the work of the billing practitioner mean that the billing practitioner must spend that amount of time each month, in addition to the clinical staff time in the code descriptors, in order to billCCM?
No, for these codes, these times should be considered like the typical times for evaluation and management (E/M) office visits. They are assumed times, established through physician survey by the American Medical Association when the codes were created and valued, for how much time the billing practitioner spends himself or herself each month, but are not exact times. The billing practitioner's time could be spent in activities such as directing clinical staff; personally performing clinical staff activities; or in the case of complex CCM, performing moderate to high complexity medical decision making.

In my view, under this definiton, the LSW who has not met state requirements could certainly bill incident to the billing provider. The LSW who has NOT met state requirements could not BE the billing provider.

From the Care Management Services MLN Booklet:
Practitioner Eligibility: Physicians and the following non-physician practitioners may bill CCM services:
Certified Nurse Midwives
Clinical Nurse Specialists
Nurse Practitioners
Physician Assistants

CAJ Note: RHCs bill G0511 or G0512. The following refer to the Fee-for-Service Care Management codes, but the descriptions apply:
NOTE: CCM may be billed most frequently by primary care practitioners, although in certain circumstances specialty practitioners may provide and bill for CCM. The CCM service is not within the scope of practice of limited-license physicians and practitioners such as clinical psychologists, podiatrists, or dentists, although practitioners may refer or consult with such physicians and practitioners to coordinate and manage care.
CPT code 99491 includes only time that is spent personally by the billing practitioner. Clinical staff time is not counted towards the required time threshold for reporting this code.
CPT codes 99487, 99489, and 99490 - Time spent directly by the billing practitioner or clinical staff counts toward the threshold clinical staff time required to be spent during a given month.
CCM services that are not provided personally by the billing practitioner are provided by clinical staff under the direction of the billing practitioner on an "incident to" basis (as an integral part of services provided by the billing practitioner), subject to applicable state law, licensure, and scope of practice. The clinical staff are either employees or working under contract to the billing practitioner whom Medicare directly pays for CCM.


Charles A. James, Jr.
President and CEO
North American Healthcare Management Services
9245 Watson Industrial Park * St. Louis, Missouri 63126
888.968.0076 Office
314.560.0098 Cell
www.northamericanhms.com

'Proper preparation prevents poor performance." Lt. Col. Tom Warner - paraphrased (USAF- Deceased)

See our Stopwatch challenge!
http://www.aprima.com/aprima-stopwatch-challenge

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1/4/2021 @ 2:30:00 PM
Post 5 of 8

Contributor: Beth O'Connor, Virginia Rural Health Association

Does any of that information change if the services are being provided via
telehealth? (depending on the regulations of the specific state)







Beth O'Connor, M. Ed.

Executive Director

Virginia Rural Health Association

540-231-7923



1/4/2021 @ 4:01:00 PM
Post 6 of 8

Contributor: Charles James, North American Healthcare Management Services

Yes and no. Yes, the Public Health Emergency waivers allows ANY personnel appriopriately licensed in the state to provide telehealth services. In this instance, however, the LSW was NOT appropriately licensed in the state. So no, she could not provide telehealth services and bill G2025.

Charles A. James, Jr.
President and CEO
North American Healthcare Management Services
9245 Watson Industrial Park * St. Louis, Missouri 63126
888.968.0076 Office
314.560.0098 Cell
www.northamericanhms.com

'Proper preparation prevents poor performance." Lt. Col. Tom Warner - paraphrased (USAF- Deceased)

See our Stopwatch challenge!
http://www.aprima.com/aprima-stopwatch-challenge

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This transmission contains privileged, confidential, and proprietary information and is only for the use of the individuals listed above, and may not be copied, distributed, or disseminated without express written consent. If you receive this transmission in error, please immediately destroy it.

1/12/2021 @ 5:43:00 PM
Post 7 of 8

Contributor: Kim Keating, Nursery Street Family Care Clinic

We are a provider based RHC in Missouri. Our state has a Primary Care Healthcare Home Initiative that we were eligible for. It provides a PM/PM for each patient that is enrolled on the panel. The PM/PM offset some to the cost of bringing on required staff, inclusive of a BHC. Our first BHC was a part-time MSW and only served our PCHH patients, concentrating on high utilizers. The next BHC was an LCSW. Since the LCSW is a billable provider in a Missouri RHC, we were able to justify full time. The LCSW's FTE is split 20/80 between the PCHH Initiative and the RHC Cost Report. Increased PCHH panel size would warrant an increase in the PCHH portion of her FTE. I'd recommend checking into any Healthcare Home initiatives your state may offer.


Kimberly L. Keating, PCMH CCE
Patient Centered Healthcare Home Director | Family Care Clinics

Bates County Memorial Hospital
615 West Nursery St | PO Box 370 | Butler, MO 64730
kkeating@bcmhospital.com www.bcmhospital.com
Office: 660-200-7000 ext 7020 Fax: 660-200-2304

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1/13/2021 @ 10:55:00 AM
Post 8 of 8

Contributor: Charles James, North American Healthcare Management Services

Kim - Thank you for this insight. Please - absolutely - as Kim says - check out these programs at the state level. These are excellent opportunities to start thinking about care management services as well. Many of us are struggling with how to make sure our patients needs are addressed. Much of this is now happening with phone contact instead of a face-to-face visit. There is a significang behavioral health component to G0511. I would LOVE to see some folks utilizing G0512, which is Psychiatric Coordination of Care. I believe these are both significantly underutilized relative to Behavioral Health.

Put it this way: It's a way to get paid for all of those phone calls. Thanks, Kim!!

Charles A. James, Jr.
President and CEO
North American Healthcare Management Services
9245 Watson Industrial Park * St. Louis, Missouri 63126
888.968.0076 Office
314.560.0098 Cell
www.northamericanhms.com

'Proper preparation prevents poor performance." Lt. Col. Tom Warner - paraphrased (USAF- Deceased)

See our Stopwatch challenge!
http://www.aprima.com/aprima-stopwatch-challenge

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This transmission contains privileged, confidential, and proprietary information and is only for the use of the individuals listed above, and may not be copied, distributed, or disseminated without express written consent. If you receive this transmission in error, please immediately destroy it.


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