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June 2017
Clarification of rules for supervision for nonphysician mental health practitioners
We’ve been asked to clarify Blue Cross Blue Shield of Michigan’s rules for supervision of nonphysician mental health practitioners in a non-outpatient psychiatric care facility setting.
Fully licensed
Generally, Blue Cross will cover the services of any fully licensed nonphysician mental health practitioner as long as the practitioner is supervised by an M.D., D.O., or fully licensed psychologist and billed by the supervising M.D., D.O., or fully licensed psychologist. When determining whether a service is a covered benefit, Blue Cross will apply any State of Michigan laws or regulations that specify requirements regarding supervision. Compliance with legal and regulatory provisions must be documented for the purposes of audit.
There are two areas where there are such requirements:
- In the general provisions of the public health code, section 333.16109 defines supervision as having all of the following:
- The continuous availability of direct communication in person or by radio, telephone, or telecommunication between the supervised individual and a licensed health professional.
- The availability of a licensed health professional on a regularly scheduled basis to review the practice of the supervised individual, to provide consultation to the supervised individual, to review records and to further educate the supervised individual in the performance of the individual's functions.
- The provision by the licensed supervising health professional of predetermined procedures and drug protocol.
- Limited licensed psychologists must be supervised by fully licensed psychologists (or other such individuals as designated by law) in the manner prescribed in rules governing psychologists. (See MCLA 333.18223 and also see Regulation 338.2571 Supervision requirements; reporting of supervision.)
Supervision and billing responsibilities for nonphysician mental health practitioners
Nonphysician mental health practitioner |
Does Blue Cross participate and directly reimburse? |
Are the services of the nonphysician practitioner covered
if supervised by a: |
M.D or D.O. |
FLP |
LMSW |
LPC |
LMFT |
LLP |
Fully Licensed Practitioners |
LMSW
Licensed Master’s Social Worker |
Yes |
Yes** |
Yes^ |
No |
No |
No |
No |
LPC
Licensed Professional Counselor |
Yes |
Yes** |
Yes^ |
No |
No |
No |
No |
LMFT
Licensed Marriage & Family Therapist |
No |
Yes** |
Yes^ |
No |
No |
No |
No |
LLP
Limited License Psychologist |
No |
No |
Yes^ |
No |
No |
No |
No |
Educational Limited License Practitioners
|
LLMSW
Limited License Master’s Social Worker |
No |
No |
No |
Yes# |
No |
No |
No |
LLPC
Limited License Professional Counselor |
No |
No |
No |
No |
Yes# |
No |
No |
LLMFT
Limited Licensed Marriage & Family Therapist |
No |
No |
No |
No |
No |
Yes**^ |
No |
TLLP
Temporary Limited License Psychologist |
No |
No |
Yes^ |
No |
No |
No |
No |
**The supervising M.D or D.O. must submit the bill using the supervising M.D. or D.O.’s NPI.
^The supervising FLP must submit the bill using the supervising FLP’s NPI.
#Either the supervising fully licensed nonphysician practitioner of the same provider type must bill using the supervisor’s NPI or the M.D./D.O./FLP supervisor of the fully licensed practitioner must bill.
State and Federal Definitions of Supervision
STATE
MCLA. 333.16109
(2) “Supervision”, except as otherwise provided in this article, means the overseeing of or participation in the work of another individual by a health professional licensed under this article in circumstances where at least all of the following conditions exist:
(a) The continuous availability of direct communication in person or by radio, telephone, or telecommunication between the supervised individual and a licensed health professional.
(b) The availability of a licensed health professional on a regularly scheduled basis to review the practice of the supervised individual, to provide consultation to the supervised individual, to review records, and to further educate the supervised individual in the performance of the individual's functions.
(c) The provision by the licensed supervising health professional of predetermined procedures and drug protocol.
Note: For educational limited licenses, different supervision requirements are required, which vary by provider type.
FEDERAL
42CFR410.32(b)(3)
(i) General supervision means the procedure is furnished under the physician's overall direction and control, but the physician's presence is not required during the performance of the procedure. Under general supervision, the training of the nonphysician personnel who actually perform the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician.
(ii) Direct supervision in the office setting means the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician must be present in the room when the procedure is performed.
(iii) Personal supervision means a physician must be in attendance in the room during the performance of the procedure.
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