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If you are part of a primary care practice that has already begun implementing behavioral health services to address your patient’s healthcare needs, or if you are just starting to consider doing so, Stephanie Allard, CEO & Compliance Consultant, Stephanie Allard Consulting LLC, addressed many of the concerns you may have in her HEALTHCON 2025 presentation, “Integration of Behavioral Health Services Into Pediatric, Internal Medicine and Family Practices.”

The presentation touched on issues such as determining what services your practice might want to provide and who should provide them, developing an effective workflow for the services, and creating processes to determine how they should be documented and audited to ensure success.

Look Over These Services and Know Who Can Provide Them

The Medicare Learning Network (MLN) Behavioral Health Integration Services booklet is a good place to start if you want to understand the definition of behavioral health integration (BHI). The MLN booklet says, “BHI is a type of care management service” that integrates “behavioral health care with primary care … for improving outcomes for millions of Americans with mental or behavioral health conditions.”

Essentially, BHI services consist of providing mental health and developmental screenings, diagnostic evaluations, psychotherapy, and medication management all in the primary care setting, according to Allard. The most difficult issue for any practice wanting to provide these services, however, lies in knowing which professionals are eligible to bill for the services.

Another MLN booklet, Medicare & Mental Health Coverage, lists the following as being eligible to be paid under Medicare Part B, and notes the percentage of Medicare Physician Fee Schedule (MPFS) payment they are reimbursed:

• Physicians (medical doctors [MDs] and doctors of osteopathy [Dos]), particularly psychiatrists (100 percent)
• Clinical psychologists (CPs) (100 percent)
• Clinical social workers (CSWs) (80 percent)
• Clinical nurse specialists (CNSs) (80 percent of the lesser of the actual charge or 85 percent of the amount paid to the physician under the MPFS)
• Nurse practitioners (NPs) (80 percent of the lesser of the actual charge or 85 percent of the amount paid to the physician under the MPFS)
• Physician assistants (PAs) (80 percent of the lesser of the actual charge or 85 percent of the amount paid to the physician under the MPFS)
• Independently practicing psychologists (IPPs) (100 percent for diagnostic tests)

All providers on the list must be licensed by, or eligible to practice in, the state in which they are practicing, while other mental health providers such as licensed professional counselors or marriage and family therapists may be eligible to bill incident-to, according to Allard. Additionally, “it is important to review what services must be provided by a physician or other qualified healthcare professional and which can be rendered by an unlicensed or noncredentialled staff member,” Allard noted.

Delve Deep Into BHI Documentation

After matching BHI services with the correct provider, it is important to understand how the services must be documented. Many services are described by time-based codes, meaning the documentation must contain information on how long the service lasted. Documentation should also include the following:

For psychological and neuropsychological testing (CPT^®  96130-+96139), documentation should include interpretation of test results, interpretation of patient data, a report of clinical decision making and treatment planning, and a record of feedback given to the patient and/or family members or caregivers.

For developmental and behavioral screening and testing (CPT^®  96110-+96113), documentation should include such things as face-to-face assessment of fine and/or gross motor skills, language, cognitive level, memory, and social and/or executive functions when performed.

For psychiatric diagnostic evaluation (CPT^®  90791-90792), documentation should include such things as collection of information regarding past and present patient behavioral concerns, family medical and social history, and any diagnostic testing performed.

For 90792 (Psychiatric diagnostic evaluation with medical services), you will also need to include documentation of any medical services provided, including such things as prescriptions ordered, medication monitoring, evaluation of comorbid conditions, and results of any clinical tests ordered. Services described by 90791-90792 “are typically used in place of an evaluation and management (E/M) service, as their documentation requirements are less restrictive,” Allard noted. However, they can only be billed once per day, regardless of time spent with the patient.

 For psychotherapy services with/without E/M (CPT^®  90832-90838) & with/without family (CPT^®  90846-90847), documentation should include such things as medical necessity supported by ICD-10-CM code(s), treatment plan, symptoms, progress to date, and prognosis. The notes should also offer clear identification of patient and provider, including signature, and time and date of service. E/M services should be documented if performed.

Implement Effective Workflow and Audit Procedures

The MLN Behavioral Health Integration Services booklet mentioned earlier provides a suggested team model for BHI that consists of three key individuals:

• A behavioral health care manager
• A psychiatric consultant
• A treating (billing) practitioner

Additionally, you will need to educate the appropriate office staff on coordinating scheduling and overseeing credentialling. Coders and billers will also need to determine responsibility for code selection and documentation and code review, according to Allard.

Periodically, your practice will need to conduct internal reviews, and possibly even bring in external reviewers, to evaluate a BHI program. You should also have a process in place for education and a re-audit should the first audit prove to be unsatisfactory.

Bruce Pegg, BA, MA, CPC, CFPC, Managing Editor, AAPC