Wiki BH services in an Article 28 clinic

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We have article 28 clinics that are specific to treating behavioral health conditions. We do not bill Incident To because we are under the impression that this can not be done in an Article 28 clinic- can someone verify this is correct?
If I am correct in saying we are not able to bill "incident to" then how do those services done by a CASAC get billed to MCR or can they not be billed?

There are conflicting views in that if the psychiatrist, MD and/or psychologist is overseeing the treatment plan then we can split bill the service, done by the CASAC, under the MD- is this accurate?

Last question, would the REV code for these services done in our clinics be the 900 rev code?

Any help would be appreciated. Thank you!
 
I'm not a specialist in BH facility guidelines, which are complex in their own right, but I think your questions are applicable to facility billing in general. You're correct that you cannot bill 'incident to' in a facility setting - in other words, physicians may not bill for the services performed by the facility's ancillary staff on their professional claims. That is because the facility is responsible for billing of all ancillary services - it's not that you can't bill for them, it's just that they have to be billed by the correct entity. A physician cannot bring their own staff into a facility to perform 'incident to' services and bill for them because those services are the responsibility of the facility in that setting. So the services provided by counselors, nurses, and other staff would all be a component of the facility's charges on the UB. If the clinic is billing a facility claim, then the only services that can be billed as professional services on a 1500 claim are those service personally performed by the physicians or NPPs - an MD or psychologist cannot submit professional charges on behalf of facility staff when they are just overseeing the care plan. Let me know if that helps clarify what you're asking.

As far as what revenue code should be used - it will depend on the type of service and patient's status - there aren't standardized coding guidelines on what revenue code you should use for what service and this can be very payer-specific. Look to your local Medicare contractor and other payers for guidance on this, either in the facility's contracts or in the payers' published policies or billing manuals as to how they expect the services to be submitted.
 
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