With the changes made in 2024 for Medicare services, there has been some confusion on what clinicians are able to bill versus the way it was billed out. For general supervision in behavioral health, it has become difficult to get black and white data to spell out the way claims need to be submitted when a clinician's supervisor is on the claim. Would the following scenario be considered paid under general supervision billing for Medicare?
The Rendering Clinician Type LPC, LPC-IT, LSW, SWT, QMHS, CT, LSW:
An established patient is in a nursing facility (POS 32) having services rendered with one of the above clinicians that does not have a Medicare ID number. The patient has already been seen by the same clinicians for CPT 90791 and is currently being seen for CPT 90837. The clinician has given the patient F41.0 as the diagnosis. The treatment plan was created by the above rendering clinician type and their supervisor reviewed it with them. The clinician is not affiliated with that nursing facility but with an outsourced vendor. The clinician is not being supervised directly but rather during monthly supervision meetings with each other. The supervisor reviews the case notes and such from the visits rendered. The supervisor has an active Medicare ID number and meets the qualifications set by Medicare. The supervisor is registered with Medicare either under Behavioral Health & Social Service Provider taxonomy code 101YP2500X or Behavioral Health & Social Service Providers/Social Worker Clinical taxonomy code 1041C0700X. The supervisor is not an NP or those of those type used for incident to billing. A claim is submitted to Medicare for processing with the supervisor's name and DQ listed in box 17 on the CMS-1500 form. The supervisor's name and NPI is listed in box 24J on the CMS-1500 form. There is a modifier on the line to reflect one of the clinician types above (U9, U7, HN, etc.). The claim is submitted to Medicare and paid for the service.
The Rendering Clinician Type LPC, LPC-IT, LSW, SWT, QMHS, CT, LSW:
An established patient is in a nursing facility (POS 32) having services rendered with one of the above clinicians that does not have a Medicare ID number. The patient has already been seen by the same clinicians for CPT 90791 and is currently being seen for CPT 90837. The clinician has given the patient F41.0 as the diagnosis. The treatment plan was created by the above rendering clinician type and their supervisor reviewed it with them. The clinician is not affiliated with that nursing facility but with an outsourced vendor. The clinician is not being supervised directly but rather during monthly supervision meetings with each other. The supervisor reviews the case notes and such from the visits rendered. The supervisor has an active Medicare ID number and meets the qualifications set by Medicare. The supervisor is registered with Medicare either under Behavioral Health & Social Service Provider taxonomy code 101YP2500X or Behavioral Health & Social Service Providers/Social Worker Clinical taxonomy code 1041C0700X. The supervisor is not an NP or those of those type used for incident to billing. A claim is submitted to Medicare for processing with the supervisor's name and DQ listed in box 17 on the CMS-1500 form. The supervisor's name and NPI is listed in box 24J on the CMS-1500 form. There is a modifier on the line to reflect one of the clinician types above (U9, U7, HN, etc.). The claim is submitted to Medicare and paid for the service.