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Billing One Clinican under another as "supervised"?

  1. #1
    Default Billing One Clinican under another as "supervised"?
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    Have an interesting predicament....
    We have a licensed psychologist who is going to be a temporary employee for approximately 3 months; during which time she is going to be performing psychological testing on several clients.

    She is not credentialed with anyone other than MA, and does not want to be.

    Our MD wanted me to bill her "incident to" however, under CMS guidelines, 96101 cannot be billed "incident to".

    Another of our psychologists offered to be her "supervisor", however this does not seem ok to me, since the new PysD is licensed.

    So, in addition to, (since we are a teaching facility) we have students who would be supervised under this same PsyD for the testing (96101) that they are performing, however, the students' supervisors would like to bill the testing under their own licenses as if it was a regular therapy type visit, even though it would be the new PsyD who is doing the actual supervision on the testing....again, this to me does not seem totally "kosher".....

    Thoughts?

    (it seems to me that having a supervisor of a supervisor of a student is not exactly right....)
    Thanks!
    Last edited by jcochran; 01-31-2012 at 01:35 PM. Reason: added text after "so in addition to..."

  2. #2
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    I would encourage you to read and better understand the Medicare Teaching Physician Guidelines and grasp that psychology "interns" are not comparable to MD "interns". Additionally, you have a complicated situation. To minimize the various supervision issues, credential this new psychologist. If you start early enough, the 3 month period shouldn't be too much of an issue.

    http://www.cms.gov/MLNProducts/downl...gresfctsht.pdf

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