Medicare/Psych Assistants

Posted - 12/5/18 - Updated version posted 12/10/18

Click here for the handout for today’s 11 a.m. Noridian (Medicare) live webinar for Mental Health providers. Of note: slide 22, which is specific for unlicensed psychological assistants and “incident-to” billing.

Posted - 6/28/18 

If the psychological assistant is not licensed by the state in which the services are furnished, the psychological assistant would not be permitted to serve incident to the services of a clinical psychologist for Medicare purposes. The Medicare Beneficiary Policy Manual, Publication 100-02, Chapter 15, Section 60.2 states that these non-physician practitioners, who are being licensed by the States under various programs to assist or act in the place of the physician, include, for example, certified nurse midwives, clinical psychologists, clinical social workers, physician assistants, nurse practitioners, and clinical nurse specialists. Nonetheless, in order for services of a non-physician practitioner to be covered as incident to the services of a physician, the services must meet all of the requirements for coverage specified in §§60 through 60.1. Based upon the CMS Manual provision cited above, the MAC is correct in requiring that the non-physician personnel who is assisting the physician be properly licensed.


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Posted on the LACPA Listserv June 14, 2018

Subject: Important notice to LACPA members about Medicare and Psychological Assistants

Over the past few years, there has been an increase in postings to psychological listservs regarding the question of whether or not it is ethical/legal for a Medicare psychologist to have a psychological assistant see their patients, whether in a facility setting (skilled nursing or assisted living) or in an outpatient setting (office or home). Often times, the topic of “incident to” is used to justify licensed psychologists having their psychological assistants see patients and then the licensed psychologist bills Medicare as though they saw the patient.
The reality is that Medicare does not recognize psychological assistants, nor does it allow for a licensed psychologist to bill Medicare for services they did not deliver. This is insurance fraud. There have been licensed psychologists who have not only lost their licenses but have gone to federal prison for this, as well as having to repay Medicare. 
Last July, Noridian (the Medicare Administrative Contractor for Southern California) did a two-part webinar for Mental Health providers, and in part 2, they addressed the question of psychological assistants and the “incident to” issue. Specifically, the question asked was “Does Medicare allow “pre/post interns or psychological assistants” to conduct psychotherapy and/or assist “incident to” of a licensed psychologist? The answer: No. Psychological assistants, trainees and interns are not recognized by Medicare.
If you are a psychological assistant currently engaging in this activity, stop. If you are a psychologist who accepts Medicare patients and are engaging in this activity, stop. It is unethical, illegal, and can have dire consequences.
Lauren Mulheim, Psy.D., on behalf of the LACPA Ethics Committee

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Click here to open the complete PDF presentation slideshow that Noridian (Medicare) did July 2017 - slide 51 (see below) states psych assistants, trainees, and interns are not recognized by Medicare and not allowed to do psychotherapy and/or assist licensed psychologists.

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APA Practice Organization posted “Medicare will not pay for services provided by a supervised individual”: