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Marilyn Posted Wed 12th of March, 2014 16:57:21 PM

LPC is seeing pateints under Psyd supervision, do I bill using the LPC individual NPI as rendering, and in enter in box 17 of cms 1500 the supervising PsyD information or can I just totaly bill the claim under the supervising provider? Both signatures are on documents.

SuperCoder Answered Thu 13th of March, 2014 15:59:27 PM

For the more recent one about supervision and billing -- I think part of the answer depends on whether the services being provided qualify as incident-to. Did the physician meet with the patient and meet all the criteria for planning out treatment and the non-physician provider is now providing care for the patient based on that plan (and under the supervision of a physician in the office at the time)? If so, it might be incident-to and be billable under the name and ID of the supervising physician who's present at the time of service. That would allow 100% payment. But if they aren't meeting all the incident-to requirements, it sounds like the non-physician practitioner would need to bill under his/her name and number instead of the physician's. In that case, Medicare would pay 85% of what the normal full allowance for payment would be.

We really need a few more details before we could give a solid answer.

SuperCoder Answered Thu 13th of March, 2014 15:59:27 PM
With Leigh
Marilyn Posted Mon 17th of March, 2014 17:27:25 PM

LPC is fully being supervised by the physician, so the the service(s) can be billed under the physician?

What if the the physician was not present at time of service but coordination of care, codings, etc., was supervised by physician over the phone with the LPC? Can service still be billed under the supervising physician?

SuperCoder Answered Mon 31st of March, 2014 14:42:25 PM

Here is my CE reply to your question-

First, I am assuming that "LPC" stands for licensed professional counselor. If so, then the question becomes whether or not an LPC's services can be billed "incident to" those of the physician. I addressed that question in a Q&A that appeared in the May/June 2013 issue of AAFP's Family Practice Management. My answer was as follows:

"First, let's consider your question with respect to Medicare. Two facts suggest that what you propose might not be possible. One is that marriage counseling and pastoral counseling are not covered by Medicare. The other is that licensed marriage and family therapists and licensed professional counselors are categories of nonphysician providers that are not currently recognized by Medicare, a status that means they cannot bill Medicare directly for their services. However, because Medicare does not have explicit requirements regarding the qualifications of auxiliary personnel who may provide “incident to” services, it is possible that some services of marriage and family therapists and licensed professional counselors could be reported “incident to” if they met the requirements and were not otherwise non-covered services.
Section 60 of chapter 15 of the Medicare Benefit Policy Manual states that “auxiliary personnel” means “any individual who is acting under the supervision of a physician, regardless of whether the individual is an employee, leased employee, or independent contractor of the physician, or of the legal entity that employs or contracts with the physician.” Typically, auxiliary personnel are considered to be clinical staff such as nurses and technicians. Other Medicare-recognized nonphysician providers, such as nurse practitioners, physician assistants, and clinical nurse specialists, may also have their services covered “incident to.”
In general, “incident to” services and supplies must be:
• An integral, although incidental, part of the physician's professional service;
• Commonly rendered without charge or included in the physician's bill;
• Of a type that are commonly furnished in physician offices or clinics;
• Furnished by the physician or by auxiliary personnel under the physician's direct supervision.
You may want to confer with your local Medicare administrative contractor before submitting a claim for the “incident to” services you've described.
As for commercial insurers, you should check with each carrier to confirm your understanding of their policies. Some may allow “incident to” billing for such therapists."
For AAFP members and FPM subscribers, that Q&A is available online at:
I would say there is a much higher likelihood of the counselor's services being covered under the physician's ID if the physician is present in the office suite when the services are provided. If the physician is not present, basic "incident to" rules are not met under Medicare, and I suspect most private payers would also be reluctant to pay for the counselor's services in the absence of the physician.

I hope this helps!

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