Rehabilitation Services T R A I N I N G O N M E D I C A L A S S I - - PowerPoint PPT Presentation
OMHSAS & Permissible Arrangements for Psychologists Providing Behavioral Health Rehabilitation Services T R A I N I N G O N M E D I C A L A S S I S T A N C E B U L L E T I N O M H S A S - 1 1 - 0 5 I S S U E D M A R C H 8 , 2 0 1 1
T R A I N I N G O N M E D I C A L A S S I S T A N C E B U L L E T I N O M H S A S - 1 1 - 0 5 I S S U E D M A R C H 8 , 2 0 1 1
I.
Exceeding supervision limit of unlicensed professionals (MT’s
& BSC’s)
Allowing other psychologist or “providers” to bill for services
under their provider number or billing for services supervised by other psychologist
No participation in treatment planning or service delivery No oversight of program development Deviating from approved Service Description
Background… 1989 Congress amends the Early and Periodic Screening, Diagnosis and Treatment (EPSDT) provisions of the Medicaid statue, requiring states to provide necessary treatment and services 1994 Therapeutic Support Staff (TSS), Mobile Therapy (MT) and Behavioral Specialist Consultant (BSC) added to Medicaid fee schedule (MAB 01-94-01). 2001 MAB 01-01-05 revises policies related to BHRS including qualifications, training and supervision requirements for TSS 2003 MAMIS-to-PROMISe transition psychologists previously enrolled as “provider type 50” re-enrolled as “provider type 19” to align with federal taxonomy codes. 2005 DPW begins utilizing National Provider Identifier (NPI) and associating with PROMISe ID. 2007 DPW begins offering MA Bulletins via email
To do business with the Department of Public Welfare,
provider entities must first enroll in the Pennsylvania Medical Assistance Program.
Enrollment requires a complete a base provider enrollment form and
applicable addenda documents.
For psychologists ….
Must be licensed without restriction and meet established provider type
criteria:
http:/ / www.dpw.state.pa.us/ provider/ promise/ enrollmentinformation/ index.htm
Approved applicants are issued unique PROMISe number and entered
into statewide network
To provide BHRS,
Submit Service Description (SD) the OMHSAS-
A completed SD includes information as outlined in MAB 01-
94-01 and formatted in accordance with Attachment 7 of MAB 1153-95-01
Supporting documentation includes: signed Verification of
Responsibility form, copy of valid license, letters of county support and collaboration with BH-MCO’s (technical assistance
materials provided by the Children’s Bureau available upon request).
Approval, denial or request for revisions provided within 45
days of submission
MAB 01-96-11 requires providers to submit a revised Service Description if…. “there are substantial changes in a service that the Department previously approved.” According to MAB 01-96-11 examples of “substantial changes” include some of the following:
1.
Changes to the actual services provided
2.
Change in staff qualifications or staffing ratios
3.
Change in service site (e.g. main service location or counties served, addition of a new service location)
MAB OMHSAS-11-05 initiates requirement for
Acknowledges awareness of regulations governing
This is required for all new submissions effective March 8,
2011
Service Descriptions will not be approved without submission Previously approved providers must sign and submit to
OMHSAS-Children’s Bureau
COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE OFFICE OF MENTAL HEALTH AND SUBSTANCE ABUSE SERVICES BUREAU OF CHILDREN’S BEHAVIORAL HEALTH SERVICES
Verification of Responsibilities I understand that when I provide Behavioral Health Rehabilitation Services (BHRS) I must comply with both the Pennsylvania Board of Psychology’s licensing requirements and the requirements that govern participation in the Pennsylvania Medical Assistance Program and provision of BHRS. I also understand that I am fully responsible for any services billed under my Medical Assistance provider number. By signing the attached service description, I accept responsibility for the following services to be billed using my Medical Assistance provider number:
Evaluations MT BSC TSS
_______________________ Psychologist Signature _______________________ Psychologist Printed Name ________________________ Date ________________________ Psychologist License Number
Why is the Department of Public Welfare-OMHSAS
The signed “Verification of Responsibilities” acknowledges
that the psychologist will be using their individual MA provider number and thus financially, legally and ethically responsible for all services outlined on the approved Service Description.
Providers lacking direct involvement in the development of their
Service Description risk program noncompliance, unethical practice arrangements or unacceptable billing practices resulting in financial penalties or practice sanctions
The Professional Psychologist Practice Act (1986,
Title 49, Chapter 41 State Board of Psychology, defines
standards for the employment and supervision of unlicensed persons with graduate training in psychology.
Subsections 41.58(b) and 41.58(c)(2) directly apply to the
provisions of BHRS for psychologist providers and supervision of BSC’s, MT’s and TSS.
§ 41.58 “Standards for the employment and
Paragraph (b) requires that the employing psychologist must: Ensure proper educational requirement of any employee Bear full professional responsibility for services provided by
employee
Provide appropriate supervision arrangements, including proper
delegation of supervisory responsibilities to other psychologists and/ or qualified professionals
Paragraph (c)(9) Prohibits the employing psychologist from supervising more than
three full-time (FTE) or their equivalent in part-time employees.
“FTE” based on established personnel policy and in accordance
with applicable labor laws and regulations
PA State Board of Psychology: the work of a TSS as it
However, regulations by the Board and by virtue of billing
under their MA provider number, the psychologist remains responsible for all aspects of BHRS.
MAB 01-01-05 (June 2001) revised minimum staff
Additionally, MAB 01-01-05 establishes minimum
These criteria allow BSC’s and MT’s who meet the educational
requirement to provide supervision up to 9 full-time equivalent TSS workers
For TSS employed 20hrs per week or more, ongoing supervision
includes:
children or adolescents (varies depending on experience)
The purpose of the guidance document from the
To provide examples of arrangements a psychologist enrolled
in the MA Program to provide BHRS. The examples address both permissible and impermissible arrangements.
To identify specified regulations and policies that
Licensed Psychologist TSS TSS TSS
Licensed Psychologist TSS TSS TSS
MT/ BSC
TSS TSS TSS
Entity
Unlicensed Professional
Program
Pre-Doc Intern
Psychologist (Type 19)
(3 FTE & TSS)
Psychologist (Type 19)
(3 FTE & TSS)
Psychologist (Type 19)
(3 FTE & TSS)
Providers billing for services without proper
Nonpayment of questionable claims Civil monetary penalties Exclusion from the Medicaid Program Imprisonment and criminal fines
Additionally, the Pennsylvania State Board of
Civil monetary penalties License suspension/ revocation Additional training and corrective actions deemed appropriate
by the Board.
www.parecovery.org Pennsylvania Recovery and Resiliency- Provides access to behavioral health resources both at the state and community level
DWP link to bulletin search (A list of BHRS-related bulletins referenced in OMHSAS-05-11) www.paproviders.org Pennsylvania Community Providers Association (PCPA) serves as a forum for the exchange of information and experience, archived information related to BHRS and updates on trainings for providers www.pacode.com Provides access to regulatory language governing DPW and the provision of BHRS
Provider Enrollment Provides assistance regarding MA enrollment processes, file maintenance and general MA enrollment questions: 1-800-537-8862 Hours of operation: Monday – Friday, 8 AM-4:30 PM http:/ / www.dpw.state.pa.us/ provider/ promise/ enrollmentinformation/ index.htm OMHSAS Toll-Free Inquiry Line Technical assistance for behavioral health counties, plans and providers to assist with enrollment, billing, eligibility discrepancy, etc. 1-800-433-4459 Hours of operation: Mon-Fri 8 AM-4 PM, Voicemail available after 4 PM
Contact:
Garrett Rosas, PsyD Consulting Psychologist OMHSAS- Bureau of Children's Behavioral Health Services P.O. Box 2675 Harrisburg, PA 17105-2675 Voice: 717-425-7674 Fax: 717-705-8268 c-grosas@state.pa.us Courtney Coover, Chief Planning, Policy & Development Division OMHSAS- Bureau of Children's Behavioral Health Services P.O. Box 2675 Harrisburg, PA 17105-2675 Voice: 717-772-7855 Fax: 717-705-8268 ccoover@state.pa.us
www.dpw.state.pa.us