omhsas & permissible arrangements for …...this is required for all new submissions effective...
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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
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OMHSAS & Permissible Arrangements for Psychologists
Providing Behavioral Health Rehabilitation Services
OVERVIEW
I. Background on Pennsylvania DPW-OMHSAS Medical Assistance Bulletin (MAB)
II. Introduce Verification of Responsibilities form
III. Examples of appropriate/inappropriate service delivery arrangements
MAB OMHSAS-11-05 March 8, 2011
Over time, OMHSAS found…. some psychologists lacked a full understanding of the
BHRS requirements they were a provider of or how these requirements intersected with Pennsylvania State Board of Psychology regulations. Key findings include:
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
Providing BHRS
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
General Enrollment
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
Providing BHRS
Current regulations allow for a psychologist to offer BHRS as an independently recognized provider (provider type 19)
To provide BHRS,
a psychologists must….
Providing BHRS
Submit Service Description (SD) the OMHSAS-Children’s Bureau for review and approval (new provider)
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
Providing BHRS
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)
Providing BHRS
MAB OMHSAS-11-05 initiates requirement for Verification of Responsibility form
Acknowledges awareness of regulations governing standard billing practices and limits on supervised employees.
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
Providing BHRS
Why is the Department of Public Welfare-OMHSAS requiring the psychologists’ signature?
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
Permissible Service Arrangements
The Professional Psychologist Practice Act (1986, P.L. 89, No. 33) empowers the Pennsylvania State Board of Psychology to define and regulate standards for professional practice.
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.
Permissible Service Arrangements
§ 41.58 “Standards for the employment and supervision of unlicensed persons with graduate training in psychology”
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
Permissible Service Arrangements
§ 41.58 “Standards for the employment and supervision of unlicensed persons with graduate training in psychology” continued…..
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
Permissible Service Arrangements
PA State Board of Psychology: the work of a TSS as it is currently defined and being provided is not the practice of psychology
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 qualifications and established minimum training and supervision requirements for TSS workers
Permissible Service Arrangements
Additionally, MAB 01-01-05 establishes minimum qualifications for professionals supervising TSS
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:
• At least 1hr individual or group supervision per week
• On-site assessment and assistance prior to working alone with children or adolescents (varies depending on experience)
• Periodic on-site supervision (determined by supervisor)
Permissible Service Arrangements
The purpose of the guidance document from the bulletin is:
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 apply to psychologists enrolled in the MA program to provide BHRS.
Service Arrangements
Licensed Psychologist
TSS
TSS
TSS
MT/BSC
TSS TSS TSS
Entity
Unlicensed Professional
Program
Pre-Doc Intern
Service Arrangements
Psychologist (Type 19)
BHRS (3 FTE & TSS)
Psychologist (Type 19)
BHRS (3 FTE & TSS)
Psychologist (Type 19)
BHRS (3 FTE & TSS)
Entity
Penalties
Providers billing for services without proper approval or for unnecessary services face civil and criminal penalties in accordance with state and federal laws. Penalties may include:
Nonpayment of questionable claims
Civil monetary penalties
Exclusion from the Medicaid Program
Imprisonment and criminal fines
Penalties (cont.)
Additionally, the Pennsylvania State Board of Psychology may impose penalties and sanctions including:
Civil monetary penalties
License suspension/revocation
Additional training and corrective actions deemed appropriate by the Board.
Information
Service Bulletins and policies related to the provision of BHRS can be found:
www.parecovery.org Pennsylvania Recovery and Resiliency- Provides access to behavioral health resources both at
the state and community level www. services.dpw.state.pa.us/olddpw/bulletinsearch.aspx 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
Information
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
Information
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 [email protected] 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 [email protected]
www.dpw.state.pa.us