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Hi, everybody.
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My name is Civy Suckerman, and this is Therapists Unchained, a podcast hoping to educate, empower, and inspire mental health clinicians across the country facing the systems that we're facing in this ever-evolving mental health landscape.
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If you listen to my episode that came out two weeks ago with Susan Frager, the psych billing coach, this is an impromptu kind of part two with Susan.
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So she's back.
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This is the first time I've had a sequential back-to-back part one and part two.
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We didn't know there was going to be a part two, but there's been a lot of stuff happening and it felt really vital to get Susan on the show again to talk about some of the things happening.
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So welcome back.
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Thanks, Civic.
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Glad to be back.
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And just so you know, if you're not already familiar, I have been working closely with the Mental Health Insurance Reform Task Force.
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If you haven't listened to my episodes with Nicole Sartini, I highly recommend that.
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The first episode specifically, it talks a lot about the uh vision behind the Mental Health Insurance Reform Task Force.
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And I'm just going to be calling it the task force because it's too many words to continue saying.
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But Susan also is involved with the task force.
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And one of the things that has come up, and this is a major reason why I wanted Susan back on the podcast so quickly, is because of what if you're not familiar with what's going on specifically in Michigan, but I think it's spreading, is Blue Cross Blue Shield in Michigan recently sort of changed their, I would you say contracts?
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I don't know how you'd frame it, Susan.
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It's their policy.
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Policy.
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Thank you.
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Their payer policy with respect to supervisory billing.
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Yeah.
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And so one of the things I really wanted Susan to speak to, because I see this a lot in my therapist groups, is this conflation of incident to billing and supervisory billing.
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Even Blue Cross Blue Shield in what they're talking about with this new policy, which we'll talk about, is conflating those terms.
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So, Susan, what I would love for you to do for everybody, because people, you know, I'm not a professional biller.
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You've been doing this for a long time.
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You know all about all of this stuff.
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Can you help people understand specifically what the actual difference is between incident to billing and supervisory billing?
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Uh, sure.
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Thanks, Civy.
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So incident to is primarily a Medicare concept coming out of the medical field.
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It has very limited ability to be adapted to behavioral health.
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People, and when I say people, I mean mental health clinicians sometimes think they can adapt it because they have been misled by people who don't understand the difference, or by insurance companies who are conflating it, like Blue Cross Blue Shield of Michigan, but they certainly aren't the only blue or the only payer that conflates it.
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Essentially, to understand incident two billing, you sort of have to go back to your graduate training, maybe your internship placements.
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If you were ever in a facility, a hospital, a treatment center where you worked on what in social work we used to call the treatment team approach.
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That's incident two billing.
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The treatment team is headed by a physician, either a medical physician or a psychiatrist, somebody who directs the care, determines the treatment goals, the treatment plan.
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They see the client first.
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It is, from a billing perspective, their client.
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So under incident two, everything is billed under the psychiatrist, which a lot of people like because when you bill it under psychiatrists, now you're getting 100% of Medicare.
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So for that reason, it is one of the most frequently and highly audited and clawed back procedures that one can encounter with Medicare.
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They are constantly auditing incident two, they are constantly finding errors and clawing back.
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It's under a lot of scrutiny.
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In Medicare's eyes, the line between just misunderstanding incident two billing and abusing it to the point of what they would consider fraud is very, very, very thin.
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Okay.
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Other people have used incident two, quote unquote, as a way to get around credentialing a new person on the team, or maybe not totally get around credentialing, you know, somebody who joins a group, but just in the nine or 12 months it takes to get them added to your group, they're like, well, we'll just build incident two.
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It's understandable, absolutely, but it's unfortunately wrong.
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So am I understanding when you say that that it would be that the supervising provider in under incident two would be listing themselves as the rendering provider?
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Yes.
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Okay.
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Yes, because in Medicare's eyes, the psychiatrist is the rendering provider, and then a nurse practitioner, a social worker, maybe a dietitian, you know, anybody is just carrying out pieces of the psychiatrist treatment plan.
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And this is also done a lot in just fully medical settings.
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Let's say a person has diabetes, let's say.
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So the primary MD is the billing physician.
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They send the person with diabetes to a nutritionist or a diabetes educator or somebody who monitors their blood sugars.
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All of those subsidiary people get paid by primary care MD, who then turns around and bills everything as a bulk package.
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It's called bundled.
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And then Medicare just pays for the bundle to the primary care physician.
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There are, I believe, seven criteria under Medicare that you have to meet for something to be legitimately classified as incident two.
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And most of them have just absolutely no bearing on what we do in mental health supervisory billing.
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Because in the end, supervisory billing, the supervisor isn't the therapist of record.
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It's the supervisee.
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It's the associate, you know, the person who's provisional provisionally licensed.
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They're the therapist.
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The supervisor is simply signing off on hours for state licensure and is acting as a case consultant.
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And so in that situation, the supervisee, the associate or provisionally licensed person is on the claim as the rendering provider, and the supervisor is the billing provider or the practice is the billing provider.
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Is that accurate?
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If done correctly.
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And when I say correctly, I mean the way the NUCC, the National Uniform Claim Committee, wants it done.
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However, and I'll be going over, I'm giving a webinar on this on July 17th.
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I'll be going all over this in great detail.
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But the problem is many insurance companies don't want it done that way.
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They just want it as if, City, let's say I'm being supervised by you, they want you to submit the claim as if you saw the client and I'm nowhere on the claim.
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To me, that reeks of insurance fraud, but it's not insurance fraud if Aetna puts it in writing that you should do it that way, and they do.
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The problem happens is that I think they do it for two reasons.
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One is so that they can easily track by volume what to audit.
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Because if Civi, you have a group of, let's say, six clinicians, four of them are supervisees, you're supervising all of them.
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All four of us see two or three etna clients per day, and then you may have a couple that's way more ethnic clients than you can ever legitimately see yourself in a day.
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So it falls under what's called an MUE or a medically unlikely edit.
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Because if 14 claims a day go in under your NPI number, they're gonna know that they need to audit and they're gonna know it's supervisory bill.
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That's reason number one I think they do it that way.
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Reason number two is they don't want to roster the, they don't want to take the time.
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And when I say roster, it means they take the NPIs and basic credentials of the provisionally licensed clinician and add them to your group.
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They don't want to be doing that.
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They, you know how overwhelmed they are.
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You can't even change an address in under, you know, how many months, or get somebody credentialed.
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They don't want to be bothered with provisional licenses, that's just more work for them.
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So it's easier for them to just say, Oh, you bill it.
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And give us a reason to audit you.
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Exactly.
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Exactly.
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But in incident two, it's different because it's absolutely legitimate for the physician to be the only rendering provider because the physician is controlling the treatment plan and also has a one-to-one relationship with the patient.
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Whereas a supervisee, supervisor in mental health, you know, if you're supervising me and I'm seeing a client, you don't have any direct relationship with my client unless maybe I have an emergency and I have to be out and you need to take care of my client.
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But in most cases, you wouldn't meet my client, you wouldn't assess them.
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And the client, if asked who their therapist is, they'd say it was Susan.
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So it's a very different model in um behavioral health.
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The other thing with respect to Medicare and Incident Two in behavioral health is that master's level clinicians who participate with Medicare cannot be billing providers under incident two, meaning the head of the treatment team cannot be a social worker, an MFT, or a counselor.
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It is not permitted under Medicare.
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Only a psychologist, nurse practitioner, or psychiatrist can be the head of a incident two treatment team.
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Okay, I guess that does make sense.
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Right.
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That's a Medicare rule.
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So any, you know, MFT who tries to build Medicare for the services of a provisional licensee and calls it incident two, you're gonna get busted if you get audited and you will be clawed back.
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And hopefully that is the worst thing that happens.
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I mean, hopefully that's the worst thing that happens to you and not extrapolation or other penalties, you know, verging on potential fraud.
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And there's so much misunderstanding out there about this.
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And I really worry for clinicians who don't understand and make innocent mistakes and and are gonna face consequences.
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That's to me the biggest scary, scariest part of this whole uh topic.
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Well, and I think when insurance companies are conflating it, and it's my understanding too with incident two that if insurance companies are calling this incident two, the other piece is that under incident two billing, the lead provider, let's just say, who should actually be a physician in a real incident two for the most part, is supposed to be present for the most part while the service is being rendered.
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Correct.
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They have to be reachable when the patient is seeing the subsidiary providers.
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The physician has to either be present in the same office or now there's some rules around immediately reachable that go back into the COVID era.
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And to be really honest, I can't quote them because 28 years into my billing career, I have yet to bill a single incident to that.
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Because legitimately incident to billing, because it's not a model that applies to us.
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So I haven't really memorized all of the requirements with regards to accessibility.
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But yes, that is part of it, is they do have to be accessible.
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Yeah, and so that reminded me, and I want to talk specifically about what's happening in Michigan, but there's also stuff happening in Arizona.
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Yes.
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And I don't have it in front of me, but my understanding is that there was a provider, at least I mean, I'm sure there's multiple, who's a supervisor who received notice that they were I don't know if it was if they weren't present or whatever it was, that they got clawed back, like the request was like for over like$500,000.
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Like it was Yeah, I think it was about three quarters of a million.
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Um and crazy, crazy.
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Well, but that that brings up another issue that I have a lot of problems with any and all commercial insurance companies with the potential, except exception of United Healthcare.
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And I say potential because I'm not familiar enough with United's because they have a very different way of handling supervisory billing.
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But for the moment, we'll we'll talk later about United.
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Don't forget to ask me about them.
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But my biggest beef, aside from them misclassifying incident two versus supervisory billing, is that they don't come out and say, here is our expectation with regards to what is acceptable documentation.
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There is nothing I read provider manuals routinely.
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This is what I do.
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I teach clinicians to know these things that insurance companies don't tell you so that you don't get tripped up and clawed back.
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I read these things and they put them out knowing that who has time to sit there and dig through and read them.
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Well, I do.
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And I can tell you there's nothing in there about how you're supposed to document it.
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Well, to me, that's an open invitation for a clawback because if you're supposed to be held to a standard that you don't know what the standard is and nobody's really defined it, then they can basically just say, Oh, well, yeah, I guess we'd like$750,000 back.
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Thank you very much, ching ching.
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And, you know, the person is being cited for documentation errors that she didn't know what the standard was.
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It makes me crazy.
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Yeah, I mean, that I feel like, yeah, I mean, that's across the whole thing because across all of healthcare, because I remember doing some research about like what actually medical necessity is, and there's no agreed upon meaning to that, what that even means.
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Well, there's more than supervisory billing documentation of the years.
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Yeah, there's, I mean, it's just like there's so much, there's so much that we're up against that's not that there's a lack of clarity on.
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And this particular piece, this incident two versus supervisory.
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I'm my spidey senses are being triggered with this when I see what's happening in Arizona, when I see what's going on in Michigan.
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And then again, to go back to Arizona for a moment, was that, and I really hope I'm not getting this wrong because I had forgotten about it until this very moment.
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So I'm going to talk about it, but that they wanted to change it so that the supervisor had to do the intake for their supervisee.
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And I remember seeing a lot of stuff, people freaking out in Facebook groups about this.
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And it feels like they're trying to hold us to incident two, that that is what they're doing, that the somehow the supervisor is qualified to create a treatment plan, but the associate is not, even though the associate is the one to be treating the person.
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Because incident two is a creation of Medicare, the way things work when commercial insurers borrow from CMS is they are allowed legally to morph it, adapt it, change it.
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There is no obligation under the law for them to use the exact same definition as a government payer.
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That's part of the problem.
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So they are within their rights legally to do that if they want to.
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Um, and yes, I think that is part of it.
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Although, to be honest, I'm just starting uh putting together my webinar for the research.
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So I'll have more research coming from both Arizona and Michigan.
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But I have worked with clinicians in both states, and one of the group owners in Arizona was like, How am I gonna do that?
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I I I'll never be able to see my own clients if I have to see everybody's all my supervisees' clients for the first time and develop treatment plans.
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And and you know, the the the vibe I get is well, not our problem.
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Oh, exactly.
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Exactly, exactly.
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And then just to offer more clarity on what recently transpired in Michigan, it got a lot of press.
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So Blue Cross Blue Shield, this is my understanding, I'm not an expert in this, but this is my understanding of what happened, is they Blue Cross Blue Shield of Michigan changed their policy to basically, and I think they're actually calling it incident to billing, they're not even calling it supervisory billing because I I I that's my understanding, they're not calling it that.
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But they're basically saying that if a clinician is provisionally licensed, that the only way that they can bill under a supervisor is if they work in a facility setting.
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Is that how you understand it?
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Well, like I said, I haven't had a chance to really this is so impromptu.
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And what with what with Aetna and Alma and CIQH and Data Spring and it's like I can't even keep up.
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And it's I'm sitting here going, it's summer, I want my vacation.
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This is supposed to be the slow time, right?
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Um, I do have it.
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It is a there's an FAQ dated June 1st, and it's called Incident 2 Services and Billing Professional, Frequently Asked Questions for Providers.
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Now, my guess is just looking at it, I mean, this is 11 pages.
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I've got it up on my big monitor here, which you can't see.
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But my guess is it's not specific to behavioral health.
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The way Blue Cross of Blue Shield, Michigan wrote it, it does not sound to me like they're even talking about behavioral health.
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And that's part of the problem with a lot of these payers, is they just hand down these policies.
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They're really meant for medical.
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We are such a small proportion, and everything is so different in mental health.
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And frankly, I don't think they want to even freaking bother with us, but we're just a thorn in their side, we're pesky.
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And so these policies that are 11 pages may have half a paragraph about behavioral health.
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And so I am gonna have to read it very, very carefully.
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But that is my understanding also, is that this is primarily facility-based community mental health and not private practice.
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And I think you bring up a this is a big point that I that I think you're bringing up, which is that hospitals or facilities are the predominant training sites for physicians.
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Yes.
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That makes sense if you're a physician, because that they are training sites.
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And I'm gonna come back to that in a moment, uh, talking about sort of some of the policy or model legislation I'm working on around this because I think it's an issue.
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But with mental health providers, specifically therapists, master's level, we don't our training sites are group practices and community mental health, but not as much facility-based settings.
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And not maybe substance abuse.
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Yeah.
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And then on top of it, my concern is we know across the country, like I just had Jessica Frick on from Pennsylvania.
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She was telling me that the community mental health centers in her community in Erie are all owned by insurance companies.
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So I go, all right, so BCBS of Michigan is now saying everybody has to train in a facility, basically, if you're provisionally licensed or working towards licensure.
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And what happens when all these facilities are owned by insurance companies, right?
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Well, I don't have the data on what Blue Cross Blue Shield, Michigan owns, but I can tell you that in Michigan, Michigan, it's one of those states where Blue Cross is the dominant payer.
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I think I saw a statistic somewhere that said something like 70% of Michigan is Blue Cross Blue Shield.
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Yeah, I mean it it feels like they're trying to put a chokehold on the whole pipeline, right?
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Um I'm sure that's not their intention.
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I'm sure that they would disclaim it as being their intention, but that is the result.
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Absolutely.
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Yeah, and then they they control everything, they could control training sites and models that you get to work on under.
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And it's gonna, in my opinion, my concern is the impact on clinical growth and getting actually like I'm not saying that you can't get quality supervision in a facility setting, but the But there aren't gonna be enough placements for everybody.
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No, there's no way that there's gonna be enough placements.
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And then, and and where are interns gonna work to get their hours?
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You know, like it exactly.
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And then when I see the language where Blue Cross Blue Shield is calling it incident two and not making that distinction, it it can it, I think it further confuses the conversation because I hear a lot of clinicians in like Facebook groups talking about incident two, and I'm like, we don't do incident two.
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I know.
00:21:58.319 --> 00:22:09.359
And I feel like I'm I'm like, I don't mean to be That argue person, but I like we need to get our terminology straight so that we can advocate for ourselves, so that we understand what we're fighting for.
00:22:09.519 --> 00:22:24.079
And that's really why I wanted somebody other than me to speak to the difference between incident two and supervisory billing so that we can be using the correct language when we're advocating for ourselves on these issues.
00:22:24.319 --> 00:22:36.079
And I wanted to talk a little bit too about my um, I went down this rabbit hole where I was trying to come up with like what could our argument be at the national level?
00:22:36.319 --> 00:22:42.799
The parity issue, in a lot of ways, is off the table because of stuff going on around those laws.
00:22:43.200 --> 00:22:45.200
Unless there's a state parody law.
00:22:45.359 --> 00:22:48.079
And um I you may have seen me look at my phone.
00:22:48.240 --> 00:23:01.119
My computer once again is crashing, and I was there's two documents from Blue Cross Blue Shield, Michigan, and one of them is called the Incident 2 FAQ, the other one is called supervisory updates.
00:23:01.279 --> 00:23:06.799
And I was trying to see if there was anything in there, and it's there's nothing in there, it's just a one-page.
00:23:06.960 --> 00:23:08.559
Hey, look at the FAQ.
00:23:09.440 --> 00:23:12.640
Um, so I I apologize for interrupting you on that.
00:23:12.880 --> 00:23:28.079
But yeah, um, unless Michigan or Arizona has some sort of really hard state parity law, parody is it would be nice if we could use it, but parody has become so toothless thanks to yeah, that's yeah.
00:23:28.160 --> 00:23:31.599
And in my research, what it said is basically this has to become a statute.
00:23:31.759 --> 00:23:34.240
Like we need to get to the level of a statute.
00:23:34.400 --> 00:23:40.319
And the argument in the It is a federal statute, but not for us, I think.
00:23:40.559 --> 00:23:45.119
Oh, no, mental health parity and equity act, MHP.
00:23:45.440 --> 00:23:50.160
Well, I'm talking about I'm talking about, I should back up and fully explain what I'm talking about.
00:23:50.319 --> 00:24:04.160
So my argument on this is that the systems, the government, everybody, and this is written into statute, the physician residency pipeline, right?
00:24:04.240 --> 00:24:08.559
There's an understanding, and it is built into our healthcare system.
00:24:08.640 --> 00:24:11.200
It's even funded by the government.
00:24:11.519 --> 00:24:14.559
They pay training hospitals for residents.
00:24:14.720 --> 00:24:22.640
So the training is paid for by the government that there's an understanding of what the training pipeline is for physicians in this country.
00:24:22.880 --> 00:24:30.079
There doesn't seem to be an understanding of the training pipeline for master, especially master's level mental health providers.
00:24:30.640 --> 00:24:48.400
No, no, we're expected to just work it out on our own, and that falls on the individual uh student, clinician who is expected to, you know, have huge student loans, internships not paid for, and in a lot of cases, associates probably aren't even making minimum wage in a lot of cases.
00:24:48.720 --> 00:24:52.000
And that's just kind of eh, too bad, so sad, figure it out.
00:24:52.079 --> 00:24:53.599
Uh, there's no support.
00:24:53.839 --> 00:24:54.799
You're absolutely right.
00:24:54.880 --> 00:24:56.000
And there needs to be.
00:24:56.319 --> 00:25:06.400
And now, if they're taking away our people's ability to do supervisory billing, which is really the only funding stream, which isn't, if you're being honest with yourself, is not a funding stream.
00:25:06.559 --> 00:25:07.839
It's just paying for the service.
00:25:08.000 --> 00:25:15.920
Like, we don't get billions of dollars in training subsidies from the federal government to help bring forward the next generation.
00:25:16.240 --> 00:25:18.000
You don't even get a dollar in subsidies.
00:25:18.079 --> 00:25:18.720
You get zero.
00:25:19.200 --> 00:25:20.000
We get zero.
00:25:20.319 --> 00:25:29.920
So my angle is that I mean, I guess it is kind of a parity argument where it's like we have this infrastructure built for physicians that's recognized.
00:25:30.160 --> 00:25:36.319
We need a separately recognized understanding of the training pipeline for mental health providers.
00:25:36.559 --> 00:25:39.599
And I it is a parody issue, but I think it goes beyond that.
00:25:40.000 --> 00:25:44.319
Well, it's a parody issue, but unfortunately it's not covered under the MHPAEA.
00:25:44.480 --> 00:25:45.200
So yeah.
00:25:45.519 --> 00:25:46.000
Exactly.
00:25:46.160 --> 00:25:46.400
Yeah.
00:25:46.720 --> 00:25:51.839
So in my research, it was talking about sort of a different angle, which I'm still investigating.
00:25:51.920 --> 00:26:00.480
But part of the reason I'm sharing this is because I recognize that I've had a few people tell me, I started listening to an episode of your podcast and I got really depressed.
00:26:00.559 --> 00:26:01.359
I think you were Susan.
00:26:01.759 --> 00:26:02.160
That was me.
00:26:04.240 --> 00:26:06.720
But you're not the only, you're not the only one that's doing that.
00:26:06.960 --> 00:26:11.279
And I try to all, you know, to amplify voices of people that are doing incredible work.
00:26:11.519 --> 00:26:17.680
But a lot of this stuff sucks, and people feel like, all right, well, boy, Siv, like, this is a lot.
00:26:17.759 --> 00:26:20.319
And now I now I'm feeling paralyzed.
00:26:20.480 --> 00:26:44.720
So the reason I'm talking about the policy work is because I want people to know that there are a lot of folks right now actively strategizing to figure out ways that we can legislatively start to find these gaps and these holes and push on them and come up with strong and creative arguments to help advance our work.
00:26:44.960 --> 00:26:45.200
Right.
00:26:45.279 --> 00:26:51.440
And that's what I try to do, like in my newsletter, is I try to focus on state-level positive developments.
00:26:51.599 --> 00:26:56.160
I haven't focused on this, but you might want to look at, and I can send it to you after we're done.
00:26:56.400 --> 00:27:01.759
Governor Kotek in Oregon put forward a whole training mental health thing recently.
00:27:01.920 --> 00:27:10.799
And I don't think it's been launched yet, but the proposal has been made to help fund the mental health pipeline in Oregon.
00:27:11.119 --> 00:27:17.680
And for instance, there was a very wonderful initiative that did pass in Illinois.
00:27:17.759 --> 00:27:30.720
It's going to be live January 1st, where insurance companies that operate within Illinois have to pay a minimum of 141% of Medicare to behavioral health clinicians.
00:27:30.880 --> 00:27:46.079
And there are already certain insurance companies who shall remain nameless who are actively working to get around that because I've already called them on it and been successful because they disclaimed that that was the reason.
00:27:46.160 --> 00:27:51.759
And I'm like, mm-hmm, we'll let the insurance, you know, commissioner in state of Illinois decide that.
00:27:51.839 --> 00:27:57.519
But in the meantime, you're not gonna, you know, do my clinician wrong, and yeah, you're gonna pay these claims.
00:27:57.599 --> 00:28:15.119
And I may or may not write more about that as we get closer to January 1st in Illinois, but you know, it seems like kind of for every move we make, the insurance companies and the venture capital, they're five, six, seven, eight steps ahead of us, they anticipate.
00:28:15.359 --> 00:28:23.359
And because they have the resources that we don't have, and also they don't have a lot of the legal constraints that we have.
00:28:23.519 --> 00:28:29.200
Like, for instance, the constraint against collective bargaining, they are able to do so much more, and it is depressing.
00:28:29.279 --> 00:28:30.640
It's depressing as heck.
00:28:30.880 --> 00:28:36.079
There's times I even get depressed, and and I'm just like, oh my God, this is just, you know.
00:28:36.880 --> 00:28:37.839
And there's a lot.
00:28:37.920 --> 00:28:43.359
I mean, like you were you were kind of joking about like CAQH turning into data spring and this happening and that happening.
00:28:43.519 --> 00:28:45.839
And there were there's a lot being thrown at us.
00:28:46.000 --> 00:28:50.720
And I I I understand that like it can feel really overwhelming.
00:28:51.039 --> 00:29:01.920
And I have to be honest, like both you and I, I mean, Susan, poor Susan got booted out of Zoom for the last task force meeting, but there were like a hundred and some people there.
00:29:02.640 --> 00:29:05.279
I mean, to me, that's amazing from all over.
00:29:05.519 --> 00:29:08.160
I think we actually have representation now in all 50 states.
00:29:08.319 --> 00:29:16.400
Woohoo! So I want people to know, like, yeah, there is a lot of stuff coming down that is, and I try to highlight because I want people to be educated.
00:29:16.480 --> 00:29:24.240
I don't want to freak you out, but we need to understand this stuff and you know, have your, you know, moments of grief and anger.
00:29:24.400 --> 00:29:24.799
Do it.
00:29:24.960 --> 00:29:29.200
I feel that way, and recognize that we can sit in that.
00:29:29.359 --> 00:29:30.880
I'm gonna sound like a therapist here.
00:29:31.039 --> 00:29:34.000
We can sit in that, or we can use that to fuel our action.
00:29:34.079 --> 00:29:39.279
And what I'm trying to do for myself is use it to fuel action.
00:29:39.440 --> 00:29:40.720
How do we push this?
00:29:40.880 --> 00:29:43.839
How do we like come together and strategize?
00:29:44.000 --> 00:29:46.799
And so I want you people to know that that is happening.
00:29:47.039 --> 00:29:49.119
And I just found out about a bill.
00:29:49.200 --> 00:29:55.680
I don't want to get it wrong, so I'm gonna open my email right quick because I sent it to somebody recently in my email.
00:29:55.759 --> 00:30:01.920
But there is something slowly, as things are, slowly moving through Congress.
00:30:02.079 --> 00:30:03.519
I'm gonna see if I can find.
00:30:03.759 --> 00:30:09.519
Are you talking about the um Elizabeth Warren and Josh Hawley um breakup big medicine?
00:30:09.839 --> 00:30:10.720
Is that the one you're talking about?
00:30:11.119 --> 00:30:12.880
This is, I found it.
00:30:13.039 --> 00:30:21.200
It's House Resolution 8081, which is the Mental Health Access and Provider Support Act of 2026.
00:30:21.440 --> 00:30:23.119
Oh God, please send that to me.
00:30:23.359 --> 00:30:24.720
I will forward this to you.
00:30:25.200 --> 00:30:26.720
No, I hadn't I hadn't heard of that one.
00:30:26.880 --> 00:30:28.240
I hadn't heard about it either.
00:30:28.319 --> 00:30:33.519
I'm opening it here real quick because I believe that because there's two different bills.
00:30:33.680 --> 00:30:34.640
It's very timely.
00:30:34.799 --> 00:30:54.880
If if you've read my my current blog series that's coming out in parts, the last one that I just did uh was about it had a lot to do with our Medicare rate, the 75% CMS rate that we are at, how we got there, I will say, because I'm such a fan of Susan and she's knows so much about this.
00:30:55.119 --> 00:30:59.039
Before we recorded, she was like, I just read that piece and you nailed it.
00:30:59.200 --> 00:31:00.160
So I felt really good.
00:31:00.240 --> 00:31:03.759
I felt like, oh, good, I did a good job because Susan approved of it.
00:31:04.000 --> 00:31:10.640
But the text of this house resolution basically would lift us all up to the 85% range.
00:31:10.880 --> 00:31:12.240
Oh my, that's amazing.
00:31:12.400 --> 00:31:14.079
But I just found out about that.
00:31:16.960 --> 00:31:18.640
I believe PAs get that.
00:31:18.880 --> 00:31:21.920
Dieticians you had in your article get that.
00:31:22.160 --> 00:31:40.400
There's no reason for us to be at 75%, other than that 1989 compromise that you mentioned in your article, which really triggered a lot of memories for me because I was in social work school at the time that was being hammered out, and everybody was like, woohoo, look at us, aren't we, aren't we wonderful?
00:31:40.480 --> 00:31:41.039
Blah, blah, blah.
00:31:41.119 --> 00:31:47.200
And it's like the only reason they grade to it was so that it would pass politically, which, okay, that's fine.
00:31:47.279 --> 00:31:51.839
I'm sure they intended to do better uh later on, and it just never happened.
00:31:52.000 --> 00:31:58.480
And so at this point, we're essentially doing something because we've always done it with no other re reason.
00:31:58.799 --> 00:31:59.200
Mm-hmm.
00:31:59.359 --> 00:32:00.240
Yeah, absolutely.
00:32:00.400 --> 00:32:05.200
And I wanted people to know about it because I think that this is an opportunity.
00:32:05.359 --> 00:32:08.799
It's on people's radar at the house level, at least.
00:32:09.119 --> 00:32:11.839
So make a little mental note.
00:32:11.920 --> 00:32:25.119
If you're listening to this podcast, write it down, contact your your state rep or your house representatives and find out more information so that we can unify around this because it's already a house resolution, Bill.
00:32:25.440 --> 00:32:26.000
Potential.
00:32:26.319 --> 00:32:32.319
One suggestion when you contact your rep, especially if you don't work with Medicare.
00:32:32.480 --> 00:32:47.279
And if the reason you don't work with Medicare is because you feel like the reimbursement rate is too low, then point that out that so many more people would be willing to work with Medicare if they could be sure of getting a better rate.
00:32:47.519 --> 00:32:55.839
And that would open up access, keyword, key, key term, access to more people with Medicare.
00:32:56.079 --> 00:33:01.119
And this is really important because you know, I do a lot of education about Medicare.
00:33:01.440 --> 00:33:07.920
I help a lot of people get enrolled, I help a lot of people try to decide is it better to enroll, is it better to opt out?
00:33:08.319 --> 00:33:20.720
And let's face it, we're all getting older, and I think I read that by 2030 it's gonna be like 20% of the population is Medicare eligible.
00:33:20.880 --> 00:33:25.359
And so that's gonna be a big issue for legislators.
00:33:26.079 --> 00:33:28.720
It's interesting that you're bringing that up, Susan.
00:33:28.960 --> 00:33:32.319
Yes, I found out about another thing happening.
00:33:32.480 --> 00:33:43.440
Yes, I don't know where it is, but it's in the Senate, uh, number 683, which is called More Behavioral Health Providers Act of 2025.
00:33:43.839 --> 00:33:55.759
And this bill provides for additional Medicare payments to healthcare practitioners who provide services in mental health professional shortage areas for individuals with mental health or substance use disorders.
00:33:56.079 --> 00:33:57.359
Did it apply?
00:33:57.759 --> 00:33:58.880
It's just hanging out.
00:33:59.039 --> 00:34:09.199
This bill applies to physicians, physician assistants, nurse practitioners, clinical nurse specialists, clinical social workers, clinical psychologists, marriage and family therapists, and mental health counselors.
00:34:09.519 --> 00:34:12.960
It's been introduced, but that's all that I've learned about.
00:34:13.119 --> 00:34:14.880
Well, that's that's interesting.
00:34:14.960 --> 00:34:17.920
I would love information about that to write on that as well.
00:34:18.159 --> 00:34:28.559
Right now, the only category of clinician that can get extra payment for practicing in a hipsa, a health care health provider shortage area, is a psychiatrist.
00:34:29.039 --> 00:34:32.880
No other practitioner in behavioral health can get that.
00:34:33.199 --> 00:34:35.519
So what they're trying to do is change the language.
00:34:36.400 --> 00:34:44.000
Like 75% of this country is a mental health hipsa, and you can look it up to see if you are in one.
00:34:44.239 --> 00:34:46.880
Believe it or not, I mean, you know where I am, Civy.
00:34:46.960 --> 00:34:49.760
Uh Olympia, I'm in a hipsa.
00:34:50.239 --> 00:34:55.039
I'm I'm a 16-17 score, and it's scored on a 25.
00:34:55.280 --> 00:35:01.599
And I think anything over like, I can't remember, is it 12 or 15 is considered a hipsa.
00:35:01.840 --> 00:35:05.679
And they specifically break it out to like primary care, dental, and mental health.
00:35:05.840 --> 00:35:06.800
Those are the only categories.
00:35:07.039 --> 00:35:10.320
Are they only counting psychiatrists or psychiatric nurse practitioners?
00:35:10.480 --> 00:35:20.159
I would have to go back and and read the site, but yeah, it's possible that if they only reimburse psychiatrists, then that's all they count.
00:35:20.239 --> 00:35:29.440
And of course, psychiatrists, I mean, I think the statistic is like, you know, four in five psychiatrists don't take Medicare, don't take insurance.
00:35:29.679 --> 00:35:32.239
So yeah, that would definitely make sense.
00:35:32.480 --> 00:35:42.079
Yeah, and I will try to remember to put links to the texts of these things in that are in motion in the show notes so that people can.
00:35:42.239 --> 00:35:44.000
There's not a whole lot, they're very short.
00:35:44.079 --> 00:35:48.960
Like the text is basically like strike out this paragraph and put in this paragraph.
00:35:49.119 --> 00:35:51.519
Like it's very minimal at this point.
00:35:51.760 --> 00:35:58.400
But I think that we need to know, like, I've been involved in this advocacy work for a while, and it was kind of accidental.
00:35:58.559 --> 00:36:03.199
I don't even remember how I found about about it, where I was like, wait a minute, where did this come from?
00:36:03.360 --> 00:36:04.800
I didn't even know about this.
00:36:05.039 --> 00:36:17.440
So I think it's important to see what is already being pushed forward so that we can rally behind it instead of everybody kind of doing their own thing and not like knowing what everybody else is doing so that we can.
00:36:17.760 --> 00:36:20.559
Um there is another resource that's really valuable.
00:36:20.639 --> 00:36:22.880
Um, are you familiar with the group Inseparable?
00:36:23.119 --> 00:36:23.360
Yes.
00:36:23.599 --> 00:36:23.679
Okay.
00:36:24.639 --> 00:36:57.280
Tell people about it because they They published a workforce report, I think in April, maybe in March, and they went state by state, all 50 states, and I think maybe even DC, and they talked about the mental health landscape in each state and where they kind of broke it apart into four or five different areas that they think are are most urgently needed for intervention to improve the situation, and they sort of ranked all states by kind of their progress towards that and any bills that are pending on the state level.
00:36:57.519 --> 00:37:00.000
And um, it's it's really very enlightening.
00:37:00.239 --> 00:37:00.559
Okay.
00:37:01.119 --> 00:37:02.320
So inseparable.
00:37:02.719 --> 00:37:03.440
Inseparable.
00:37:03.599 --> 00:37:08.000
It's it's the 2026, excuse me, inseparable workforce report.
00:37:08.239 --> 00:37:09.440
That's great information.
00:37:09.679 --> 00:37:12.159
You had me write down United, and I just want to look.
00:37:12.719 --> 00:37:13.440
I'm trying to read it.
00:37:13.599 --> 00:37:16.480
Okay, so with supervisory billing and united healthcare.
00:37:16.639 --> 00:37:16.880
Okay.
00:37:17.119 --> 00:37:25.599
Currently there are only four states where United has to provide, has to allow supervisory billing.
00:37:25.760 --> 00:37:27.840
And that's because of state statute.
00:37:28.000 --> 00:37:29.039
There's only four.
00:37:29.280 --> 00:37:38.480
It is California, Iowa, Massachusetts, and I'm writing these down because I've been I was talking with the Washington Mental Health Commission.
00:37:38.719 --> 00:37:39.360
It's not Washington.
00:37:40.000 --> 00:37:49.280
Well, no, I brought it up at their pol policy and professional advocacy committee as a point that I think we need to be trying to get on a state level.
00:37:49.440 --> 00:37:50.719
And they're totally game.
00:37:50.800 --> 00:37:54.719
So I'm frantically writing down the state names so that we can look at model levels.
00:37:54.880 --> 00:37:55.599
I I can get you that.
00:37:55.760 --> 00:37:58.000
I can get you the other um state.
00:37:58.320 --> 00:38:10.400
Anyway, United's policy is that in those states, any in-network provider, in network only, can provide reimbursable supervisory billing.
00:38:10.559 --> 00:38:19.119
Outside of those four states, you cannot, it is not covered unless you get a special addition to your contract.
00:38:19.280 --> 00:38:25.360
So you can only be a group, and then the problem is you have to be a big enough group.
00:38:25.519 --> 00:38:28.079
They never really define big enough.
00:38:28.400 --> 00:38:44.239
And then my understanding is they do some sort of like pre-audit and they look at how you document, and you have to come up, you have to meet a certain standard, but I haven't been able to ever find that information because it's all behind you know login walls and things like that.
00:38:44.559 --> 00:38:50.800
And I would have to, I guess, work with a group that had that kind of contract and they could maybe tell me.
00:38:50.880 --> 00:38:56.480
So if anybody's listening and feels like they want to, you know, share that information, you can, you know, reach out to me.
00:38:56.639 --> 00:39:05.119
But the problem is a lot of groups have approached United and they're told they're not big enough, or we're not doing that anymore, or we've got everything we need.
00:39:05.360 --> 00:39:06.880
Because guess what?
00:39:07.360 --> 00:39:15.920
One of the recent developments that's been overlooked in all the drama is that Headway just announced that they're sponsoring supervisory billing.
00:39:16.320 --> 00:39:17.760
You can't see me rolling my eyes.
00:39:17.920 --> 00:39:19.920
I can see you rolling your eyes.
00:39:21.599 --> 00:39:25.599
Except in Michigan, I guess, unless they become a facility too.
00:39:26.079 --> 00:39:29.679
Well, they're working on it because of Medicare Access, which I know.
00:39:29.760 --> 00:39:33.039
That's why I kind of said that to like spur that part of the conversation.
00:39:33.840 --> 00:39:37.840
Can you help people understand sort of that access thing if you as much as you know about it?
00:39:38.239 --> 00:39:40.880
Um it's actually a blog on my website.
00:39:40.960 --> 00:39:43.360
I think I came out with it the last week in April.
00:39:43.440 --> 00:39:46.480
It's called Finding the Value in Value-Based Care.
00:39:46.639 --> 00:39:59.199
It goes into what is value-based care, what's how Medicare has derived this, what are their criteria for this program called Access, which is essentially what they're trying to do.
00:39:59.360 --> 00:40:04.880
They're trying to pay for outcomes, not a 908.34, a 908.37.
00:40:05.039 --> 00:40:08.800
They're trying not fee for they're trying to go away from fee for service.
00:40:09.119 --> 00:40:09.599
Correct.
00:40:09.840 --> 00:40:10.159
Okay.
00:40:10.719 --> 00:40:17.920
So you have to have enough scale to be able to sign up as a provider for access.
00:40:18.800 --> 00:40:47.760
And honestly, the I looked at the list when I did the blog, and as of like April 23rd, and um, they the deadline didn't close till May 15th, so there may have been other people who joined after I did my blog, but the platforms that have signed up that I knew about Headway, Sondermind, something called Innerwell, which specializes in at-home ketamine treatment, which I'm just like, how can that even be safe?
00:40:47.920 --> 00:41:05.760
And I have a note venture capital, but no known insurer investment, Isaac Health, which specializes with dementia and caregivers, insurer investors, care source and intermountain healthcare, Sondermind, we all know about Sondermind, and then something called Total Life.
00:41:06.239 --> 00:41:13.599
They have an insurer investor, G-E-H-A, and other investors of note, Google and Charm EHR.
00:41:13.840 --> 00:41:22.239
So those are the platforms, and then there are a whole slew, just a slew of AI and tech.
00:41:22.639 --> 00:41:27.920
Headspace is one, um, slingshot AI, which is just basically a chat bot.
00:41:28.079 --> 00:42:00.800
And then they have this thing which kills me called, I was telling you about it before we started recording, called Meo Mind, where all they do is they pedal session recordings or transcripts and they sell them to third parties with the goal of somehow that if I'm Civvy's client and some third party listens to our session, that they can get some sort of like I'm forgetting the word, like some sort of at one hand remove, they can get some sort of um like through osmosis.
00:42:00.880 --> 00:42:01.280
They'll get it.
00:42:01.679 --> 00:42:07.360
Through osmosis, they can get some sort of benefit, but of course, there's no reimbursement to Civi for that.
00:42:07.679 --> 00:42:12.639
And I it's supposedly de-identified, and supposedly they ask for permission.
00:42:12.719 --> 00:42:15.440
And I'm just, to me, it's just horrifying.
00:42:15.599 --> 00:42:17.199
It's just absolutely horrifying.
00:42:17.360 --> 00:42:23.280
And their website claims that clients give consent for their therapy sessions to be recorded and published.
00:42:23.360 --> 00:42:24.000
I wonder.
00:42:24.159 --> 00:42:26.239
I'm not a lawyer, I'm not an ethicist.
00:42:26.480 --> 00:42:27.440
Informed consent.
00:42:27.519 --> 00:42:30.719
I I don't know any more than anybody else, but I just really wonder.
00:42:31.119 --> 00:42:38.320
Well, I'll be honest, this informed consent, I think on both sides for a lot of this shit, is under duress.
00:42:38.639 --> 00:42:44.880
Because if it's like, well, in order to see your therapist, you have to sign this.
00:42:45.360 --> 00:42:51.199
How is that not signing something under duress if you're saying I can't receive services unless I agree?
00:42:51.599 --> 00:42:53.519
Even more subtle and more gentle than that.
00:42:53.599 --> 00:43:05.039
I I put this on LinkedIn, so it's not exactly private, but I saw a nurse practitioner during COVID for depression, and I had one of those policies that waived patient responsibility for telehealth.
00:43:05.119 --> 00:43:08.400
And of course, I have you know really super high deductible being self-employed.
00:43:08.559 --> 00:43:10.480
So, you know, I was taking advantage of it.
00:43:10.639 --> 00:43:16.239
And I mean, I'm well educated, I've got an MSW, I've been billing since 1998.
00:43:16.400 --> 00:43:18.960
I certainly know my way around this system.
00:43:19.519 --> 00:43:29.199
And when the nurse practitioner came on telehealth, she said, you know, I use this AI recording model, and it helps me help you.
00:43:29.760 --> 00:43:35.039
And I think that was probably the first time I heard about AI recording models, and that was now six years ago.
00:43:35.360 --> 00:43:43.039
And, you know, I was going through depression, I had a lot of anxiety, and just the phrase, it helps me help you.
00:43:43.199 --> 00:43:54.079
Well, I don't want to like get in my way of my therapist helping me, so of course I'm going to say yes, but did I get any kind of assurance of anything?
00:43:54.400 --> 00:43:54.719
No.
00:43:55.440 --> 00:43:59.760
And I said yes because I felt like to say no would be to.
00:44:00.639 --> 00:44:02.559
Number one, disrupt my treatment.
00:44:02.639 --> 00:44:03.679
Number two, displease her.
00:44:03.760 --> 00:44:06.000
And let's face it, there is a power dynamic.
00:44:06.400 --> 00:44:13.440
And if somebody with a master's in social work feels that way, how do you think you know 98% of the people out there are gonna react?
00:44:13.519 --> 00:44:16.960
They're gonna be like, okay, I understand, even if they feel uncomfortable about it.
00:44:17.119 --> 00:44:24.800
And in fact, NPR had a big article recently about that where they interviewed somebody who felt that way about her therapist.
00:44:24.960 --> 00:44:28.639
She gave consent and she was really uncomfortable with it.
00:44:28.960 --> 00:44:40.480
And um, that's I I that's when I, you know, disclosed all this personally because I posted that uh link to the NPR article and I said, look, this is my story, and I totally believe this.
00:44:40.559 --> 00:44:48.559
And people aren't recognizing in the informed consent that there is a power differential between the clinician and the client.
00:44:48.880 --> 00:44:55.760
And you know, then you bring up this whole duress thing about, well, you know, if you're working for a platform, you may not have a choice.
00:44:56.000 --> 00:44:59.280
You you either use AI or you don't get service or you don't get paid.
00:44:59.599 --> 00:45:02.639
Yeah, and now Headway wants biometric data.
00:45:03.440 --> 00:45:05.360
Yeah, I'm sure you heard about that too.
00:45:05.679 --> 00:45:06.239
Oh, yeah.
00:45:06.400 --> 00:45:07.360
I heard about that.
00:45:07.599 --> 00:45:08.239
Oh yeah.
00:45:08.960 --> 00:45:12.800
Yeah, I mean, that's how is that I'm not under duress where it's like, well, what am I gonna do?
00:45:13.199 --> 00:45:14.719
If I'm already here, what am I gonna do?
00:45:14.800 --> 00:45:16.480
Now they're asking for biometric data.
00:45:16.800 --> 00:45:19.280
So either I can give it to them or stop getting care here.
00:45:19.920 --> 00:45:25.760
I feel like what they're weaponizing is something that came out many, many years ago called the red flag rules.
00:45:26.639 --> 00:45:35.440
Um the red flag rules many years ago were a kind of it was the intention was to prevent identity theft in healthcare.
00:45:36.239 --> 00:45:47.199
So, like if you've ever gone to a doctor and they take your picture so that they can verify that you are the same person as on your identification, that's what that's for.
00:45:47.920 --> 00:45:56.239
I feel like Headway is using that and sort of manipulating it to God knows what end.
00:45:56.320 --> 00:46:04.639
I mean, don't they have some sort of lawsuit pending against data breaches with Google or Google something?
00:46:04.880 --> 00:46:05.519
I don't even know.
00:46:05.599 --> 00:46:31.519
I'm not a cybersecurity expert, but it just seems to me like their their justification is you know preventing identity theft, and it's got this precedent in these very old set of rules, and yet it's I mean, these these rules go back 20 years long before AI and they were never meant for an AI telehealth kind of system.
00:46:32.480 --> 00:46:41.119
Um, they were meant for an in-person system, and they're taking it and just kind of running with it because there's no there's nobody to stop them.
00:46:41.679 --> 00:46:45.519
Yeah, they're like, oh, it's an opportunity because hey, I can we can capture this.
00:46:45.679 --> 00:46:51.760
How they're gonna use that is probably in the fine print that nobody if it's even there.
00:46:52.000 --> 00:46:58.960
And speaking of headway, I want to go back to something that you said about because they are they were on the access model list for Medicare.
00:46:59.280 --> 00:47:02.400
And you also said that they're now doing supervisory filling.
00:47:03.039 --> 00:47:07.519
And the whole part with the access was the value-based care.
00:47:07.599 --> 00:47:15.199
It's also my understanding, though, that with at least this stuff through from Blue Cross Blue Shield, I'm kind of going full circle here.
00:47:15.360 --> 00:47:21.599
The Blue Cross Blue Shield stuff in Michigan, I think it was under that that I was seeing that, or maybe it wasn't through that.
00:47:21.679 --> 00:47:31.360
I'm confusing myself, but that under the access model, supervisory billing does not get paid for the value-based care piece.
00:47:31.760 --> 00:47:34.480
Well, it can't because this is Medicare.
00:47:34.639 --> 00:47:36.639
Medicare doesn't cover supervisory billing.
00:47:36.960 --> 00:47:38.559
So, how is Hedwig in a circle?
00:47:38.719 --> 00:47:42.960
I mean, so they're just they just won't uh access is only for people with Medicare.
00:47:43.119 --> 00:47:47.280
So for supervisory billing, if you have Medicare, you don't qualify for that.
00:47:47.599 --> 00:47:47.920
Okay.
00:47:48.400 --> 00:47:49.280
All right, folks.
00:47:49.440 --> 00:47:54.000
This has been a second edit because uh more technical difficulties.
00:47:54.079 --> 00:48:00.960
And Susan and I were just joking that maybe like AI is trying to shut this interview down because it doesn't like where it's going.
00:48:01.119 --> 00:48:08.639
And and we're being spied on right now by some investor-backed, like venture capitalist-backed something here.
00:48:08.960 --> 00:48:11.519
So if we're gonna get this out if it kills us.
00:48:11.679 --> 00:48:14.719
Yeah, if you don't hear from us, you'll know what happened.
00:48:14.880 --> 00:48:16.559
I'm gonna preserve the recording.
00:48:16.719 --> 00:48:20.320
Um, this is this is what you know, the voice of the resistance.
00:48:20.639 --> 00:48:21.360
Yeah, I know.
00:48:21.679 --> 00:48:24.239
I've never had this many tech issues in an interview.
00:48:24.400 --> 00:48:24.559
Never.
00:48:24.880 --> 00:48:25.440
Me neither.
00:48:25.679 --> 00:48:26.320
It's nuts.
00:48:26.400 --> 00:48:30.639
It does feel like is are we being watched right now that they don't want Susan to speak?
00:48:30.800 --> 00:48:32.079
That's what I think is happening.
00:48:32.239 --> 00:48:41.519
But, you know, I think what I was saying, because I've lost track of myself a million times now, is that we were talking about Headway and supervisory building and how Hedway wants to be a facility.
00:48:41.599 --> 00:48:53.760
And I said, but Hedway like tries to walk the bridge because they are trying to be billing, saying that they're a billing service to get people on, but then they're really so much more and so much more into control.
00:48:54.159 --> 00:49:06.960
And you were talking about kind of how at the beginning they appeared like they were a solution, and so it was easy for people to kind of under kind of, oh, this will be the answer to all my administrative problems.
00:49:07.280 --> 00:49:16.159
Yeah, and I think that again, I know what I was talking about that people weren't looking at that long game of what is what are they, what is their plan for this?
00:49:16.320 --> 00:49:24.880
Because if they're getting gazillions of dollars in venture capital, all these companies are getting all these like series A funding.
00:49:25.199 --> 00:49:29.199
I don't even know what all that series crap is, but I don't understand it.
00:49:29.280 --> 00:49:39.760
It's just series A is like your first round of funding, and then you have to show like profitability or potential enough, and then series B is like they pump more money into you.
00:49:40.079 --> 00:49:41.119
And I think that's what it means.
00:49:41.199 --> 00:49:41.760
I don't really know.
00:49:42.480 --> 00:49:53.280
But yeah, that there is an endgame here that people don't want to talk about, and that I understand in the short term, people are like, I have to pay my mortgage, I have kids, I have like I have like, what do you want me to do?
00:49:53.360 --> 00:50:18.000
And I totally get that, but we're we're starting to see what's happening, and it it's I think it's they now feel so safe, it feels kind of blatant at this point because they have gotten tens of thousands, tens of thousands of providers on I'd say it's probably more like hundreds of thousands at this point.
00:50:18.320 --> 00:50:26.480
Yeah, and so they're in a position where they they carry the market, they deeply influence the pipeline.
00:50:26.800 --> 00:50:29.679
We can't challenge them with a marketing budget.
00:50:29.920 --> 00:50:33.599
We can't, I mean, how do you step up against headway for a marketing budget?
00:50:33.840 --> 00:50:37.760
Well, and they know that we're legally constrained and can't collectively bargain.
00:50:37.920 --> 00:50:38.320
Mm-hmm.
00:50:38.559 --> 00:50:38.960
Mm-hmm.
00:50:39.840 --> 00:50:44.079
So I just want folks, you know, a big part of this podcast is education.
00:50:44.320 --> 00:50:49.360
And if you know folks that are still holding tight to these platforms, maybe have them listen to this episode.
00:50:49.519 --> 00:50:50.880
All the episodes would be great.
00:50:51.199 --> 00:50:54.480
I'm not here to shame people or make you depressed.
00:50:54.800 --> 00:50:57.440
Because again, I know this stuff is depressing.
00:50:57.760 --> 00:51:05.599
But we have to face what's happening because they're already 20 steps ahead of us.
00:51:05.920 --> 00:51:09.039
And there are many of us that are coming together.
00:51:09.360 --> 00:51:10.480
Get involved.
00:51:10.800 --> 00:51:13.679
Go to buildbetterhealth.org.
00:51:14.000 --> 00:51:17.840
Sign up to get engaged in the mental health insurance reform task force.
00:51:18.079 --> 00:51:31.760
If you're like, I don't know how to do any of that, just reach out and say, hey, who's the state lead from my state so I can connect with them so that like I can at least know what's going on and be involved to whatever extent that you feel like you can.
00:51:32.000 --> 00:51:38.800
There are hundreds of people at this point across the country that aren't just joining a membership group.
00:51:38.880 --> 00:51:43.360
They're actively engaged and we're strategizing.
00:51:43.519 --> 00:51:45.199
And I want people to hear that.
00:51:45.440 --> 00:51:59.440
We are strategizing right now on federal policy, linking up states with each other who have passed, like what happened in Illinois with that 141% rate, that law that got passed.
00:51:59.679 --> 00:52:08.079
Um, how do we connect that information to other states, which is what the state leads are kind of doing, is trying to disseminate information to their states.
00:52:08.400 --> 00:52:11.280
So there is a coalition building.
00:52:11.519 --> 00:52:25.280
I don't want people just to sit in the despair of what feeling like they're watching their profession collapse and have a corporate takeover because there are people that are working together across discipline, right?
00:52:25.519 --> 00:52:28.400
We would love for our professional associations to be doing this.
00:52:28.559 --> 00:52:30.079
The reality is they're not.
00:52:30.239 --> 00:52:31.599
They're probably not going to.
00:52:31.760 --> 00:52:32.480
This is where we are.
00:52:32.639 --> 00:52:34.480
Well, there's we can set an example.
00:52:34.639 --> 00:52:35.679
We can set an example.
00:52:35.920 --> 00:52:37.199
Yeah, there's a little bit of hope.
00:52:37.440 --> 00:52:48.880
Two APAs, American Psychology, Psychological and American Psychiatric, got together and wrote an R uh letter to Aetna about Alma, Aetna, the, you know, reimbursement rate.
00:52:49.039 --> 00:53:00.719
I mean, yeah, it's probably, I'm not gonna say it's token, but I don't expect it's gonna have any impact because professional associations have been, you know, by and large, relatively ineffective.
00:53:00.960 --> 00:53:11.199
But what mental health insurance reform task force is doing is is much more grassroots, and they have um legal experts that they're consulting with.
00:53:11.280 --> 00:53:13.519
You know, they have technical experts that they're consulting with.
00:53:13.679 --> 00:53:14.880
That's why I signed on.
00:53:15.039 --> 00:53:39.039
I'm not here to promote my business because I've got plenty of business, but the credentialing, I've got credentialing webinars on my website, but I've also got behind a membership platform one whole module of several lessons on credentialing that I think I'm gonna turn into a product that's a single, single, you know, you don't pay a membership, it's just a one-time thing, and it's literally everything you need to know about credentialing and contracting.
00:53:39.199 --> 00:53:40.559
It's it's ready to go.
00:53:40.639 --> 00:53:48.880
I just need to actually like get it, export it out of where it lives now, put it into a format like a PowerPoint and put it on my website.
00:53:48.960 --> 00:53:55.920
I mean, and and if not me, I mean, there's a million other people that can help you with credentialing and contracting.
00:53:56.000 --> 00:54:06.559
And at this point, as rates on the platforms are going to start to fall, you'll find that the rates on the platforms aren't going to be any better than the rates off the platforms.
00:54:06.800 --> 00:54:07.920
Yeah, and I love that.
00:54:08.000 --> 00:54:13.679
And I also because we are pretty much out of time for this episode, I do want you to speak.
00:54:13.840 --> 00:54:15.840
You you you mentioned it at the beginning.
00:54:16.000 --> 00:54:21.679
A big part of me having you back on the show so quickly was because I do want to amplify what you're doing.
00:54:21.760 --> 00:54:24.639
And you have a webinar scheduled for July 17th.
00:54:25.039 --> 00:54:30.079
Can you give people a little and there'll be a link in the show notes on how to register for that and all of that?
00:54:30.159 --> 00:54:31.440
But yes, well, a sense of.
00:54:32.079 --> 00:54:40.159
So if if people aren't able to attend, you can register and get the recording and the handouts after the fact, or you can buy it in my web store.
00:54:40.320 --> 00:54:44.639
It's always the same price, whether live or you buy it on demand.
00:54:44.880 --> 00:54:48.800
It's called Stop Stumbling Over Supervisory Billing.
00:54:48.960 --> 00:54:55.280
It's gonna start with the whole incident two versus supervisory thing that Cidy and I were talking about.
00:54:55.679 --> 00:55:02.239
And then it's going to go into how do you document supervisory billing?
00:55:02.480 --> 00:55:12.000
I've worked with documentation experts to come up with what I recommend as a documentation standard to protect yourself against audits.
00:55:12.320 --> 00:55:15.599
How do you keep yourself audit safe?
00:55:15.840 --> 00:55:18.239
How do you recognize the audit triggers?
00:55:18.480 --> 00:55:24.079
How do you look at or understand when you can do this and when you can't?
00:55:24.400 --> 00:55:27.280
Because even, I'll give you an example.
00:55:27.440 --> 00:55:34.400
Even let's say Aetna, where you can do supervisory billing and it's pretty much across the board and they're hands off.
00:55:34.559 --> 00:55:42.800
There are certain policies you can't, because there are certain policies, well, not for one, Aetna Medicare Advantage, you can't do it there.
00:55:43.039 --> 00:55:54.239
Another one would be what's called self-funded plans, because self-funded plans often are handled by an administrator, like let's say Maritain, which is owned by Aetna.
00:55:54.800 --> 00:56:00.559
But if that employer who determines what's covered, that's what self-funding means.
00:56:00.639 --> 00:56:02.480
The employer gets to design the plan.
00:56:02.639 --> 00:56:05.760
The employer might say, Well, we don't want to pay for supervisory billing.
00:56:05.920 --> 00:56:06.480
Now what?
00:56:06.559 --> 00:56:09.039
Your supervisory billing, and then you find out after the fact.
00:56:09.119 --> 00:56:22.400
So it's gonna be it's gonna get into a lot of the ethical, sticky issues and how as a practice owner you can do the best you can to keep yourself safe and make decisions, what to think about.
00:56:22.719 --> 00:56:23.280
Fantastic.
00:56:23.440 --> 00:56:26.400
I'm like, ooh, I need to take that because I'm probably doing stuff wrong.
00:56:26.559 --> 00:56:29.199
I hope I'm not, but I probably am.
00:56:29.440 --> 00:56:34.239
So I'm definitely, I'll probably do the on-demand though, because my schedule is I'm it's so hard for it.
00:56:34.400 --> 00:56:37.840
Well, and to be honest, um, I'm expecting this to sell out.
00:56:38.079 --> 00:56:47.199
So if people can't attend live, I'd ask that you maybe do it on demand because I have my Zoom license only allows a certain number of people at night.
00:56:47.360 --> 00:56:51.039
I haven't looked at registrations lately, but it we're still more than a month out.
00:56:51.119 --> 00:56:53.360
Um, and it's obviously gonna get some publicity.
00:56:53.440 --> 00:56:55.519
So Sivy, you're gonna fill my room, right?
00:56:55.920 --> 00:56:56.639
That's the goal.
00:56:56.800 --> 00:56:57.519
That's the goal.
00:56:57.760 --> 00:56:58.320
Yeah, yeah.
00:56:58.480 --> 00:57:04.079
And yeah, it's it's it's meant to kind of shed some light on this.
00:57:04.239 --> 00:57:20.719
I mean, this is a poorly documented, and yeah, whether we want to sit here and say it's by intention or just because insurance companies are primarily focused on medical and we're the afterthought, you know, the redheaded stepchild, whatever you want to call it.
00:57:20.880 --> 00:57:34.559
Whether, I mean, you can you can think about conspiracy theories, you can get angry, you can not get angry, but the reality is we're still left with no documentation, no expectations, no understanding, no guidance.
00:57:34.719 --> 00:57:43.360
And let's face it, calling customer service and asking customer service is not going to get you what you need because they don't know.
00:57:43.760 --> 00:57:44.960
Yeah, they have no clue.
00:57:45.119 --> 00:57:46.559
I mean, we have no clue.
00:57:46.800 --> 00:57:51.840
Anyone that's called a provider rep at any insurance company knows that.
00:57:52.000 --> 00:57:54.079
That is absolutely 100%.
00:57:54.719 --> 00:57:55.199
Right.
00:57:55.519 --> 00:58:04.480
So this is literally like meant to be a starting point because there's lots of things I don't know because the insurance company hasn't figured them out yet.
00:58:04.639 --> 00:58:14.719
I mean, I'll probably end up doing this webinar more times as things develop, as policies develop, as states do different things, as insurance companies do different things.
00:58:15.039 --> 00:58:21.039
But what it will be on July 17th is what I know as of July 17th.
00:58:21.360 --> 00:58:23.599
Uh, and it's ever evolving.
00:58:23.679 --> 00:58:43.599
So that's why it's important to like stay connected to, you know, my pod, uh your Civil's podcast, my newsletter, you know, mental what what mental health insurance reform task force comes out with, other, you know, newsletters and trusted, I would say independent publications, because there's plenty of publications out there.
00:58:43.760 --> 00:58:45.920
Some of them are just in the pocket of venture capital.
00:58:46.079 --> 00:58:47.760
Sad to say, but it's really true.
00:58:48.000 --> 00:58:48.639
Yeah.
00:58:48.960 --> 00:58:53.840
So please check out Susan Frager, the psych billing coach.
00:58:56.079 --> 00:58:59.519
She's yeah, she's got a great newsletter, a great blog.
00:58:59.760 --> 00:59:01.280
Definitely check out her website.
00:59:01.440 --> 00:59:13.599
All the ways to connect with her will be in the show notes, including how to register for the July 17th, which I think we're saying if you can do it on demand, please do it on demand because it's probably gonna be a standing room only.
00:59:13.920 --> 00:59:16.800
It's virtual, so it's not really standing room only, but you know what I mean.
00:59:16.960 --> 00:59:25.519
There'll be a lot of people there signed up because uh Susan is a very well-respected person in the world of mental health insurance billing.
00:59:25.599 --> 00:59:29.679
She's been doing this for a long time, which is why I'm so grateful that she has.
00:59:29.840 --> 00:59:44.320
I mean, we've now sat and talked for probably like 10 hours total, because I don't I don't remember if I said this in the last episode, but that was the second time we had to record the last episode because the first time there were tech there were technical difficulties, Susan.
00:59:44.480 --> 00:59:47.679
In the first time that we tried to do That's right, there were.
00:59:48.239 --> 00:59:48.960
It's like following us.
00:59:49.039 --> 00:59:50.960
Like there's this is really scary.
00:59:51.280 --> 00:59:53.119
The powers that be do not want more.
00:59:53.599 --> 01:00:01.440
Well, and you know, when I started to talk at right at the task force meeting on Wednesday, that's when my Zoom crashed.
01:00:01.679 --> 01:00:06.159
Yeah, there I think the powers that be are spying on you because they know that you I think they are.
01:00:06.400 --> 01:00:08.239
I think they are all right, everybody.
01:00:08.400 --> 01:00:10.719
Well, we need to hold her like she's a national treasure.
01:00:10.800 --> 01:00:12.559
Everybody keep their eye on Susan Frager.
01:00:12.800 --> 01:00:14.159
We can't let anything happen to her.
01:00:14.400 --> 01:00:16.719
If I disappear from the airwaves.
01:00:17.760 --> 01:00:19.679
It's always such a joy, Susan.
01:00:19.760 --> 01:00:22.239
Like you and I like clicked immediately.
01:00:22.320 --> 01:00:27.199
I'm sure I'll hand you on again, and I'll see you at the task force meetings and events and all of that.
01:00:27.360 --> 01:00:31.360
And I'm so grateful for all the time that you've given and the support you've given to the podcast.
01:00:31.599 --> 01:00:32.960
Super, super grateful.
01:00:33.199 --> 01:00:39.840
You're really at the core of what I want to do around educating people because there is, I think it's an intentional complexity.
01:00:39.920 --> 01:00:40.960
I think it's by design.
01:00:41.039 --> 01:00:42.000
Um, absolutely.
01:00:42.320 --> 01:00:45.119
But it is so vital that people understand this stuff.
01:00:45.280 --> 01:00:48.639
And listen, I've been doing this for 20 years and I'm still learning stuff.
01:00:48.719 --> 01:00:50.639
And things, like you said, things are changing.
01:00:50.800 --> 01:00:53.280
And it's hard to keep up with all this shit.
01:00:53.519 --> 01:00:57.920
Like my menopausal brain cannot hold all of this information.
01:00:58.079 --> 01:01:00.480
So if people are feeling overwhelmed, guess what?
01:01:00.639 --> 01:01:01.519
We all feel that way.
01:01:01.679 --> 01:01:06.639
It's not like I have some magical powers that I can hold all of this, or even Susan can hold all of it.
01:01:06.719 --> 01:01:09.760
She has to go look stuff up too, because it is complicated.
01:01:09.920 --> 01:01:14.480
So if you're feeling like it's too much, it's it is it is too much.
01:01:14.559 --> 01:01:15.199
And that's fine.
01:01:15.519 --> 01:01:19.039
Well, and I've got a what I'm calling my external brain.
01:01:19.119 --> 01:01:21.440
I've got a whole, it's in development right now.
01:01:21.599 --> 01:01:22.800
People can subscribe.
01:01:22.960 --> 01:01:29.760
I'm I'm not necessarily developing it just for the purpose of having a subscription.
01:01:29.840 --> 01:01:36.639
Although if people want to subscribe, they certainly can because a lot of building services are finding that it's very useful in training their employees.
01:01:36.800 --> 01:01:38.960
But so anybody who wants to subscribe can.
01:01:39.039 --> 01:01:40.320
It's called the Rescue Builder.
01:01:40.400 --> 01:01:46.320
It's not even done because I don't have venture capital money and I'm not using freaking AI to build it.
01:01:46.480 --> 01:01:48.800
It's a repository of all of this stuff.
01:01:48.880 --> 01:01:54.159
And I gotta tell you, it's a full-time job keeping up with this stuff.
01:01:54.480 --> 01:02:01.199
And I have another full-time job, which is I'm, you know, consulting and doing projects for people and expedited appeals and all that.
01:02:01.280 --> 01:02:04.559
So that's why it's been over two years in development now.
01:02:04.880 --> 01:02:09.280
And I'm just like every day I wake up and I was like, will I ever get freaking done with this?
01:02:09.440 --> 01:02:14.159
And probably not, because as soon as I get done done, I mean I'm gonna constantly have to update.
01:02:14.320 --> 01:02:22.159
Like right now, before I release the uh the credentialing piece, I'm going to have to update C AQ H into data spring, right?
01:02:22.320 --> 01:02:26.800
So there's always the update, but it's it's a it's it's just a resource.
01:02:26.960 --> 01:02:36.320
There's lots of resources out there, and the important point is to know that they're out there, use what works for you, and you don't have to feel alone.
01:02:36.559 --> 01:02:37.760
Thank you, Susan.
01:02:38.159 --> 01:02:39.119
Thank you for having me.
01:02:39.360 --> 01:02:39.760
I love it.
01:02:39.840 --> 01:02:40.079
Yes.
01:02:40.960 --> 01:02:42.079
This is this is great.
01:02:42.159 --> 01:02:47.519
Um, and we will persevere and tell those tech demons where they can stick it.
01:02:47.760 --> 01:02:48.480
Exactly.
01:02:48.719 --> 01:02:49.119
Exactly.
01:02:49.280 --> 01:02:50.159
I'm right there with you.
01:02:50.320 --> 01:02:51.199
I'm right there with you.
01:02:51.360 --> 01:02:54.719
So thank you so much for being here yet again at such short notice.
01:02:54.800 --> 01:02:56.320
We just booked this like two days ago.
01:02:56.480 --> 01:02:58.880
I was like, we need to do a part two right now.
01:03:00.400 --> 01:03:01.840
I'm glad I was able to fit it in.
01:03:02.000 --> 01:03:02.880
Me too.
01:03:03.039 --> 01:03:12.559
Uh so if if you listen to this episode first, go back to the last episode and listen to that one too, because we had another really great conversation.
01:03:12.719 --> 01:03:14.960
We talked about like the transparency data.
01:03:15.119 --> 01:03:17.519
There was a lot of really great information in that.
01:03:17.840 --> 01:03:19.840
So thank you, Susan, for being here.
01:03:20.400 --> 01:03:26.800
Just a second to update this whole transparency data because of what Alia just did this week.
01:03:27.039 --> 01:03:28.880
What did Alia do this week?
01:03:29.199 --> 01:03:38.480
Alia put forth a public transparency air quotes database that ever that they say is really useful.
01:03:38.559 --> 01:03:40.639
And I went, oh, do you remember that?
01:03:41.039 --> 01:03:44.239
I shared it because it was like three insurance or four insurance companies.
01:03:44.559 --> 01:03:49.599
And it was very it wasn't even it was showing what Hedway, Alma, I don't remember which ones.
01:03:49.920 --> 01:03:52.000
Headway, Alma, Rula, all of them are getting.
01:03:52.239 --> 01:03:54.559
But it was very like it was tiny little.
01:03:55.440 --> 01:03:57.679
It was also so condense.
01:03:58.000 --> 01:04:02.400
Like they didn't, it was condensed, like they didn't separate out by discipline.
01:04:02.559 --> 01:04:08.719
They didn't separate out by very, very tightly dialed in geographical.
01:04:09.039 --> 01:04:11.599
Um just like it's essentially useful.
01:04:11.760 --> 01:04:14.239
Oh yeah, and state is essentially useless.
01:04:14.480 --> 01:04:15.199
I mean, think about it.
01:04:15.360 --> 01:04:16.639
Think about Washington State.
01:04:16.960 --> 01:04:21.599
Seattle and you know, Republic are getting different rates.
01:04:21.760 --> 01:04:22.000
Yeah.
01:04:22.159 --> 01:04:26.239
You know, and the Cigna rate, I was like, I get paid more than headway than any of them for Sigma.
01:04:26.800 --> 01:04:27.360
Right, right.
01:04:27.519 --> 01:04:36.320
So this whole price transparency thing, and it kills me because it's like they're trying to, what they're doing is they're giving you a little bit of a hook.
01:04:36.559 --> 01:04:44.239
And Alia is very, very scary because of how they're funded and what they're trying to do.
01:04:44.400 --> 01:04:47.440
They're trying to say that we won't charge you anything.
01:04:47.519 --> 01:04:49.280
We're gonna charge the insurance company.
01:04:49.440 --> 01:04:52.880
But what data do you have to sign over in order to make that happen?
01:04:52.960 --> 01:04:54.960
Because nothing in life is free.
01:04:55.119 --> 01:05:02.239
And it just, I saw that and my blood boiled because price transparency data is not easy to sort through.
01:05:02.400 --> 01:05:04.400
And go back and listen to the other podcast.
01:05:04.480 --> 01:05:08.960
I won't go on and on about it, but go back and listen to the other one because it talks a lot more about that.
01:05:09.119 --> 01:05:14.320
But that's what I mean about how everything is happening so fast in this industry.
01:05:14.480 --> 01:05:17.679
Because that just happened, what, yesterday or the day before?
01:05:17.920 --> 01:05:21.840
It was recent because I shared it on a bunch of sites and people like, isn't this a VC?
01:05:21.920 --> 01:05:25.280
I said it is, and I'm I'm not sharing it because I think people should join it.
01:05:25.440 --> 01:05:33.280
I'm just sharing it because I think people need to know that a lot of people I don't think know that the data is public and they have a right to look at it, first of all.
01:05:33.519 --> 01:05:36.559
So, and I was like, and they're not really showing very much.
01:05:36.639 --> 01:05:39.440
It was like aggregated and aggregate, aggregated.
01:05:39.519 --> 01:05:42.320
I can't yeah, it's aggregated to the point of uselessness.
01:05:42.559 --> 01:05:48.000
But I can guarantee you that the only one that I was like, well, I'm doing better than they are was Cigna.
01:05:48.239 --> 01:05:53.679
All the other ones, like Aetna, I was pissed off even with the aggregated data that at how much higher it was.
01:05:53.760 --> 01:05:55.360
So you should see my data.
01:05:56.159 --> 01:06:08.400
The reason that I shared it more than anything was for people to look at it and go, this is bullshit, because there's no reason that I should be being paid less than Headway or Rula or Alma or whatever.
01:06:08.559 --> 01:06:10.239
But go listen to the other episode.
01:06:10.400 --> 01:06:12.239
Yeah, stuff is changing constantly.
01:06:12.320 --> 01:06:25.119
And I also want people to know that I am in the works of trying to figure out how to have a second podcast focused on more regular updates about stuff happening.
01:06:25.280 --> 01:06:27.760
It will not be a full-hour interview with anybody.
01:06:27.920 --> 01:06:38.400
There'll be shorter pockets where I will be kind of reading through the day's news of this happened, that happened, you should know about this.
01:06:38.559 --> 01:06:40.079
This is what I think this means.
01:06:40.320 --> 01:06:52.559
So be prepared that this might this podcast might be expanding to have those types of like legislative updates, policy updates, insurance updates, et cetera, as far as the mental health landscape.
01:06:52.800 --> 01:06:56.239
Because, like we've been saying, stuff is changing constantly.
01:06:56.400 --> 01:06:58.400
There's stuff popping up all the time.
01:06:58.559 --> 01:07:06.639
And I want a place that people can come where it's recorded, where people can be know that they can get the latest information on what's coming up.
01:07:06.800 --> 01:07:10.239
But, you know, I'm only one person, so I'll do the best I can at making.
01:07:10.719 --> 01:07:12.639
Oh, and you mean you're not taking venture capital money?
01:07:12.960 --> 01:07:15.119
And I'm not taking venture capital money.
01:07:15.360 --> 01:07:21.760
Believe me, this podcast, I wouldn't be recording it from my dining room table if that were the case.
01:07:22.000 --> 01:07:25.280
But anyway, folks, please listen to the other episode.
01:07:25.360 --> 01:07:30.000
If you haven't, it came out two weeks ago because this I know when this is coming out now.
01:07:30.239 --> 01:07:33.679
Again, big thank you to Susan Frager, the psych billing coach.
01:07:33.840 --> 01:07:35.440
Big thank you to my audience.
01:07:35.599 --> 01:07:41.679
I have to give you some props, people, because the this podcast is starting to blow up.
01:07:41.840 --> 01:07:44.880
I've had more downloads, more cities added.
01:07:45.119 --> 01:07:50.559
We're almost at 600 cities across the world that this podcast has touched.
01:07:50.880 --> 01:07:55.679
So we've we've had the best month we've ever had, which tells me that people are sharing with colleagues.
01:07:56.000 --> 01:07:57.280
Please continue to share.
01:07:57.760 --> 01:07:59.679
Check out, I know, I love it.
01:08:00.000 --> 01:08:02.639
Check out the Psych Building Coach website.
01:08:02.719 --> 01:08:04.239
The link will be in the show notes.
01:08:04.400 --> 01:08:11.840
Go to buildbetterhealth.org to find out how to get involved in the mental health insurance reform landscape or landscape, the the task force.
01:08:11.920 --> 01:08:16.000
I'm just gonna say the task force, the mental health insurance reform task force.
01:08:16.319 --> 01:08:20.560
And stay tuned because I have a lot of really exciting guests coming up.
01:08:20.720 --> 01:08:27.119
I'm gonna have somebody from the psychotherapy action network who was sued by Talkspace.
01:08:27.199 --> 01:08:30.399
I'm meeting with her next week to get something on the books to schedule.
01:08:30.560 --> 01:08:31.680
That's a whole thing.
01:08:31.840 --> 01:08:34.399
So we've got lots of great stuff coming up.
01:08:34.479 --> 01:08:39.600
So keep can continue to share, like, rate on your podcast platforms, all of that stuff.
01:08:39.680 --> 01:08:41.439
That's how we build up the algorithm.
01:08:41.680 --> 01:08:43.439
So again, thanks, Susan.
01:08:43.520 --> 01:08:44.560
Thanks to my listeners.
01:08:44.640 --> 01:08:49.039
And my name is Civy Suckerman, and this is Therapists on Chains.