Billing Under Fire: Supervisory Billing Explained (and more), with Susan Frager, MSW, Part 2

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Host Sivie Suckerman, LMHC, ACS  and “Psych Billing Coach” Susan Frager, MSW, clarify key administrative and regulatory shifts impacting mental health clinicians. 

Susan explains the technical differences between Medicare's "incident to" billing and standard behavioral health supervisory billing. The two discuss the administrative risks of unclear documentation rules, highlighting a recent $750,000 audit clawback in Arizona, and analyze how Blue Cross Blue Shield's policy updates in Michigan could affect the private practice training pipeline. Finally, they examine legislative solutions - such as state-level payment laws, House Resolution 8081, and Senate Bill 683 - and address emerging data privacy and informed consent issues introduced by AI recording tools and venture-backed care platforms.

Episode Links:

Stop Stumbling over Supervisory Billing! Upcoming July 17th, 2026

2026 Inseparable Workforce Report

H.R. 8081

S. 4202

Build Better Health

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Susan Frager. MSW

I’m a clinician at heart, but am deeply interested in the finances and management of behavioral health practices and the toxic healthcare policies that cause clinicians to lose sleep and burn out. I practiced as a licensed clinical social worker before accidentally being roped into working for a managed care system in the early 1990s – where I saw just how toxic things really were. I left and operated a mental health billing service from 1998-2024, transitioning to being a full time PsychBilling Coach beginning in 2022. 

As “The Psych Billing Coach”, I offer a hybrid approach. You do your credentialing & billing – you keep as much income as you can. But when things get rough…you call in someone to take over the stuff you don’t know. Because you don’t know what you don’t know – and you probably don’t want to know it if it’s esoteric enough!

I help with everything and anything. From credentialing, Medicare / Medicaid / Tricare enrollment, fixing data problems, electronic data interchange issues, selecting and setting up the best EHR for you, coding, collections issues, scaling and managing group practices, teaching not just billing but revenue cycle management, fixing rejections and denials, supervisory billing problems, audits/documentation, and fighting clawbacks. And, of course, fighting for reimbursement increases and detangling yourself from the venture capital platforms. 

The dormant social worker in me has awakened since becoming a full-time consultant and trainer, and I spend time working on advocacy projects as well. And, there are times when consultations do turn into coaching – because I find it really sad just how many clinicians conclude that your problems with managing your practice are somehow a personal failure, as opposed to a highly toxic system that is operating as designed – to keep profit at the top of the food chain. 

If you DO want to learn more, I’m developing The Rescue Biller® and it’s open now to Beta members. It’s a treasure trove of information, available 24/7 with a membership subscription. The Rescue Biller has downloads, videos, and tons of answers to What do I do IF?  We’re developing a community where billers, credentialing experts, administrators, and clinicians freely mingle their knowledge. Once a month we have a no-charge Zoom “Open House” where we discuss problem situations and brainstorm how to solve them, without sharing protected health information. People love the ever-growing list of insurance executive names and verified emails – for use when you just need someone to respond and fix your issue, because no one in the customer service center in Asia will be able to! My method, which I call my “Executive Badass Complaint Method,” was featured in the New Yorker in December of 2024 – after the murder of the United Healthcare CEO.  I don’t pull any punches – and I’m known for a rather sarcastic way of looking at these things. 

Links:

My main website: https://psychbillingcoach.com/

Services page:  https://psychbillingcoach.com/services/

My blog: https://psychbillingcoach.com/billing-blog/

Schedule a consultation:  https://psychbillingcoach.com/schedule/

And here are a few I’ve done specifically about the platforms:

• https://psychbillingcoach.com/tech-platform-money-trail/
• https://psychbillingcoach.com/mega-platform-billers-perspective/  (part 2 of this is the infographics only: https://psychbillingcoach.com/minor-differences/)
•  https://psychbillingcoach.com/medicare-vs-the-mega-groups/

This episode was produced and edited by Sivie Suckerman, MA, LMHC, ACS