Originally Posted by Duck Duck Goose
I appreciate you offering some numbers for consideration. But I'm still not convinced about the math because
1 - many internship sites do offer the minimum supervision and stick to it (good site or not)
2 - many internship sites do not offer good benefits, including health insurance (!!!)
3 - at least in my region of the country, practica students with Masters get their own NPI and sites bill for their services like other Masters level providers, with supervision and supervisors' signatures as appropriate (no fraud, just when a licensed psychologist is needed in addition to the Masters level), so I find it hard to believe that interns can't be / aren't set up the same way. [Disclaimer: I don't know enough about billing to know how it works but I know that I got my MA, my practicum site signed me up for an NPI, and other sites/jobs have asked if I have one and they used it for something, and I haven't been pursuing Masters level licensure supervision ever.]
1- True. Unfortunate, but true.
2- Really! I am a few years out, but I thought almost every site offered health insurance. That is awful. It takes a special kind of hypocrite to fail to provide people they employ as HEALTH PROVIDERS health insurance.
3- This is the confusing part. It isn't entirely clear whether this is legal or not. Most small groups I know of do supervisor billing, and most hospitals I know of do not. I didn't bother reading the latest implimenting standards for medicare (since I am not practicing anymore), but the previous regulations stated that the billing clinician had to be present for the critical medical intervention (or some such language). So, for therapy, what the h#ll is the critical medical intervention? It seems that the clinician should have to see the person being billed for all appointments at the very least, but maybe not with therapy. Maybe the critical medical intervention is the formulation that takes place in supervision? Who knows. The problem is that if you guess wrong, and you are a hospital, medicare will figure out the proportion of billing that was incorrect for the random charts they pull and then fine you an amount equal to that proportion of your total medicare billing. So if you guessed wrong (or medicare disagreed with you), and an intern provided 50% of the services to the clients whose charts were pulled, then medicare would take 50% of the money they had paid to you for all of your clients during the audit period. Small groups are willing to take this chance because they are judgment proof. A small group practice typically owns a coffee pot, a lease, and an LLC that can immunize the individuals from federally imposed fines provided there was no intent to defraud.
Edit: Also, small groups are willing to take this chance because they don't know they are taking this chance. Very few small practices consult with a lawyer before deciding how to structure their billing, but the same is not true for large hospital systems.