Billing for Prac Students

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Are you saying that you’re using unpaid students to do work that would regularly be done by a paid employee?


Or are you saying that you’re going to double dip into federal funds, with students getting loans, and then billing CMS? The basis of which results in private insurances disallowing this practice?




You can’t do what you’re saying. Pay your people. Don’t break the law.
 
Yeah, it's a no-go for a lot of payers, particularly those of us with patient populations that are heavily Medicare. One of the reasons why the cries of "we're just slave labor" from prac students and interns is stupid on it's face. In most settings, for the most part, prac students and interns are a huge drain on resources in terms of time and money. We'd need federal reform to change this, but it ain't coming any time soon.
 
Thanks for responses! To clarify, trying to figure out if there are ways to receive reimbursement from payors for students who are supervised for a paid practicum. Trying to also highlight benefits of having psychology trainees to a larger healthcare system.
 
We are starting up a Medicaid program that is administered by Magellan and based on the rate sheets, we can bill for them under supervisors NPI. I do pay my practicum people and since they tend to be very green masters students we start them off with providing support services mainly before taking on psychotherapy cases. Those types of services also have some billing codes associated with them and some may be compensated. The “healthcare” companies that manage this stuff are in the business of limiting treatment and have creative ways of making sure that needed services aren’t easily paid for so even if they make it look like they will pay, that doesn’t mean that it will ever actually happen.
 
Thanks for responses! To clarify, trying to figure out if there are ways to receive reimbursement from payors for students who are supervised for a paid practicum. Trying to also highlight benefits of having psychology trainees to a larger healthcare system.
I imagine it's likely to vary by payor, with most leaning toward the "we won't pay" group. But some might. Or private pay, which may not be an option in a larger healthcare system.

Maybe some will pay if the supervisor is in the room with the trainee when the service is being performed.

And yeah, this is why practica and internships are tough without some sort of federal/state grant support, particularly outside of the VA.
 
Thanks for responses! To clarify, trying to figure out if there are ways to receive reimbursement from payors for students who are supervised for a paid practicum. Trying to also highlight benefits of having psychology trainees to a larger healthcare system.
Testing or therapy pratica?

For testing, you could make a reasonable case for increased capacity for testing. Maybe you could get the student to give a structured background intake form, and bill for that. You'd still have to interview the patient, and have to eat the test administration time, but you can still bill for your intake, interpretation, and writing.

For therapy, maybe some increased capacity for group therapy, or maybe you could use them as a scribe, so you could see more patients/groups. I doubt you can bill for students doing 1:1 psychotherapy.
 
Testing or therapy pratica?

For testing, you could make a reasonable case for increased capacity for testing. Maybe you could get the student to give a structured background intake form, and bill for that. You'd still have to interview the patient, and have to eat the test administration time, but you can still bill for your intake, interpretation, and writing.

For therapy, maybe some increased capacity for group therapy, or maybe you could use them as a scribe, so you could see more patients/groups. I doubt you can bill for students doing 1:1 psychotherapy.
This. They may also be able to provide patient services that the staff psychologists don't have time for, even if it's at a loss for the hospital, which could improve patient satisfaction (and Press Ganey scores). I've often seen this with groups, like PsyDr mentioned.

And at VA, one of the selling points (other than healthcare training being one of VA's central missions) was basically, "if we train them, they're more likely to come back and work for us later."
 
I've seen externship programs where doctoral students are hired for staff positions (e.g., psychometrist) and told "what your training program thinks of the time you spend here is none of our business." I always had an arm's length relationship with these programs and can't comment on their legality or ethics.

When I co-treat or co-lead a visit with an extern, I bill for that time. I also bill for the time I spend either editing or rewriting trainee-written clinical reports. I don't bill for the trainee's time spent either writing the first draft or implementing my edits.

On our inpatient unit, my trainees each carry a small caseload. When first meeting a patient, they typically complete an interview and cognitive/emotional screen at bedside, as well as a collateral interview (if appropriate/feasible)--externs then send me their notes/a draft note based on that initial visit. I then meet with all patients seen by my supervisees during my own walking rounds and complete my own, independent brief screen (e.g., orientation, mood) and brief interview. I typically bill for these visits using a non-time-based code (e.g., 96156), incorporating information provided by the trainee. This is a scenario where partnering with trainees does increase my efficiency, while simultaneously allowing trainees to obtain supervised experience in a unique/acute medical setting (with the added bonus of giving them the opportunity to generate many integrated reports--typically at least one-to-two per day).
 
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I've seen externship programs where doctoral students are hired for staff positions (e.g., psychometrist) and told "what your training program thinks of the time you spend here is none of our business." I always had an arm's length relationship with these programs and can't comment on their legality or ethics.

When I co-treat or co-lead a visit with an extern, I bill for that time. I also bill for the time I spend either editing or rewriting trainee-written clinical reports. I don't bill for the trainee's time spent either writing the first draft or implementing my edits.

On our inpatient unit, my trainees each carry a small caseload. When first meeting a patient, they typically complete an interview and cognitive/emotional screen at bedside, as well as a collateral interview (if appropriate/feasible)--externs then send me their notes/a draft note based on that initial visit. I then meet with all patients seen by my supervisees during my own walking rounds and complete my own, independent brief screen (e.g., orientation, mood) and brief interview. I typically bill for these visits using a non-time-based code (e.g., 96156), incorporating information provided by the trainee. This is a scenario where partnering with trainees does increase my efficiency, while simultaneously allowing trainees to obtain supervised experience in a unique/acute medical setting (with the added bonus of giving them the opportunity to generate many integrated reports--typically at least one-to-two per day).
Hi! I really appreciate this model using H&B assessment, as a follow up do you incorporate student documentation as a progress note by them to help with their documentation practice or keep their documentation out of the medical chart?
 
Hi! I really appreciate this model using H&B assessment, as a follow up do you incorporate student documentation as a progress note by them to help with their documentation practice or keep their documentation out of the medical chart?
I do my own exam and my own documentation, which I supplement with information gathered by the trainee. This aboveboard at my institution; I can't comment on its status in other states, healthcare systems, etc.
 
We're in an unique position because we pay our graduate clerks and cannot bill.

We take 1-2 doctoral students for 20 hours a week, 11-month long training. These are typically 3rd year doctoral students; some background in practice, but lots and lots of questions about clinical practice. The payment we make is more of a tuition reimbursement for their program. I'm not exactly sure how it got started, but it's been this way for years. Sometimes the university has an option to use grant funding to cover part of the payment.

Our site is primarily assessment. The clinician has to be present to bill if the student is administering the test. Usually I sit next to the student and provide feedback/step in until their skills develop. Once they feel good about administration, I still have to watch assessment live, either through our camera system or in an observation room. I can't do anything else while watching their assessment. Eventually they lead the interview with me in the room, and they can draft a conclusion statement on straightforward cases.

Since we pay for our clerks, we have looked into ways to get some sort of reimbursement. There really aren't options in my state and system. At best, we're hopeful that a great training experience at this level will encourage the student to pursue pediatrics in the future and maybe one day become a colleague.
 
Thanks for responses! To clarify, trying to figure out if there are ways to receive reimbursement from payors for students who are supervised for a paid practicum. Trying to also highlight benefits of having psychology trainees to a larger healthcare system.
What setting are you working in, and do you know how they're billing? Commercial payor or Medicaid/care?

For commercial payors at least:

Many psychiatric HLOC services (RTC/PHP/IOP in particular, free standing IP as well) do inclusive billing per diem, so long as the base requirements of your contract are met. So for example let's just say BCBS says they'll pay you $3000 per diem for RTC as long as the patients have 3 groups and 1 session... it doesn't matter if a fully licensed neuropsychologist is running the group or the practicum student getting signed off by a supervisor. You get paid the $3000 regardless.

If your program does non-inclusive billing (which many inpatient/medical ones do), then it will depend on what is being billed and whether the payor will accept supervisory billing. So they might bill a base revenue rate for room/board (facility billing) and then add CPT billing for the specific services being provided on each day, so it comes down to whether the payor will reimburse for the 90834 or 90838 (or whatever it is you're providing) under supervisory billing.
 
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