Opening a Practice Unlicensed but Hiring a Licensed Psychologist

[psyd20151234]

Is it possible to open a practice without my license. I'm a Psy D and I'm studying for the EPPP but want to get things going ASAP. Could I start my practice and be sole owner and hire a licensed Psychologist to do supervision and to see the majority of the patients?

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[PsyDr]

Ownership- depends on the relevant state's laws
Billing- Probably not. IIRC, to create a clinic NPI, you have to have an NPI, which requires a license.

 

[erg923]

Is it possible to open a practice without my license. I'm a Psy D and I'm studying for the EPPP but want to get things going ASAP. Could I start my practice and be sole owner and hire a licensed Psychologist to do supervision and to see the majority of the patients?

1. You are talking about starting a business. Its free country, based on capitalism, right?

2. You would not be able to bill, so the psychologist you hired will essentially have their own private practice (they just don't own it) that you set up and funded. Seems like it defeats the purpose of number one.

 

[erg923]

Ownership- depends on the relevant state's laws

Didn't know that, interesting.

 

[psyd20151234]

Well the psychologist would rely on me to bring in the patients, which I already have a referral network established and am great at the business aspect so the psych would just have to show up and see the patients and take his/her 70%.

I do have an NPI and can see medicare/medicaid patients (or cash accounts) in my state as long as I get 1 hour of supervision by a licensed psychologist (my employee).

It seems like I SHOULD be able to do this...hmmmmm.....

 

[erg923]

as long as I get 1 hour of supervision by a licensed psychologist (my employee).

If you can convince your state licensing board that that's not a dual relationship...

 

[ClinicalABA]

Well the psychologist would rely on me to bring in the patients, which I already have a referral network established and am great at the business aspect so the psych would just have to show up and see the patients and take his/her 70%.

I do have an NPI and can see medicare/medicaid patients (or cash accounts) in my state as long as I get 1 hour of supervision by a licensed psychologist (my employee).

It seems like I SHOULD be able to do this...hmmmmm.....

Depending on the jurisdiction, there may be a prohibition on receiving required (for your future license) supervision from someone you have administrative responsibility over. If you're not going to use your time with this supervisor to meet required post-doctoral supervision hours, it SHOULDN'T (but might!) be a problem. Doesn't hurt to ask the state licensing board if this is an issue. I was in the reverse situation in a previous job- the owner/our boss asked me and the other psychologist if we could provide him with supervision to be use towards his license. After checking around, we concluded that, as employees, it was not an appropriate relationship.

(ETA- Just saw erg923's reply- like he (she?) said!)

 

[psyd20151234]

I've accrued all necessary post-doc hours so I'm all set there....the supervision would be in place so I could potentially see any medicare/medicaid patients that come through....basically the same thing I'm doing now...as an unlicensed PsyD my current employer can bill for my services from medicare/medicaid.

Oh...or I could get supervision from an outside provider it wouldn't matter to me.

 

[ClinicalABA]

It

I've accrued all necessary post-doc hours so I'm all set there....the supervision would be in place so I could potentially see any medicare/medicaid patients that come through....basically the same thing I'm doing now...as an unlicensed PsyD my current employer can bill for my services from medicare/medicaid.

Oh...or I could get supervision from an outside provider it wouldn't matter to me.

If you have the ability to get supervision from a non-employee, that might be best as it removes the dual relationship. We were quite uncomfortable when our boss asked us to be his supervisor, as he was "difficult" in many different ways (that I don't thing he was really aware of), and it would have likely put us in a very difficult position to have to be his supervisor (clinically) and supervisee (administratively). At this point in your career (as both a clinician and business owner) , you should want to make sure that your clinical supervisor is making decision based on your growth as a clinician and, ultimately the client's best interest, without concern as to whether or not her feedback with negatively impact her ability to pay her mortgage and feed her family.

 

[Peacemaker36]

If you can convince your state licensing board that that's not a dual relationship...

Yes, I would be very careful about this, depending on your state's licensing board. I think you would be in hot water doing this in my state due to the multiple relationship.

 

[erg923]

None of this makes much sense to me. You are talking about a process that will take months and months to implement/set up and get running. Just take a couple months to study EPPP starting now (there's no need for 6 months of prep for EPPP that I hear some people talking about) and get licensed. Just do this and none of the other stuff will be needed.

 

[psyd20151234]

Eh...I'm just eager to get started...definitely wouldn't take months as I have the funds to staff and a referral network to bring in patients for at least 2 clinicians (possibly 3). Just exploring the options. 🙂

 

[PsyDr]

Didn't know that, interesting.

Yeah, some states have laws about this. Hint: might be on at least one state's jurisprudence exam.

Eh...I'm just eager to get started...definitely wouldn't take months as I have the funds to staff and a referral network to bring in patients for at least 2 clinicians (possibly 3). Just exploring the options. 🙂

Advice from someone who has/had a private practice with several staff: Slow the F down. If starting a multiple provider private practice was a simple matter of $$$, lenders would be clamoring to PPs. Even if you have some explicit knowledge of billing, you lack the procedural experience of how billing/reimbursement cycles/etc work. Not to mention, legal implications, corporate structure, cashflow, etc. You are already hinting at dual relationships and unlicensed practice. Do you really want to start a career with ethical and legal problems as your foundation? You could easily convert a million dollars into a few hundred grand in 18 months here.

 

[WisNeuro]

I'd be wary of the types of people you're going to attract that are willing to join a new practice, headed by someone still on postdoc and is not licensed. If I'm looking for practices to join, honestly, that one is pretty far down the list unless I'm desperate.

 

[Therapist4Chnge]

...as an unlicensed PsyD my current employer can bill for my services from medicare/medicaid.

I believe billing Medicare requires the person have a fully and unrestricted license to practice psychology. I can't speak to Medicaid.

 

[DynamicDidactic]

you can own a practice and take a portion of the profits without seeing clients. Or if you really want to see clients, why not find someone that was not working for you to supervise. The money that your hired therapist brings in from seeing clients would likely be more beneficial than losing that hour a week to provide supervision. Additionally, I would very much be concerned about the ethical dilemmas of a licensed clinician that would supervise their own boss.

also, the whole setup sounds fishy. Just saying.

 

[psyd20151234]

Yeah...I wouldn't even need to see clients until I get fully licensed as I have my hours so the supervision concerns are out.

Nothing fishy about it...I started a consulting business for private practices while getting my PsyD and after turning around about 10 practices throughout the country I'm just ready to get started on my own and figured "Why not now?" Like I said...I have the referral base and the funds to get it started.

Just wasn't sure if I could own a practice (even temporarily) without having a license...even if I weren't seeing clients and just acting as the owner.

 

[smalltownpsych]

Yeah...I wouldn't even need to see clients until I get fully licensed as I have my hours so the supervision concerns are out.

Nothing fishy about it...I started a consulting business for private practices while getting my PsyD and after turning around about 10 practices throughout the country I'm just ready to get started on my own and figured "Why not now?" Like I said...I have the referral base and the funds to get it started.

Just wasn't sure if I could own a practice (even temporarily) without having a license...even if I weren't seeing clients and just acting as the owner.

That is a legal question which would vary from state to state and could also depend on the structure of the business that you start up, I would imagine. I would suggest that you consult an attorney with knowledge in this area.

 

[erg923]

Yeah...I wouldn't even need to see clients until I get fully licensed as I have my hours so the supervision concerns are out.

Nothing fishy about it...I started a consulting business for private practices while getting my PsyD and after turning around about 10 practices throughout the country I'm just ready to get started on my own and figured "Why not now?" Like I said...I have the referral base and the funds to get it started.

Just wasn't sure if I could own a practice (even temporarily) without having a license...even if I weren't seeing clients and just acting as the owner.

I would reiterate the advice and concerns of @PSYDR in post #13

 

[R. Matey]

Yeah...I wouldn't even need to see clients until I get fully licensed as I have my hours so the supervision concerns are out.

You just said you needed supervision from an employee or outside supervisor?! I'm completely lost. This feels really sketchy to me.

 

[R. Matey]

I believe billing Medicare requires the person have a fully and unrestricted license to practice psychology. I can't speak to Medicaid.

I've practiced as an LPC in three states that didn't require a psychologist license (or any other license for that matter) to bill Medicaid. As far as I'm aware, only can psychologists and social workers can bill Medicaid thought the professional orgs for counseling are working hard to change that.

 

[R. Matey]

oops...I'm meant Medicare.

 

[R. Matey]

I did it again..

 

[psyd20151234]

It's actually not sketchy at all. The only reason supervision was mentioned was because I figured I'd need to get some sort of supervision to continue seeing patients...like I am not at the community mental health center I'm working at.

So let's forget about the supervision...no supervision needed...I won't be seeing patients until I'm licensed because I already have all the hours necessary anyway...that being said: the question was whether I could still own a practice and hire a licensed psychologist to see the patients (and an NP or MD to fulfill the prescription need) and I take a cut of those services by being the owner of the practice...basically getting a start on opening my own practice as I study for the EPPP.

Anyway...talked to an attorney and the state board and they said that, not only is it possible, it's actually done quite often by entrepreneur-types and enterprising individuals who are close to getting licensed and want to get a jump start on starting their business...so that's my answer.

Thanks for the input everyone! 🙂

 

[R. Matey]

It's actually not sketchy at all. The only reason supervision was mentioned was because I figured I'd need to get some sort of supervision to continue seeing patients...like I am not at the community mental health center I'm working at.

So let's forget about the supervision...no supervision needed...I won't be seeing patients until I'm licensed because I already have all the hours necessary anyway...that being said: the question was whether I could still own a practice and hire a licensed psychologist to see the patients (and an NP or MD to fulfill the prescription need) and I take a cut of those services by being the owner of the practice...basically getting a start on opening my own practice as I study for the EPPP.

Anyway...talked to an attorney and the state board and they said that, not only is it possible, it's actually done quite often by entrepreneur-types and enterprising individuals who are close to getting licensed and want to get a jump start on starting their business...so that's my answer.

Thanks for the input everyone! 🙂

Why not just stay at the CMHC until after you take the EPPP and get licensed? Two sources of income seem better than one in private practice. I worked in a few of those places and I know they're not the best, but avoiding CMHC life is certainly not worth losing serious funds over.

I'm also not sure what you're thanking people for. If you're actually reading this thread, people are telling you not to do it until after you get licensed.

 

[psyd20151234]

I was thanking people for the input...taking their time to respond. 🙂

 

[smalltownpsych]

Good luck with your business. 🙂 If you have all of the supervised hours, then take the EPPP and in a short time the need for supervision would be moot and as things are getting geared up, your income will be dependent on yourself as opposed to others which might be crucial in the beginning. In other words, I trust myself to generate revenue as I have done it before, but when hiring others it can be hit or miss. Literally. I have about a 50% track record for hiring people. You might think you would do better, but the research is pretty clear that to think that is a mistake and I wouldn't want to bank my business on it. keep in mind that when you were consulting, the really bad ones had already been weeded out and they are out there - trust me on that!

 

[R. Matey]

I was thanking people for the input...taking their time to respond. 🙂

Just seemed a bit sarcastic to me, but that could've been my perception.