- Joined
- Sep 15, 2006
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From a state psychology discussion list ...
[Original message]
Greetings,
I am considering a position with a company that provides contracted services, primarily to nursing homes.
Unfortunately, I am a few months shy of my post-doc supervision requirement. The company has offered to provide supervision.
However, because they have no practicing clinicians in my location, I will have to temporarily work from a facility where they do have staff in practice -- that means a 2 hour commute. The reason given is that Medicare reimbursement requires supervisor/supervisee to be on-site together.
I am curious. Given the outcome of the discussion which concluded that telephone consultation with CLIENTS is reimbursable, why would it not be be equally permissible to have telephone consultation for supervision?
Or, alternately, face-to-face supervision but only for the 1 - 2 hours of supervision itself? My read of the NYS regs is that the supervision itself does need to be face-to-face, but there doesn't seem to be any requirement that the remaining 38 hours of the workweek require supervisor/ supervisee to be in the same physical location. Does Medicare?
[The response]
Medicare requires that the billing psychologist be present throughout the period of service delivery.
That psychologist is not supervising you but using you to provide an incidental part of a service that he himself is rendering. He must initiate the treatment and have direct personal contact with the patient.
You are in Medicare regs a technician much like an x-ray technician.
Not only does the billing psychologist have to be in the facility, but he has to be within shouting distance.
Strange but true.
---------
Three months from licensure, but even less autonomy than extern/internship!
[Original message]
Greetings,
I am considering a position with a company that provides contracted services, primarily to nursing homes.
Unfortunately, I am a few months shy of my post-doc supervision requirement. The company has offered to provide supervision.
However, because they have no practicing clinicians in my location, I will have to temporarily work from a facility where they do have staff in practice -- that means a 2 hour commute. The reason given is that Medicare reimbursement requires supervisor/supervisee to be on-site together.
I am curious. Given the outcome of the discussion which concluded that telephone consultation with CLIENTS is reimbursable, why would it not be be equally permissible to have telephone consultation for supervision?
Or, alternately, face-to-face supervision but only for the 1 - 2 hours of supervision itself? My read of the NYS regs is that the supervision itself does need to be face-to-face, but there doesn't seem to be any requirement that the remaining 38 hours of the workweek require supervisor/ supervisee to be in the same physical location. Does Medicare?
[The response]
Medicare requires that the billing psychologist be present throughout the period of service delivery.
That psychologist is not supervising you but using you to provide an incidental part of a service that he himself is rendering. He must initiate the treatment and have direct personal contact with the patient.
You are in Medicare regs a technician much like an x-ray technician.
Not only does the billing psychologist have to be in the facility, but he has to be within shouting distance.
Strange but true.
---------
Three months from licensure, but even less autonomy than extern/internship!