Dual Practitioner Guidance

Posted by Behavioral Health Billing Solutions, LLC.

Dual Practitioner Guidance as of the January 1st go-live for BH Redesign.

This week I was finally able to get some verification from a trusted colleague involved very closely with state departments to get a better understanding of how Dual Credentialed Providers are impacted as of January 1st, 2018. 

Detailed information is below and references the Ohio rules supporting this information.

As for the dual credentialed practitioners, for Medicaid payment purposes, 5160-27-01 and 03 are pretty clear that coverage and reimbursement is available when licensed practitioners are practicing within their scope of practice.  Medicaid’s approach to making this operational is by using the combination of modifiers between January and June. 

Remember, for January, only independents and RN/LPNs must use the NPIs when billing for services under the scope of practice of that license. 

The NPI registration issue and the “pick one” approach (as of January 1st) is only an issue if the professional has both an independent license and a nursing license (e.g. LISW, RN) that both require billing with an NPI during the first six months.  That’s a small, but important, group of professionals. 

Other dual credentialed can use a combination of the NPI and/or modifiers to practice across their full scope of practice without risk of audit or fear of payback until we get to the NPIs for all in July .  For example, an RN, CDCA would bill nursing services with the NPI and case management using the U6 modifier.  Similarly and LICDC, LPC would bill for SUD services using the NPI affiliated with the LICDC and for MH services using the U2 modifier for the LPC. 

The dual credential piece becomes a much bigger issue for July and going forward since the ACA requires practitioners to register with the state Medicaid agency and ODM has elected to require NPIs and link that to billing code sets.  It’s the July issue that has bigger impact and a needed resolution.

With that said, Beta testing and overall testing opens for a very short window 10/25/2017 – 11/30/2017.

10 days from now.

And yet, we still don’t know what dates to use to test with.

Update: It was announced 10/17 to test with dates between September 1st and October 15th, 2017 for Beta and Regular testing.

I currently have a client doing clinical data entry of test services “GUESSING” on what dates to use as this training was previously coordinated and scheduled, which as we all know is challenging in and of itself. We did clinical training on the entire process and I was actually very proud of how this agency has done everything in it’s power to stay ready for the changes. But remember, the dates may be wrong. It’s all good since I have a way to fix it, however, I find this particular lack of guidance concerning.

The expectation is agencies in Ohio test and I agree completely. My professional opinion is it’s critical we have all the information needed to do so or Medicaid needs to extend the testing timeline.