Providing access to behavioral health treatment has become a top focus of federal healthcare programs as the associated stigma decreased and the need for these services increased over the last few years. However, the growth in the number of licensed supervisors has not caught up with the manifold increase in the volume of patients seeking treatment.

If the practice management team is not up to date with the regulatory environment and places a high focus on productivity, it may miss the forest for the trees. Several recent cases underscore a great willingness by the federal government to pursue private equity owners of behavioral health companies that may be violating the FCA.

A banner question lurking around all executives in behavioral health is, “How do I help my practices deal with this permanent increase in volumes while the staff waits for more hands on deck?” Essentially, “How do I do more with less?”

Enhanced coordination of care and the appropriate use of incident-to-services can enable the pool of providers to perform at the top of licensure while handling this unprecedented demand. CMS has been updating several payment and coverage requirements for the past few years toward an integrated behavioral and primary care model. Telemental therapy has proven to be an effective modality and further improved the geographical delivery of care to patients.

With the evolving nature of guidelines, behavioral health is one of the most active specialties where we recommend supplemental training for staff. Oftentimes, it is the elements of routine billing and coding practices that, if not already in place, derail the best efforts to keep up with changes.

In a recent audit, we noticed a practice-wide trend of not noting the licensure of the treatment provider. Multiple charts were signed by the performing provider but did not include their licensure/credentials alongside the signatures.  It would, in some cases, state “staff,” but we were still unable to determine what credentials they held. Stating licensure is a documentation requirement as reimbursement for codes depends on if the services rendered were incident-to (under the supervision of a licensed clinician) or if the provider billed under their own license. Few other charts audited did have a provider sign in as the ‘reviewer,’ but their credentials were not stated in these charts.

Leaving ambiguity in licensure could be a red flag to auditors indicating that perhaps practice is doing ‘more with less’ but without proper credentials or supervision of staff. 

We initiated a memo for the training of the auxiliary staff to note licensure in view of existing CMS guidelines and repeated a probe audit within 3 months. These efforts led to a dramatic decrease in the number of charts with unfilled credential fields—a matter of claims hygiene that, if unchecked, could have resulted in an investigation by state or federal auditors.

Are you sure that your platform practices can navigate regular updates and scrutiny with ease? In our external audits, we isolate issues and train staff to quickly and painlessly remediate gaps. We work in all modalities in behavioral health with some of the largest PE-owned platforms and founder-owned single-modality specialists. 

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