By ROLF LOWE
Effective February 4, 2023, the Michigan Department of Health and Human Services (MDHHS) will allow Medicaid reimbursement for behavioral health services provided by recent graduates of board-approved master’s or doctoral level psychology, social work, counseling or marriage and family therapy educational training program who have completed all the requirements for a limited or temporary license as specified in the respective licensing rules for each discipline, but have not yet obtained a license from the Michigan Department of Licensing and Regulatory Affairs (LARA). The change in coverage was announced by MDHHS on January 5, 2023, in Michigan Medicaid Policy (MMP) Bulletin 23-02.
While the MMP Bulletin expands the behavioral health workforce able to treat Medicaid Beneficiaries, it does contain a requirement that the graduate providers are supervised by a Medicaid enrolled, fully licensed provider of the same profession, and graduate providers are not eligible to enroll or be directly reimbursed by the Medicaid program. The services are to be billed to the Medicaid program under the National Provider Identifier (NPI) of the Medicaid enrolled supervisor. There is also a time limit on these type of supervisory relationships, with Medicaid allowing the arrangement for a period of no longer than one year from the date the graduate provider successfully completed their graduate coursework. All other non-physician behavioral health provider requirements unchanged.
For services provided to Medicaid Beneficiaries where the Medicaid Health Plans (MHPs), Integrated Care Organizations (ICOs), Pre-Paid Inpatient Health Plans (PIHPs) and Community Health Services Programs (CMHSPS) are responsible for providing covered services, graduates who intend to provide services to the respective payer’s Medicaid Beneficiaries still need to ensure they meet any credentialing, contract, and billing requirements.
Provider entities looking to implement the expanded workforce into their delivery of care should also take steps to ensure their operations are aligned correctly. This may include direct source verification of the provider graduate’s course work and degree completion dates, notifying both general and professional liability carriers of the addition of the new workforce, training in the area of the Medicaid program and respective payers’ medical record documentation requirements and allowable services, privacy and compliance training, determining whether to employ or sub-contract the graduate for their services and the appropriate payment for those services.
While the graduate providers are not allowed to enroll and be registered through the Community Health Automated Medicaid Processing System (CHAMPS), any provider utilizing the services of a graduate provider should make sure the individual would be able to meet all of the Medicaid enrollment criteria prior to allowing them to treat and care for any Medicaid Beneficiaries. Special attention also needs to be paid to the one-year limitation on the service arrangement identified in the MMP Bulletin, as payments for these services made after the one-year anniversary of the graduate provider’s course completion date could be subject to Medicaid’s overpayment and recoupment rules.
For additional information or assistance please contact Rolf Lowe of Wachler & Associates at (248) 544-0888 or [email protected].