Group Practice Owners and Medicare Expansion to LMFT, LPC, and LMHC

"Hey guys, I am talking about Medicare opt-out for group practices. I am a group practice owner myself and started on this rabbit hole to figure out in deciding if Medicare makes sense for us. Given that as an LMFT, it's new that we might be able to bill Medicare in January. I'm looking into reimbursement rates. I'm looking into whether we want to enroll or opt-out and what all of that looks like for a group practice. And I'm here to tell you what I found what questions still exist out there. And, you know, just to be part of the conversation, happy to hear from other folks as well in what you're finding and how you're navigating this space.

So what I have learned is if you decide that you want to opt out, you cannot opt out your organization as a whole. You have to opt out individual practitioners. And this applies only to licensed folks because pre-licensed people would not be eligible to be able to bill for Medicare anyway. And so there's the process that you go through the opt out and we have another blog that describes all of the delightful steps of doing that with government things.

And the caution though in dealing with staff in a group practice is that the opt out is for the practitioner and is global for that practitioner. It's not specific to where they work. So I think as a group owner it's a tricky space to require that our employees or contractors opt out of Medicare for our practice because then that means they would not be eligible to bill for Medicare in any other work setting and that may not be a possibility for them because of the other places that they work or they may just want to keep that option open for other career possibilities or whatever.

And I called and did a consultation with a camped attorney about this particular thing. They suggested like, oh, well, if your person is enrolled in Medicare in another location, then when they come into, if there's someone who is covered by Medicare who comes into your practice and gets matched with that clinician, then you would need to just have your biller. Bill Medicare. Which sounds great, except if you're a practice that doesn't have a biller, if you're a practice who isn't enrolled in Medicare, or you don't have, you're not part of a plan, you know, one of the bigger health plans that also administers Medicare.

What, what are we to do here, right? To my knowledge, if we're not isn't enrolled and set up to do that billing, but I'm required to bill Medicare for the clinician who has medical, who's enrolled somewhere else and is partnered with a person who has Medicare. Essentially I don’t know how my practice gets paid or if they could get paid if we get ourselves into that kind of setup.

And I had asked the CAMFT attorney, well it seems like, the kind of cleanest thing to do would be to make sure that if I know that one of the therapists who's working in my practice is enrolled in Medicare somewhere else and we don't do any insurance billing or Medicare billing in this practice, then I would, it seems the cleanest thing would be to ensure that they never get matched with a person who has Medicare because then we have this, this, you know, kind of issue with the rules and getting paid and the attorney was really concerned about the optics of that and what that might look like for fairness to the client. Why, I have Medicare and here's a person in your practice who has enrolled and why can I not see them?

I suggest that we just refer to the other practice and let them be seen over there, but like this is where some of the stickiness and the gray area is that we're figuring out as we like navigate how all of these new rules go into place and what it really means for our practices.

Also, my understanding is to be able to see a client or potential client who is covered by Medicare if they want to pay cash for our services. So, then we do need to engage in a separate, a private contract, I believe, with the client that specifies that they know that we're not a Medicare provider, that they won't, you know, Medicare won't reimburse for any of these services. And so that's something that we, systems we can set up and we can put into place in our practices if we're not already enrolled in Medicare, but obviously that wouldn't be able to apply to a clinician who is enrolled. In Medicare just in a different location. So that's what we know so far. Yeah, let us know if you've learned anything else. If you have same questions or more questions that maybe we haven't thought of yet.