Psychologists Practicing Independently
Pub. 100-02, Medicare Benefit Policy Manual, Chapter 15, section 80.2 states that a psychologist practices independently when:
• He/she render services on his/her own responsibility, free of the administrative and professional control of an employer, such as a physician, institution or agency;
• The persons he/she treats are his/her own patients;
• He/she has the right to bill directly, collect and retain the fee for his/her services; and
• The psychologist is state-licensed or certified in the state where furnishing services. A psychologist practicing in an office located in an institution may be considered an independently practicing psychologist when both of the following conditions are met:
• The office is confined to a separately-identified part of the facility that is used solely as the psychologist’s office and cannot be construed as extending throughout the entire institution; and
• The psychologist conducts a private practice (i.e., services are rendered to patients from outside the institution as well as to institutional patients).
Independently practicing psychologists have a more limited benefit under the Medicare program than clinical psychologists. With a degree starting at the master’s level of psychology, independently practicing psychologists are authorized to bill the program directly solely for diagnostic psychological and neuropsychological tests that have been ordered by a physician, clinical psychologist or nonphysician practitioner who is authorized to order diagnostic tests.
Independently practicing psychologists are not authorized to supervise diagnostic psychological and neuropsychological tests. Any tests performed by an independently practicing psychologist must fall under the psychologist’s state scope of practice.
Billing Agencies
(Unless otherwise stated, this section applies to the Form CMS-855A, the Form CMS-855B, and the Form CMS-855I.)
A billing agency is an entity that furnishes billing and collection services on behalf of a provider or supplier. A billing agency is not enrolled in the Medicare program. A billing agency submits claims to Medicare in the name and billing number of the provider or supplier that furnished the service or services. In order to receive payment directly from Medicare on behalf of a provider or supplier, a billing agency must meet the conditions described in § 1842(b)(6)(D) of the Social Security Act.
The provider shall complete section 8 of the Form CMS-855 with information about all billing agents it utilizes. As all Medicare payments must be made via electronic funds transfer, the contractor need not verify the provider’s compliance with the “Payment to Agent” rules in CMS Publication 100-04, chapter 1, section 30.2. The only exception is if the contractor discovers that the “special payments” address in section 4 of the provider’s Form CMS-855 application belongs to the billing agent or agency. In this situation, the contractor may obtain a copy of the billing agreement if it has reason to believe that the arrangement violates the “Payment to Agent” rules.
If the chain organization listed in section 7 of the Form CMS-855A also serves as the provider’s billing agent, the chain must be listed in section 8 as well.
For further information on billing agencies, see CMS Publication 100-04, chapter 1, section 30.2.4.
Special Requirements for Home Health Agencies (HHAs)
(This section only applies to the Form CMS-855A.)
A. Capitalization
For initial applications, the contractor shall verify that the HHA meets all of the capitalization requirements addressed in 42 CFR §489.28. (Note that capitalization need not be reviewed for revalidation or reactivation applications.) The contractor may request from the provider any and all documentation deemed necessary to perform this task. Failure to meet the capitalization requirements shall result in a denial or revocation, as appropriate. For more information on HHA capitalization, see §489.28 and section 15.26.2 of this chapter.
B. Nursing Registries
If the HHA checks “yes” in section 12B, the contractor shall ensure that the information furnished about the HHA nursing registry is accurate. (A nursing registry is akin to a staffing agency, whereby a private company furnishes nursing personnel to hospitals, clinics, and other medical providers.)
Contact Persons
Unless stated otherwise in this chapter or in another CMS directive - or unless the provider requests that the contractor communicate with only a specific individual (e.g., an authorized official) or via specific means (e.g., only via the correspondence address e-mail) - the contractor has the discretion to use the contact persons listed in section 13 of the Form CMS-855 for all written and oral communications (e.g., mail, e-mail, telephone) related to the provider’s Medicare enrollment. Such communication need not be restricted to a particular enrollment application of the provider’s that the contractor is currently processing. Nor is the contractor required (again, unless either CMS or the provider directs otherwise) to send certain materials to the correspondence mailing or e-mail address rather than the contact person’s mailing or e-mail address.
The provider may have as many contact persons as it wishes.
If the contractor discovers that a particular contact person qualifies as an owning or managing individual, the provider shall list the person in section 6 of the application.
If multiple contact persons are listed, the contractor has the discretion to select the individual to contact unless the provider indicates otherwise via any means. In addition:
• The contractor may use multiple contact persons throughout the enrollment process; it need not use the same individual for the entire duration unless, again, the provider indicates otherwise.
• All contact persons shall be stored in PECOS and shall not be removed unless the provider requests the removal via letter, e-mail, or fax.
Pub. 100-02, Medicare Benefit Policy Manual, Chapter 15, section 80.2 states that a psychologist practices independently when:
• He/she render services on his/her own responsibility, free of the administrative and professional control of an employer, such as a physician, institution or agency;
• The persons he/she treats are his/her own patients;
• He/she has the right to bill directly, collect and retain the fee for his/her services; and
• The psychologist is state-licensed or certified in the state where furnishing services. A psychologist practicing in an office located in an institution may be considered an independently practicing psychologist when both of the following conditions are met:
• The office is confined to a separately-identified part of the facility that is used solely as the psychologist’s office and cannot be construed as extending throughout the entire institution; and
• The psychologist conducts a private practice (i.e., services are rendered to patients from outside the institution as well as to institutional patients).
Independently practicing psychologists have a more limited benefit under the Medicare program than clinical psychologists. With a degree starting at the master’s level of psychology, independently practicing psychologists are authorized to bill the program directly solely for diagnostic psychological and neuropsychological tests that have been ordered by a physician, clinical psychologist or nonphysician practitioner who is authorized to order diagnostic tests.
Independently practicing psychologists are not authorized to supervise diagnostic psychological and neuropsychological tests. Any tests performed by an independently practicing psychologist must fall under the psychologist’s state scope of practice.
Billing Agencies
(Unless otherwise stated, this section applies to the Form CMS-855A, the Form CMS-855B, and the Form CMS-855I.)
A billing agency is an entity that furnishes billing and collection services on behalf of a provider or supplier. A billing agency is not enrolled in the Medicare program. A billing agency submits claims to Medicare in the name and billing number of the provider or supplier that furnished the service or services. In order to receive payment directly from Medicare on behalf of a provider or supplier, a billing agency must meet the conditions described in § 1842(b)(6)(D) of the Social Security Act.
The provider shall complete section 8 of the Form CMS-855 with information about all billing agents it utilizes. As all Medicare payments must be made via electronic funds transfer, the contractor need not verify the provider’s compliance with the “Payment to Agent” rules in CMS Publication 100-04, chapter 1, section 30.2. The only exception is if the contractor discovers that the “special payments” address in section 4 of the provider’s Form CMS-855 application belongs to the billing agent or agency. In this situation, the contractor may obtain a copy of the billing agreement if it has reason to believe that the arrangement violates the “Payment to Agent” rules.
If the chain organization listed in section 7 of the Form CMS-855A also serves as the provider’s billing agent, the chain must be listed in section 8 as well.
For further information on billing agencies, see CMS Publication 100-04, chapter 1, section 30.2.4.
Special Requirements for Home Health Agencies (HHAs)
(This section only applies to the Form CMS-855A.)
A. Capitalization
For initial applications, the contractor shall verify that the HHA meets all of the capitalization requirements addressed in 42 CFR §489.28. (Note that capitalization need not be reviewed for revalidation or reactivation applications.) The contractor may request from the provider any and all documentation deemed necessary to perform this task. Failure to meet the capitalization requirements shall result in a denial or revocation, as appropriate. For more information on HHA capitalization, see §489.28 and section 15.26.2 of this chapter.
B. Nursing Registries
If the HHA checks “yes” in section 12B, the contractor shall ensure that the information furnished about the HHA nursing registry is accurate. (A nursing registry is akin to a staffing agency, whereby a private company furnishes nursing personnel to hospitals, clinics, and other medical providers.)
Contact Persons
Unless stated otherwise in this chapter or in another CMS directive - or unless the provider requests that the contractor communicate with only a specific individual (e.g., an authorized official) or via specific means (e.g., only via the correspondence address e-mail) - the contractor has the discretion to use the contact persons listed in section 13 of the Form CMS-855 for all written and oral communications (e.g., mail, e-mail, telephone) related to the provider’s Medicare enrollment. Such communication need not be restricted to a particular enrollment application of the provider’s that the contractor is currently processing. Nor is the contractor required (again, unless either CMS or the provider directs otherwise) to send certain materials to the correspondence mailing or e-mail address rather than the contact person’s mailing or e-mail address.
The provider may have as many contact persons as it wishes.
If the contractor discovers that a particular contact person qualifies as an owning or managing individual, the provider shall list the person in section 6 of the application.
If multiple contact persons are listed, the contractor has the discretion to select the individual to contact unless the provider indicates otherwise via any means. In addition:
• The contractor may use multiple contact persons throughout the enrollment process; it need not use the same individual for the entire duration unless, again, the provider indicates otherwise.
• All contact persons shall be stored in PECOS and shall not be removed unless the provider requests the removal via letter, e-mail, or fax.
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