Clinical News You Can Use: New Medicaid Rules for Trainees

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Medicaid has paid for psychotherapy for over 30 years, long before mental health professionals were licensed in Wisconsin.  So Medicaid created a credential, Approved Provider, to identify those who could be providers of reimbursed services.  The purpose of the credential was to identify persons who had met a minimum level of presumed competence. That credential is the well-known “3000-hour letter” formerly called the “Dan Crossman letter,” then when he retired, the “Otis Woods letter,” and more recently the “Mark Hale letter.”

Psychologists have been licensed since around 1977 and approved for insurance payments since around 1978.

In the early 1990s, a law was passed creating certification of Marriage and Family Therapists, Social Workers and Clinical Social Workers, and Professional Counselors.  Certification only meant that no one could use those titles unless they met certain minimum requirements and were approved by the Department of Regulation and Licensing.

A law passed in 2001 upgraded certification to licensure.  That meant not only were the titles protected, but the very practice of psychotherapy was limited to those with one of these licenses.

All along, graduate students could practice under Medicaid and bill under a supervisor.

All this time, around 34 years, those who had graduated with a masters or doctorate, but who had not completed the Approved Provider credential or, after 1993, certification, could not practice under Medicaid – their services could not be billed to Medicaid.  This gap left new Masters level clinicians scrambling to get 3000 hours.

Finally, this week, Medicaid issued a bulletin, 2012-64, rectifying this long-standing problem.  From now on, masters-level clinicians who procure a training license and PhD/PsyD level clinicians who are on post-doctoral training will be able to credential as Medicaid providers.  They will be known as Qualified Treatment Trainees (QTT), a title defined under DHS35.03.  These provisions ONLY apply when the clinician works for a licensed mental health clinic.

This a major step to enable clinicians to train for licensure and to increase the capacity of the mental health community to serve Medicaid clientele.

To read the bulletin, go to

The basic provisions are as follows:

1.QTT’s are only permitted to bill Medicaid by working within licensed outpatient clinics.

2. Changes are retroactive to 11/1.

3. 4 groups of services are covered:

. Intensive In-Home Mental Health and Substance Abuse Treatment Services for Children, a Healthcheck “Other Service.”

. Outpatient Mental Health.

. Outpatient Mental Health and Substance Abuse Services in the Home or Community for Adults.

. Screening, Brief Intervention, and Referral to Treatment (SBIRT).

4. New Billing Modifiers have been developed:  Grad students bill U7 and those QTT qtt pic2clinicians with a training license will use U6.

5. Grad students are billed following DHS 107.01 as always, under a supervisor, while they are in practicum.  The U7 modifier must be on these claims.  Reimbursement is at the supervisor’s rate.  The supervisor must be a Medicaid provider.  [Adding a U6 modifier is a new procedure.]

6. A QTT is someone with the Master’s degree or PhD/PsyD, who must be working toward licensure.  Master’s level staff need a training license.  The person must have a PC-IT, MFT-IT, APSW, or a psych PhD/PsyD.

7. The person must become a Medicaid provider.

8. QTTs working In-Home can only be the second team member on an SED case, not Leads, EXCEPT for 11/1/12 through 1/31/13 — if they were a lead on a UBH case, they can continue as a Lead for that period.

9. Outpatient (IN THE OFFICE) work by QTTs who are on training licenses will be reimbursed at 80% of the rate for licensed providers.  IN HOME work by QTTs who have training licenses will be 100% of the rate for licensed providers.

10. When a QTT becomes fully licensed, they fill out a Provider Change of Address or Status form, F-01181.  That will change the status from RENDERING PROVIDER to BILLING/RENDERING PROVIDER.

11.  This policy change is for Fee for Service, not the HMOs.  The HMOs may adopt the same policy.

This is a terrific and important change that benefits trainees and increases the capacity of the community to offer treatment to Medicaid members.

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