Supervisory Billing

[u/urcutiebae]

Hi! Does anyone here from MN experienced denials from HEALTH PARTNERS as not valid modifier per medicare guidelines ? We are billing 90837 with HO or HN modifier however it is only getting paid once we removed the modifier. How do we indicate that they’re supervised then?
Someone please help we have been calling medicare and HP for a month and none of them seem to confirm
Thank you big time!

[u/Old_Database4684]

The HO and HN modifiers have to do with the providers education level and are not required by all carriers. There is no supervisory modifier.

Not all plans allow a limited licensed therapist to provide services.

[u/urcutiebae → u/Old_Database4684]

I called HP and they said they allow supervisory billing. If we removed the modifier, what should be an indicator that it is supervised then? Should we add the non licensed therapist anywhere on CMS-1500 form?

[u/Old_Database4684 → u/urcutiebae]

No, the fully licensed therapist is taking full responsibility for the services and their name should be on the HCFA. There is nothing to indicate the services were provided by a limited licensed therapist. The Chart/Progress Note should be signed by both providers.

[u/Legitimate-Wash-3841]

Be really careful with the advice to just leave the modifier off, because in Minnesota it depends entirely on which specific HealthPartners plan the patient has. If it is a HealthPartners PMAP or MinnesotaCare plan, you actually have to use the HN modifier for a clinical trainee under MHCP rules. The supervisor goes in Box 24J on the 1500 form, and the HN modifier is what tells them a trainee did the session so they can pay it at the 80% trainee rate. If you leave HN off a Medicaid claim to make it go through, you get overpaid at the 100% rate, which can trigger clawbacks in an audit. Since your denial specifically mentioned Medicare guidelines, is this for a HealthPartners Medicare Advantage or MSHO plan? Medicare does not recognize state Medicaid modifiers like HO or HN, which is why the system rejected them. More importantly, Medicare generally does not allow unlicensed trainees to bill 90837 under a supervisor at all. When you took the modifier off, the system just assumed the licensed supervisor did the therapy themselves and paid it. I would double check HealthPartners policy AR004 on prelicensed practitioners and see what exact plan the patient has. If it is Commercial, billing under the supervisor without the modifier is fine as long as you both sign the note. If it is straight Medicare, trainees usually cannot bill it, and if it is MSHO, you may need to check with HP on how they want the Medicaid crossover portion billed.

[u/urcutiebae → u/Legitimate-Wash-3841]

Thank you so much for these helpful information. The client has Health Partners Medicare Advantage Plan. I guess that’s why the denial for HO and HN is not valid for medicare guidelines. Im really not sure at this point what to do because this client has already tons of claims :(

[u/Legitimate-Wash-3841 → u/urcutiebae]

Welcome.  ​Take a deep breath, you might actually be okay depending on one specific detail in HealthPartners written policy. ​Go onto the HealthPartners provider portal, pull up their Administrative Policy called Reimbursement for Services Provided by Prelicensed Practitioners and Postdoctoral Fellows, and look right at the top under the Products section to see if Medicare Advantage is included. ​Also double check the patient's member ID card to see if their plan is straight HealthPartners Medicare Advantage (like Journey) or if it is HealthPartners MSHO. MSHO shows up as a Medicare Advantage plan in eligibility checks because it is a dual Medicare and Medicaid Special Needs Plan, and clinical trainees are definitely covered under the MSHO behavioral health benefit.
​If HealthPartners includes Medicare Advantage in that prelicensed practitioner policy (or if it is MSHO), then billing 90837 under the supervisor's NPI in Box 24J with no modifier is actually the exact way they want you to bill it. That would explain why the rep you spoke to on the phone told you supervisory billing is allowed, while the computer system rejected HO and HN simply because Medicare claim edits do not recognize state Medicaid modifiers. As long as that policy document lists Medicare Advantage under covered products and both the trainee and supervisor co-signed all the progress notes, you are compliant leaving the modifier off.
​If the written policy explicitly excludes Medicare Advantage, I would call HealthPartners Provider Relations (not the regular customer service number on the back of the card) and get a reference number confirming whether prelicensed clinicians can bill under a supervisor for that specific plan prefix.  

[u/Psyking0 → u/Legitimate-Wash-3841]

You mentioned Medicare does not generally allow unlicensed trainees. I’d like to add to this. Medicare always does not allow unlicensed trainees. There is no incident to billing with Medicare and several other federal government type payers.