memoranda 2005

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7/11/2005 12:00:00 AM

ARTICLE 28 CLINICS (E-mail sent regarding two critical memos from DOH.)

                 UPDATE

 For further information, contact: Mike Alvaro, Associate Executive Director

On Friday, July 8, DOH sent out two critical memos on issues we have been following for some time regarding Article 28 clinics.

1)     Billing for Social Work Services – The Department mailed a “Dear Article 28 Certified Clinic Provider” letter clarifying the Department’s position on billing for social work, clearly identifying the letter’s contents as interim guidance.  The letter notes that DOH will be issuing regulations within the next 6 to 8 months to permit Article 28 clinics to bill for medically necessary individual psychotherapy services provided by qualified social workers.  Billing is prohibited for group services and those provided in part-time clinics.

2)     Group Services Billing – (NOTE: This was sent only to providers DOH has identified as having billed for group services in the past.)  In this letter, DOH outlines their interim approach in response to CP of NYS’s objections to the July 2004 prohibiting the billing of group services.   The letter permits the continued billing of group services (for physical, occupational and speech therapy and mental health services) so long as the group therapy billings are properly identified and documented.   This letter assures providers that they will not be subject to disallowance on audit for these services until the DOH/OMRDD provider council develops an overall solution to this and other problems.

It’s important to note that the provider council is specifically referred to in both letters, and it is our understanding that the letter detailing the provider council’s establishment will be sent to providers this week.  The two Article 28 letters have been altered from their earlier versions and include much of what we had asked for – we realize they are not the ideal solution, but we’re optimistic about provider council which will begin soon.

If you have not received the group billing services letter and have been billing for group services, please contact me right away and we will work to get you included.

If you have any questions or would like further information, please call or e-mail me.

Thank you.

Mike Alvaro

Associate Executive Director

(518) 436-0178/FAX (518) 436-8619

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