Figuring out the Alphabet Soup of MH/DD/SA: Licensure & Billing for NC Clinical Social Workers

Figuring out the Alphabet Soup of MH/DD/SA: Licensure & Billing for NC Clinical Social Workers
Jack Register, MSW, LCSW Director of Advocacy & Legislation
Katherine Rinehart, MSW, LCSW Legislative Chair

NASW-NC receives calls on a daily basis from students, PLCSWs, seasoned clinicians, agency billing staff, legislators and policy makers from all over the state who are confused about requirements for social work licensure and billing for services provided to Medicaid recipients in the State of North Carolina. We would like to address some of these concerns.
Licensure Requirements for the Provisional Licensed Clinical Social Worker (PLCSW)
In regard to becoming a Licensed Clinical Social worker in the State of North Carolina, the law states that to practice clinical social work in NC you must be licensed as either a PLCSW or a LCSW.

The Provisional Licensed Clinical Social Worker license (PLCSW) is a license that allows social workers with a Master’s Degree in Social Work to practice clinical social work while gaining the necessary supervised experience to become fully licensed.  As with other social work certification/licensure levels, the P-LCSW is issued for two years.  The PLCSW will not be eligible for the LCSW in less than 2 years.

The PLCSW must be renewed every 6 months during the provisional period. The PLCSW must also take and pass the clinical level exam during this two-year period.  Upon passing the exam, the provisional status can be held for up to six (6) years from the original issue date to accumulate the required supervised clinical experience. During the provisional period, the PLCSW must complete a minimum of 3000 hours post MSW employment with 100 hours of clinical supervision in order to be eligible for the LCSW license. The required clinical supervision during the provisional period must be provided by a LCSW in order for the PLCSW to receive credit toward the LCSW license. A social worker holding a valid, current PLCSW license is considered to be licensed to practice clinical social work.

The North Carolina Social Work Certification and Licensure Act very clearly states that anyone engaged in the practice of clinical social work must be licensed by the NC Social Work Certification & Licensure Board (NCSWCLB) as either a PLCSW with the concurrent supervision, or a LCSW with the ability to practice independently. Social workers seeking licensure are strongly encouraged to understand the law governing the practice of clinical social work in the State of North Carolina. Questions may be directed to the (NCSWCLB) at www.ncswboard.org; or 800-550-7009.

Reimbursement for services provided by a Provisional Licensed Clinical Social Worker
Billing for services rendered by a PLCSW is confusing and complex. Billing procedures change frequently and clinical social workers providing behavioral healthcare services are advised to become familiar with acceptable billing practices and procedures.

There are currently three ways for PLCSWs to receive payment for their services.
Private pay (fee for service): a client can pay a PLCSW directly for services provided. Clients paying via this method should insure that the PLCSW meets the standards set forth by the licensure board (e.g. the PLCSW holds a valid, current license to practice clinical social work in NC). Note: A PLCSW must have special permission from the licensure board to be in private practice.
H codes (Medicaid only): H codes are billed through the LME for PLCSWs. The PLCSW’s employing agency must have a contract with the LME in order to do this. These codes are slated to end June 30, 2010. It is the position of all the social work organizations (i.e., NASW-NC & NCSCSW) that the Division of Medical Assistance develop a permanent billing method for clinical social workers. We continue to work diligently to fix this issue.
“Incident to:” (Medicaid only) PLCSWs who are not contracted with a LME must use incident to billing procedures. Incident to billing occurs when a non independent practitioner uses the billing number of an independent practitioner (Medical Doctor-M.D.) to bill for services rendered. Medicaid does not allow PLCSWs to enroll in their program as independent practitioners. Therefore, PLCSWs must use incident to billing practices in order to receive reimbursement for services rendered. This requires a M.D. to be associated with the agency in which the PLCSW is providing services. The Medical Doctor, in this case, must be physically in same building as the PLCSW at the time services are rendered. PLCSWs cannot do incident to billing using an LCSW, LPC, LMFT, LCAS or PhD.

Again, all the social work organizations hold the position that this method is cumbersome at best. We are working to develop another structure. However, at this time, there are no alternatives available to PLCSWs for billing Medicaid. It is the responsibility of the social worker to know how their services are being billed using their license and enrollment numbers.

Reimbursement for services provided by a Licensed Clinical Social Worker (non-Provisional)

Licensed Clinical Social Workers (non-provisional) can apply to the Division of Medical Assistance (Medicaid) for enrollment as a direct enrolled, independent Practitioner (please see DMA website for application information): www.dhhs.state.nc.us/dma
Upon completion, acceptance, and approval of the application by DMA, the LCSW must then apply for a National Provider Identifier number (NPI). Information about the NPI can be accessed through the following link: www.dhhs.state.us/dma/NPI/index.htm
The NPI is formerly known as the Medicaid Provider Number. The LCSW must have a NPI number in order to bill for services rendered to a Medicaid recipient. There three methods of reimbursement for a LCSW’s services:

The LCSW can direct bill Medicaid (or other insurance plan if he/she is an approved provider for that plan) for his/her own services using a paper claim form or through electronic billing (third-party payment).
Private Pay (fee for service)
LCSWs may also elect to have the provider agency employing or contracting with the LCSW to bill for services rendered if same provider agency has a multispecialty group number.
Due to the complex and evolving nature of billing practices and procedures, all clinical social workers (PLCSW and LCSW) are encouraged to understand your agency’s policies and procedures for service delivery and billing. The following are suggestions to consider.
LCSWs and PLCSWs engaging in a contractual agreement to conduct behavioral healthcare services with a provider agency are encouraged to thoroughly understand agency billing policies and procedures. Clinical social workers are directly responsible for all billing done under their name. Requesting to review the agency’s EOB’s (Explanation of Benefits) on a regular basis is advisable.

As always, documentation is critical. Whether it is for supervision sessions, administrative supervision, or dialogues with the reimbursement companies.
LCSWs providing clinical supervision for PLCSWs should be specific and include nature, scope, and objectives of supervision. If a LCSW is providing clinical supervision for a PLCSW within differing agencies, the LCSW is encouraged to maintain contact with the PLCSWs on-site supervisor. Regardless of whether clinical supervision is being conducted by parties within the same place of employment, all supervisory sessions should be documented. The NCSWCLB website (www.ncswboard.org) contains a manual for Clinical Supervisors (click “forms”).

The following is a glossary of commonly referenced terms:
LME: Local Management Entity. The local governmental authority for the MH/DD/SAS system.
EOB: Explanation of Benefits. Sent by insurance payor sources breaking out payments.
H codes: Medicaid code that is used for billing for services rendered. This code can be used by clinicians for particular purposes. Commonly used by PLCSWs and billed through LMEs. The PLCSW must have a contract with their local LME in order to bill using H codes.

Finally, it is our responsibility to care for our profession. Advocacy efforts have to be informed by what you are experiencing in the field. If you run into a problem, let us know. Jack can be contacted at the chapter by email at Jack@naswnc.org or by phone at 919-828-9650. While we can offer consultation and, at times, intervention to larger system issues we cannot guarantee we can “solve” your problem. We can, however, guarantee, that it informs and drives our efforts in advocacy with the Governor, the Divisions, the legislature, and with third party payers. We remain dedicated to protecting and advancing the profession of Social Work.
Jack is the Director of Advocacy & Legislation for NASW-NC. He is an advocate, lobbyist, coalition member, organizer, and policy analyst for the association. Jack is a licensed clinical social worker with practice experience in mental health, medical, nonprofit, and private practice settings.
Katherine is the NASW-NC Legislative Chair and is in private practice in Raleigh.