Here are three co-therapy scenarios. Will insurance cover them?

Scenario #1: Two therapists have developed a treatment program for couples which involves having two therapists in each session. Can each therapist bill for the session?

A: “It’s double-dipping, two therapists each billing for the same exact session,” says Susan Frager, Owner of Psych Administrative Partners Medical Billing Service (www.psychadminpartners.com). “The insurance company doesn’t view it as two people each offering their expertise on the case.” In their eyes “it’s one encounter, one procedure. Pick one provider and bill under that person.” Remember, of course, that couples therapy sessions are only billable to insurance when there is an identified client with a diagnosis, and usually more than just a DSM-5 Z-code is necessary for coverage (for more on this topic, see my article on couples therapy billing).

Scenario #2: A therapist is providing individual therapy for a client; the client’s partner is seeing another therapist. The two therapists would like to do some couples sessions, with both therapists in the room. Can each therapist bill for the session?

A: This is a little trickier. The billing and documentation would look like one therapist was having a session with his client during the same time period as another therapist was having a session with her client. And both would have to bill for CPT code 90847 (couples/family session), since an individual session was not provided. Finally, each therapist would need to reflect in their client’s clinical records that they provided a session, and record the start and stop time. Could each therapist truly argue that in the same session they were both addressing their individual client’s diagnosis and treatment plan? “That MIGHT fly,” says Frager, “but as a biller, I’d be highly uncomfortable knowingly billing it this way. My instinct screams that an insurance auditor wouldn’t approve it, since they are hired by plans to find excuses to recoup money. My instinct is to play it safe and not do anything that even remotely resembles double-billing.” Even if the plan initially paid for these sessions, you’d risk having to reimburse funds in an audit. “At that point the couple might no longer be in treatment, and you’d have a hard time getting them to reimburse you the money you had to pay back to the plan,” says Frager.

Scenario #3: Two therapists are facilitating a group. Can both bill each group member’s insurance for their time?

A: Group therapy is commonly co-facilitated, but according to Frager, “only one therapist can bill for it. Period. No wiggle room there. It’s customary that the second (non-billing) therapist is reimbursed something for his/her time by the billing therapist” or organization. And if you are a network provider, “I guarantee you it’ll be forbidden to surcharge the client on top of their copayment just because there’s a second therapist,” says Frager. “If the client is private pay, you could do it, but I think it would be a hard sell to the client. If that private pay client is seeking insurance reimbursement, the plan will still limit reimbursement based on their allowed amount for the code, which is determined by one therapist, so it is unlikely they would reimburse more. Also, says Frager, “since it’s a group, presumably made up of several clients with all different financial arrangements, you have to ask yourself: Is it ethical or fair that Client A only has to pay their $15 copayment because their therapist takes insurance, but Client B has to pay $100 because the therapist is out of network and is inflating the charge to allow for 2 therapists?”