The leading practice resource for behavioral health providers — since 1974

Volume 36, No. 10, Issue 438
October, 2010

PRACTICE BUILDING:  Beef up the bottom line with a phone consultation policy

Providing additional services for patients outside the therapy room can be a sticky issue, particularly if you derive much of your income from managed care.  How much telephone time can you spend with patients?  Can you bill managed care for this time?  Should you bill the client directly?

In the box on page 6, we look at some of the legal issues.  The word we get is that you might--in some cases--be reimbursed for this time while keeping your practice on firm legal and ethical ground.

But first we hear from Holly Hunt, a therapist and practice consultant in Los Angeles, who believes that clinicians should charge for phone chats on a pro-rated basis--just as attorneys do.

Hunt works with managed care clients, but she makes it clear at intake that if they need to talk to her by phone, they’ll be charged over and above their co-pay.  The outgoing message on her answering machine spells out the times durig the day when she’ll be returning calls.

She bases her phone charges not on managed care rates but on her own standard fee--$130 for a 45-minute session.  “That way, they’re paying something for the service, which keeps it professional,” Hunt says.  “And they have to decide:  Is this important enough for me to pay for a phone visit?”

Hunt uses the 15-minute gaps between sessions to return calls.  “You can do a little bit each hour,” she says.  “You can get a lot done, and then you don’t have that much to do at the end of your client week.”  (Of course, it’s not necessarily that simple--see the box.)

A lot of therapists try to bill managed care for this kind of phone work.  But that’s a mistake, says Jean Thoensen, who owns PsychBiller, a therapist billing service in Centreville, VA.  She says therapists often try to bill phone sessions using a 90806 for individual therapy.

This is outright fraud,” she says.  “Because the definition of CPT code 90806 specifically includes the phrase, ‘face-to-face.’  A phone session clearly doesn't meet that definition.”

Rarely, she goes on to say, a managed care company will approve a phone session for reimbursement.  But you should check with the company ahead of time--don’t try for it after the fact.  “I suggest using CPT codes 99371, 99372, or 99373, depending on the length of the call.  Otherwise I tell my providers that this is a no-no, and phone sessions are self-pay.”

Those codes were adopted by the AMA in 1995, by the way.  Use a 99371 for a brief phone consultation, 99372 for an intermediate call, and 99373 for a complex exchange.  The definition of terms like “brief” and “complex” are subjective, Thoensen adds.  She defines “brief” as 15 minutes.

Contacts: 1) Holly Hunt, Long Beach, CA (562) 987-8947,; 2) Jean Thoensen, PsychBiller, LLC, Centreville, VA, (703) 266-8612,

Legal and ethical issues

Should you check with a patient’s managed care company before billing directly for a brief phone call? Yes, advises Bryant Welch, a risk management attorney who works with the American Professional Agency, a malpractice insurance broker.

He says some contracts prohibit clinicians from charging additional fees. “Some require that the therapist accept the managed care fee as payment in full for treatment,” Welch points out. “It doesn’t provide for billing for telephone contacts. The billing could be interpreted as a violiation of that provision.”

Jean Thoensen, the billing professional quoted in the accompanying article, hasn’t found that to be a problem. She says billing the client directly for short phone conversations is akin to billing them for no-shows.

Many managed care contracts, including some Magellan contracts she’s seen, allow a clinician to charge a client for a no-show at the managed care rate. Thoensen suggests staying within that range for phone consults, too, rather than charging your full rate.

“As long as the patient has signed an agreement at intake that they will pay for phone calls out of pocket, then there’s no problem at all. It doesn’t even need to be reported to your managed care company—no managed care company is going to say you can’t talk to your patient on the phone.”

Thoensen adds that she’s never heard of anyone

getting into hot water with a managed care company or licensing board over phone billing or billing for no-shows. In fact, she works with one client who charges clients over and above her full fee for missed appointments.

“If the client cancels within 24 hours, she charges $100, which is her full fee,” says Thoensen. “But if the person just doesn’t show up, she charges $125.” Does she ever collect? “Sometimes,” Thoensen says.

Our advice is to check your managed care agreements to see if these questions are addressed. Some companies cover these issues on their websites as well.

By the way, the American Psychological Association ethics code—adopted verbatim by many state licensing boards—approves of billing for phone therapy. The same goes for email, according to Stephen Behnke from the APA’s office of ethics.

“The ethics code doesn’t specify modality, so it would apply to any type of service the [therapist] would be providing,” Behnke says.

Phone therapy, “is something people are interested in looking at for a variety of reasons—maybe they live in rural areas, or they may be ill and can’t travel. There are a lot of people within the APA who think that can be done successfully.”

A final note: Bryant Welch reminds us that even with private pay clients, policies concerning billing for phone sessions should be spelled out at intake.