August 25, 2023

Recently a NYS Council member agency rep wrote to me with a question about whether an LMHC that has not yet completed Medicaid credentialing can bill for services while they wait to complete the (credentialing) process.   Obviously our overarching concern is with the extensive backlog practitioners currently face as they wait to be credentialed AND the adverse impact the backlog has on access to care and your ability to recruit and retain valued practitioners.

I asked OMH for its official response to the question about billing in this situation.  Here’s the response:

For LMHCs, or any enrollable Medicaid practitioner delivering services and billing under an OMH licensed or designated program (example- Article 31 Clinic or CFTSS), it is appropriate to provide Medicaid billable services while in the process of completing credentialing.  The agency may use the supervisor (or other appropriately credentialed/enrolled member of the treatment team’s) NPI until such time the unenrolled Medicaid practitioner has completed enrollment.  Providers must complete both the attending and referring fields of the claim per the OMH guidance: https://omh.ny.gov/omhweb/clinic_restructuring/docs/attending_referring_guidance.pdf