Of late, there has been an increase in the number of requests we are seeing for progress notes by Payers. While most of these are reasonable requests, primarily in support of higher levels of coding, others fall into a gray area of need to know, especially in the case of behavioral health providers.
It is always a little disconcerting when an Insurance Company requests Psychotherapy session notes as part of their claims adjudication process. It is something we, and consequently our clients struggle with. How do you comply with the requirement to be reimbursed while maintaining HIPAA compliance and being sensitive to patient privacy?
Well, HIPAA’s psychotherapy notes provision safeguards sensitive patient information. But it is critical that you the provider follow certain guidelines during the consultation and encounter.
In this context, it is important to differentiate Progress notes from Psychotherapy notes. Do not keep these n the same folder or location in your medical records system. When an insurance company requests notes, Progress Notes are the only notes that are required to be sent. Separating the two will avoid the accidental submission and eliminate the possibility of administrative over reach.
Moreover, most States have laws in place that are even tighter when it comes to protecting patient privacy. HIPAA requires specific patient permission to release psychotherapy notes – and more importantly – insurance companies cannot deny payment if the permission is withheld. The American Psychological Association has some excellent resources to assist you and additional details on the topic that can be found at https://www.apa.org/monitor/feb03/hipaa.
So go ahead and start SEPARATING your PROGRESS notes from your PSYCHOTHERAPY notes. And call us for more ways to ensure you get paid while staying compliant!
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