By: Samantha Slaughter, Psy.D. Director of Professional Affairs
Being the Director of Professional Affairs (DPA) is never boring, that’s for sure. A lot has happened since my initial email to you in January. Mostly, I am regularly meeting with and responding to questions from you which is my primary responsibility. I am getting systems in place so that I can respond to member emails and phone calls in a timelier manner. Thank you for your patience so far! In addition, I am attending meetings with the WSPA Board of Trustees, the University of Washington’s Psychology Internship Program Steering Committee, and the Examining Board of Psychology. I am also a member of a work-group with the Bree Collaborative that was tasked by the Washington Legislature to establish clinical best practices related to the change to our Duty to Warn laws due to the Volk decision in 2016. I traveled to Olympia twice to testify on behalf of WSPA, which gave me the chance to meet some of the lobbyists and representatives of other mental and physical health providers.
In the first quarter of 2019, I made progress on the following advocacy efforts:
- LNI – For those of you who provide services for LNI, I have some news. For a very long time now, WSPA has worked to bring to their attention ethical and legal problems related to the policy of using the WHODAS 2.0 and requiring that the scores are disclosed to LNI. I can report that they now appear to hear the message and are working to change the policy. Do not alter how you are currently managing this issue as policy change comes slowly, especially with an institution like LNI. I’ll check in with them periodically and continue to offer to engage in the policy discussion so that their mental health requirements are changed as soon as the process allows. The goal is to have a policy that allows psychologists to choose the instrument(s) used and not to be required to disclose raw data.
- New testing codes – After filing a complaint on behalf of all psychologists in Washington with the Office of the Insurance Commissioner (OIC) on January 10, 2019, I was asked to assist in the drafting of a letter to all insurance companies that went out March 27, 2019. My complaint discussed the fact I heard from many psychologists across the state and determined that the none of the insurance carriers were ready to provide prior authorization and/or to correctly pay for services billed with the new CPT codes. I asked that the OIC help us by requesting that the insurance companies communicate with all in-network providers about the new testing codes. The OIC’s letter asked that all insurance companies “send written information about appropriate prior authorization (if applicable), billing, and interpretation of the new CPT codes for psychological and neuropsychological assessments to all network providers no later than April 30, 2019. This information should be separate from regular newsletter or other such provider-related communication” (emphasis in original).
Since the OIC letter was sent, a response was received from the Association of Washington Healthcare Plans (AWHP) that asks for more details and requests, among other things, that the OIC “share the specific complaint or complaints received, so that we can understand the time frame of the issue raised with the OIC, how widespread the issue is, the location of the provider or providers, the type of claims involved, the market and coverage involved, and whether enrollee services were affected. Please confirm whether or not the complaints were communicated to specific carriers and resolved.”
There are other requests from the AWHP as well, but I’ve highlighted the one above to demonstrate the importance of filing complaints with the OIC. I have communicated with some psychologists who say they are worried about retaliation should they file a complaint against a specific insurance company (this does not typically happen to my knowledge, which Lucy Homans and the DPAs nationwide confirmed). Other psychologists consider the process onerous; still others are completely unaware that complaints to the OIC are an avenue for them. What the AWHP request shows is that insurance carriers depend on complaints and see them as a legitimate part of the process. I’m going to write a separate article about how and when to file a complaint, but I want to show you with this real-life example how complaints are our responsibility and serve us well!
- We and a few other states were approached by APA Office of Legal and Regulatory Affairs about starting a pilot project to lay the foundation for Medicaid to pay for services provided by trainees in Washington State. This is very exciting! APA completed a pilot in Washington, DC and is looking to expand to more locations. Medicaid paying for trainee services has the potential to strengthen current training sites and to encourage the creation of new ones, thereby expanding access to mental health care for the Medicaid population. WSPA is communicating with APA on this possible project and hopes to move forward on a pilot here soon.
That’s the year so far. Below you will find an outline of the issues we continue to watch and/or grapple with as of February 8, 2019:
- Testing codes – I have information and stories from several of you about your experiences with the new testing codes, but please keep this information coming. Also, let me know if you receive any communication from the insurance companies about the new testing codes. APA is also looking to collect information on people’s experiences with the new testing codes. You can fill out their survey, but please do email me separately as I will not receive their data.
- Scope of practice – WSPA continues to work to protect our scope of practice when it comes to the supervision issue with applied behavior analysts and dual credentialing for substance use disorder treatment.
I have scheduled upcoming speaking engagements with various groups about practice-related issues. Contact me if you’d like me to present on a practice issue for your group/organization. As always, the best way to reach me is to send an email to DPA@WSPApsych.org. I will do my best to keep you informed of all relevant issues. One final note – if you are unsure of your WSPA membership level, log in to the member portal or contact the WSPA office. Unlimited DPA consultation is available for members at the Premium or higher level. There are other benefits as well, so make sure your membership is at a level that works for you.