8/20/2024

CMS Requirements and Credentialing for Psychological Services

According to CMS policy, a person must be licensed by the state where practicing to perform psychological services. Additionally, the individual’s training and scope of practice must allow that person to perform such services. These training and license requirements are intended to ensure an adequate level of expertise in the cognitive skills required to perform diagnostic and therapeutic psychological services. Additionally, these requirements help ensure patients receive the best possible care.

Under the “incident-to” provision, individuals who are not licensed, or otherwise authorized by state law to provide psychological services, may not provide these services. This level of professional credentialing is necessary to furnish appropriate medically necessary psychological services. The description below details who can perform services under the “incident-to” provision.

What is “Incident-to”?

“Incident-to" a physician's professional services means that the services or supplies are furnished as an integral, although incidental, part of the physician's personal professional services in the course of diagnosis or treatment of an injury or illness. Coverage of services and supplies “incident-to” the professional services of a physician in a private practice is limited to situations in which there is general physician supervision of auxiliary personnel. To be considered an employee (auxiliary personnel), the nonphysician performing an “incident-to” service is defined as any individual who is acting under the supervision of a physician, regardless of whether the individual is an employee, leased employee, or independent contractor of the physician or legal entity that employs or contracts with the physician.

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