Our organization just dodged the bullet and survived another audit. It looks like we will have a small payback and it seems our major mistake was relying on a consultant, rather that wading through some of the detailed rules ourselves and assuring that the consultant’s advice was sound.
I understand that when you participate in Medicaid, Medicare, or managed care programs that you are accepting the risk of not getting paid, if you do not comply with all the rules. But it also seems that in most cases the reason for non-payment is some trivial technicality that has no relationship to the quality of service provided or for the value that the participant actually received.
As a case in point we recently started turning away Medicare clients from some of our rural offices because of the difficulty we have had in recruiting licensed clinical social workers for some of these areas. For many years we provided treatment to these clients with other staff and simply accepted the fact that we would not be compensated. However, I defy anyone to show me any evidence that the treatment provided by licensed clinical social workers is superior to the treatment provided by licensed mental health counselors (or unlicensed for that matter). Where is evidence-based decision making when you really need it.
We all know that many of these kind of rules are the result of the lobbying by our professional “guilds” that have the resources to push their member’s agendas. I don’t fault them, but it seems that governmental regulatory agencies have latched on these rules as a pretext to garner uncompensated services for their participants.
Unfortunately we provide intangible services, not products, so we can never repossess what these funders have appropriated from us.