Q: I have an individual part-time private practice in Michigan. In my area, several licensed professional counselors have experienced difficulty gaining access to insurance panels and reimbursement. To help learn from each other, we have begun to discuss becoming a group practice. However, we are struggling with how we look into this option — the legalities, etc. We even wonder if we can advertise together without officially being a group.

Also, in our area, the main insurance carriers are Priority and Blue Cross/Blue Shield. Priority has denied me and several other qualified LPCs, indicating they have “enough” in our area. I am thinking of trying the ad hoc procedure to gain access with Priority. More frustrating is the response I get from Blue Cross/Blue Shield indicating that they will not reimburse any LPC in the state of Michigan. Is this true, and if so, how can we go about changing this? Do we need to employ a physician or psychologist to gain access to Blue Cross/Blue Shield reimbursement? Being only a part-time therapist, I have found this a very time-consuming and frustrating process!

A: The “Private Practice” section of the American Counseling Association’s website (www.counseling.org) includes response letters to denials by managed care companies. To use the letters to become an “ad hoc” or out-of network-provider, you need a client who wants to work with you so you can get paneled. Persistence is key.

Once you are “ad hoc,” you most likely will be included in the database for that managed care company. We have had people get referrals from companies after ad hoc status.

As far as Blue Cross/Blue Shield of Michigan, we have talked with many Michigan counselors and are aware of the problem you described. Have you tried to use your state organization to get Blue Cross/Blue Shield to recognize counselors? Among the letters on the “Private Practice Pointers” section of the ACA website is a template that state organizations can use.

We understand the medical director of Blue Cross/Blue Shield in your state is an M.D. who won’t budge on including licensed counselors. Don’t give up. Unite others and form a committee or join one that is already working on this issue in your state. It is a very important issue, because Blue Cross/Blue Shield recognizes LPCs in almost every other state.

Your question about using a physician or psychologist to get on panels may not work because each provider must submit bills under his or her own national provider identifier (NPI) number. A corporate NPI is good to have, but it’s not enough, because an individual number is also needed on the HCFA CMS 1500.

Your initial question about forming a group practice is good. Consult an accountant in your state for particulars, and then move forward with your idea. It’s also a great idea to advertise and market together. Just make certain that you have a good written agreement defining your group and money issues and containing an exit clause.

Q: A friend of mine has a private practice. However, he does not hold a license or credential in counseling, even though he has a Ph.D. in counseling. He is clocking hours for a credential and is sitting for the oral and written exam that is pending. In the meantime, he has a therapist in his office sign off for billing purposes. Can you clarify the term “therapist of record” and the legalities of such a procedure?

A: With the disclaimer that we are

not lawyers, we’ll offer our opinion — and stress that it is our opinion alone and not that of ACA. In researching “therapist of record,” we found the term only in the literature of physical therapists, speech therapists and occupational therapists. We did not find any references for counselors.

State licensing boards give very clear guidelines about counseling practice and credentialing. Check the state where you work for specifics. In Illinois, where we practice, only licensed counselors may treat clients. We have a two-tiered license with the LPC (licensed professional counselor) as the first credential and LCPC (licensed clinical professional counselor) as the independent credential. With the LPC, a counselor can see clients under the direct supervision of an LCPC. The LPC must disclose that he/she is under supervision. The LPC cannot bill third-party payers such as insurance or managed care.

We don’t think it is ethical to bill under another name. This practice may open both the counselor and the supervisor up to discipline by the licensing board.

Q: In the October 2007 issue of Counseling Today, you addressed a question regarding employee assistance programs (EAPs). I’d like to know which managed care companies you would recommend signing up with as opposed to the ones that have extensive paperwork and horrible rates.

A: ACA’s website contains our list of the top 57 managed care and insurance companies with EAP contact information. We designed the list to include direct links to the provider relations section of each website as well as information on how many lives are covered, reimbursement rates and paperwork requirements. Check the list and decide which of these companies are good for you. We don’t make specific recommendations for obvious reasons (we don’t like lawsuits).

The list and much more information is free for ACA members to download. From www.counseling.org, click on “Counselors” and then “Private Practice Pointers.”

Stay tuned for more information coming in the next few months regarding implementation of a required transfer plan, as addressed by the 2005 ACA Code of Ethics (Standard C.2.h., “Counselor Incapacitation or Termination of Practice”). We will be posting a bulletin on the “Private Practice Pointers” section of the ACA website detailing the essential components.

We hope to see you at the ACA Conference in Hawaii. We will be signing our book, The Complete Guide to Private Practice for Licensed Mental Health Professionals, at the ACA Bookstore in the Convention Center on Thursday, March 27, from 5:30-6:30 p.m. We will also be presenting a preconference Learning Institute, “Starting, Maintaining and Expanding a Successful Private Practice,” on March 27.

In addition, the New York Mental Health Counselors Association will be sponsoring our workshop on private practice at its convention on April 11 at the Marriott Hotel in Albany, N.Y. For more information, visit www.nymhca.org.

Finally, the Illinois Mental Health Counselors Association will be offering the workshop on June 8. More information is available at www.imhca.org.