Reflections on 2024 and What Lies Ahead in 2025 for Behavioral Health Professionals
A new year is upon us! Looking back… Wow, we went through the ringer.
Specific payer updates and things to be prepared for in 2025 are below, but first let’s take stock of 2024.
First was the Change Healthcare Crisis in February. Like Covid, our industry had to pivot immediately in order to get 1/3 of our country’s claims processed and remittance advice back to our clients. I’m proud of how the team at Breezy worked through that and continue to work through some of the lingering remittance issues for some of our non-BreezyNotes billing customers.
Then in July the 21st Century Cures Act took effect, and despite notifications and providers calling Medicaid to confirm enrollment, and often being told incorrectly that, yes, they were enrolled, many of our customers found they were in fact NOT properly enrolled resulting in warning letters from payers.
This stemmed from how Medicaid had previously added providers to their rosters. If a provider was not enrolled with Medicaid, but submitted claims through an MCO for PMAP clients, Medicaid provisionally enrolled them, so it looked like they were officially enrolled when in fact they weren’t. We wrote about this issue on the blog of our sister company, Phoenix Credentialing (click here to read it).
The last big one was Optum changing the rules on supervision. First they finalized a rule so groups can no longer get approval to submit supervised claims. Then they changed how those claims need to be submitted for groups on contracts where supervision was approved.
The claim submission change required all softwares to either re-code how supervision is handled just for Optum Commercial claims, which is how we did it at BreezyNotes, or do acrobatics to get their systems to submit claims properly. For our Billing Services customers not using BreezyNotes, there are some we are just now getting set up properly, primarily because the software reps didn’t even know how to do it correctly.
In addition to all this is the issue of consolidation. It’s getting harder to run a private practice, and investors and healthcare systems are buying up clinics left and right because owners are tired.
Just look at what we all dealt with in 2024.
I fear our industry may be going the way of Western medicine in that there will be a handful of huge behavioral health systems, along with some regional ones, that try to box in our country’s behavioral health or insurance companies more and more making clinical decisions disguised as rules so they can maximize profits. If you control the providers, you control the revenue.
BUT
I don’t like that future. My hunch is you don’t either. In 2025 you’ll find me doing whatever I can to fight that, whether that’s making credentialing and contracting easy through Phoenix Credentialing, significantly reducing the administrative burden for our customers so they can thrive with BreezyBilling and BreezyNotes, or representing our customers wherever it’s needed. I think it’s a fight worth having.
Sincerely,
Paul Jonas, CEO
BreezyBilling and Phoenix Credentialing
Updates for 2025
Payer Updates
There are quite a few payer updates this year. Especially with PMAPs.
PMAPS
The big news is the United Healthcare Community plan, which terms on 12/31. HealthPartners PMAP is basically done accepting new enrollees and Ucare is done accepting new enrollees EXCEPT in Hennepin County. Details here:
Blue Plus
Blue Plus will be an available health plan option for the Prepaid Medical Assistance Program (PMAP) and MinnesotaCare in Ramsey and Scott Counties effective Jan. 1, 2025.
HealthPartners
No longer open to NEW enrollees effective Dec. 1, 2024, for PMAP, MinnesotaCare, and Special Needs BasicCare (SNBC) with the following exceptions:
Newborns whose parent was enrolled with HealthPartners at the time of birth,
Enrollees who were previously enrolled in HealthPartners that regained eligibility after a lapse in coverage
Family members added to a household with other household members already enrolled in HealthPartners
HealthPartners SNBC
Enrollees will continue to receive their medical services from HealthPartners through March 31, 2025, unless the enrollee chooses a new SNBC health plan or requests to return to Medical Assistance fee-for-service. Members that remain on their SNBC plan will be moved to a new SNBC health plan effective April 1, 2025.
South Country Health Alliance
No longer be available in Kanabec County for all managed care programs effective Jan. 1, 2025.
Medica
Available in Anoka, Carver, Dakota, Olmstead, Ramsey, Rice Scott, Stearns, and Washington county effective Jan. 1, 2025.
Ucare
No longer open to NEW enrollees effective Jan. 1, 2025, for PMAP with the following exceptions:
UCare will continue accepting new enrollees in Hennepin County.
Newborns whose parent was enrolled with UCare at the time of birth
Enrollees who were previously enrolled in UCare that regained eligibility after a lapse in coverage
Family members added to a household with other household members already enrolled in UCare
UnitedHealthCare (UHC) Community Plan
Terminating 12/31/2024. UHC enrollees must select a new health plan or the Minnesota Department of Human Services (DHS) will move enrollees to a new health plan effective January 1, 2025. DHS can no longer contract with UHC for public programs. DHS notified UHC that contracts would end for all programs effective Dec. 31, 2024. Refer to Minnesota Statutes, 256B.035 prohibiting DHS from contracting with for-profit health maintenance organizations.
Other Payer Updates
Medicaid - is going back to 26 psychotherapy units per calendar year in 2025. You will need to track your sessions if you are doing more than one every two weeks.(Update 1/14/25: DHS is no longer requiring this for psychotherapy services. While the DHS Psychotherapy Billing page still indicates 26 sessions are required, it also refers to the Authorizations page, which indicates that, “Providers do not have to submit authorization requests for Psychotherapy services until further notice.”)
As of July, thanks to the 21st Century Cures Act, Medicaid became what I’m calling the “Payer of Record.” Individuals and Group Practices need to make sure:
They are properly enrolled with Medicaid
The address information is correct
The Taxonomy code on file for each location matches what’s on file with NPPES (The NPI Registry Tool) AND matches what is being sent out on your claims in BreezyNotes or any other software
Individual providers need to be properly affiliated with the Groups they contract/work with.
Mayo Medica Plan
Claims processing for 2025 claims is going through Optum so we will be adding a new payer, Mayo Medica Plan (2025) in BreezyNotes. Any client on a Mayo Medica plan will need to be switched to the new payer setup for 2025 claims.
Medicare
LMFTs, LPCCs, and Master’s level LPs became eligible to enroll with Medicare at the beginning of 2024. Since then we’ve been very busy helping primarily those licensures, but also LPs and LICSWs get enrolled with the program.
Working with LMFTs and LPCCs new to Medicare led to many questions being asked. As a result of those questions we learned that there were two core points of confusion that went beyond LMFTs/LPCCs and really to all behavioral health providers:
Behavioral health supervision claims are not allowed. Providers who aren’t fully licensed and enrolled with or Opted Out of Medicare may not see Medicare or Medicare Advantage clients.
If you are not enrolled in Medicare as either Participating or Non-Participating, or you’re opted out, you cannot see Medicare OR Medicare Advantage clients. At all. Not even for cash. End of discussion.
It took dozens of phone calls to both Medicare directly and Commercial payers offering Medicare Advantage plans to finally get clarification on these points.
For the first one about supervision, when we’d call and ask about supervision we’d be told, “Yes. It’s allowed.” But those reps were talking about a very specific thing called “Incident-To Supervision.” Standard behavioral health supervision is not incident-to supervision, unfortunately.
For the second point about Medicare Advantage plans, they have to follow Medicare rules. If you’re not enrolled in Medicare, then Advantage plans are not supposed to reimburse you.
As a result, we are recommending all providers get enrolled with medicare as Participating, Non-Participating, or Opt-Out. Not sure what these mean? I put together a blog post for our sister company, Phoenix Credentialing: Understanding Medicare Provider Enrollment or Opting Out for LMFTs, LPCs and Behavioral Health Providers: What you Need to Know
Surest
If you see Google, Microsoft, UPS and others, these large corporations are changing their plans to Surest. Surest is an Optum product, so as long as you’re In Network with Optum all you need to do is make sure to get updated policy information.
Tricare
BlueCross BlueShield is administering Tricare in 2025 as part of the “TriWest Healthcare Alliance” (aka TriWest), which takes effect on 1/1/25. Some providers needed to be recontracted, and in that case should have received a contract in June of this year. More details here.
Additionally, more of a concern for clients, six states are moving to the Tricare West Region and anyone who pays using EFT/DirectDebit need to update their payment info. Details to share with Tricare clients here.
Ucare
For ARMHS providers, in 2025 Ucare is removing the authorization requirements for units up to:
1200 units (300 hrs) per calendar year of Basic Living and Social Skills (H2017)
72 units (72 sessions) of Environmental or Community Intervention (90882)
104 units (26 hrs) of Medication Education (H0034)
Anything beyond the above limits will require authorization however. Details here.
Ucare also added a new clearinghouse option, Availity. We are working with our clearinghouse to ensure they are ready for any changes.
Collecting Debt from Clients
The Minnesota Debt Fairness Act changes how collections are done in Minnesota. MN Attorney David Holt runs it down for clinicians here. Practices must have a collections policy in place, posted and probably part of intake paperwork. Under the new rules:
You cannot refuse to provide medically necessary care to someone because of medical debt.
You must post something in office or on your website outlining your policy on collection of debt.
You can refer to a collections service, but they can no longer submit the debt to credit reporting agencies.
If you use a collection agency, I would reach out to make sure they are compliant.
A health care provider may require the patient to enroll in a payment plan for the outstanding medical debt owed to the health care provider. The payment plan must be reasonable and must take into account any information disclosed by the patient regarding the patient's ability to pay.
If there is a billing error, the client must be notified of the billing error and cannot be billed for those services until a review has been completed.
Recommendations: Get cards on file and charge them. Have a collections policy in place.
Contracting and Contract Updates
I mentioned above that Medicaid is now the “Payer of Record.” That means that MCOs and Commercial Payers are denying contract applications and contract updates if your Medicaid enrollment isn’t correct or doesn’t match what they have on file.
For most commercial payers in this case, you will first need to get Medicaid into ship shape before making any changes to an existing contract or applying for a new contract.
So that means, taking into account Medicaid processing time, it’s taking 30-45 days longer to update existing commercial/MCO contracts or apply for new ones.
Breezy Customers: If you are changing people, locations, anything about your practice, it is now imperative to:
Update Medicaid first
Submit those changes to your commercial payers second.
