Medicaid reimbursement victory in Arkansas
When the next group of predoctoral psychology interns begin their internships in Arkansas on Sept. 1, their mental health services will once again be reimbursed by Medicaid. A licensing change effective Jan. 1, 2014, had suspended Medicaid reimbursement for all mental health services provided by predoctoral psychology interns in Arkansas. But thanks to advocacy efforts from the Arkansas Psychological Association and grassroots support, new rules were drafted that overturned the change.
Prior to Dec. 31, 2013, mental health services provided by predoctoral psychology interns in Arkansas were reimbursed through Medicaid as long as the intern was provisionally licensed as a Licensed Psychological Examiner (LPE). The LPE was a master’s-level license that required a 60-hour master’s degree in psychology or a related field. On Dec. 31, 2013, the LPE was sunset and no new LPEs could be licensed by the Arkansas Psychology Board (Board). Thus mental health services provided by predoctoral interns could no longer be reimbursed by Medicaid.
A task force consisting of representatives from the Arkansas Psychological Association (ArPA), the Board, and the affected internship programs began working to address this issue last fall. ArPA reached out to the Department of Human Services (DHS), which manages Medicaid in Arkansas, to begin discussions through email and in-person meetings.
The task force proposed a change in Arkansas Medicaid rules to include reimbursement for services provided by predoctoral psychology interns under the following conditions:
- Internship program is accredited by the American Psychological Association (APA).
- Clinical supervision is approved by the Arkansas Psychology Board.
- Supervisor is an approved Medicaid provider.
The new Psychology Intern Policy addresses billing and how supervision will be done.
In order to achieve this change, the task force had to work with both the DHS and the state psychology board to make regulation and rule changes at the same time. The state Medicaid plan needed to be updated to accommodate intern reimbursement, and the Board had to make rule changes regarding supervision of psychology interns. The changes were then opened for a public comment period.
The Medicaid plan changes and the Board rule changes were sent to the state Public Health committee on July 25 and the Rules and Regulations Committee on Aug. 6, where they received final approval. ArPA mobilized grassroots members to lobby state senators and representatives on those committees to help minimize delays.
A shortage of psychologists providing mental health services in Arkansas, particularly in rural areas and to underserved populations, meant this issue was important not only to psychologists and patients, but to state Medicaid officials as well. “There was not really any resistance,” said Art Gillaspy, PhD, chairperson of the Department of Psychology and Counseling at the University of Central Arkansas. “It was just a matter of working out the details and informing DHS about how psychology internships are different from other mental health professions.”
Part of the issue, said Gillaspy, was that “intern” can be a vague term. Many professional programs have training experiences labeled “internships.” “DHS’ concern was if psychology interns are allowed to bill through supervisors, other mental health professions will want the same privilege,” says Gillaspy. “We did a lot to educate them about what psychology internships involve, and the checks we have in place to guarantee the quality of our internship training.”
The task force met several times with Arkansas Medicaid administrators at DHS to work out the terms of the proposed changes to the Medicaid plan. The group also met several times with the Arkansas Psychology Board to develop proposed rule changes that explicitly allow the Board to approve supervision of doctoral-level interns.
Letters to the psychology board and to the Medicaid office from the APA Education and Practice directorates provided a big-picture perspective on this issue. ArPA also used talking points from APA’s "Compilation of Medicaid State Barriers to Psychological Services" in its response during the public comment period.
Gillaspy’s involvement with the effort began in fall 2013. At that time, then ArPA President Courtney O. Ghormley, PhD, was already in discussions with Laurence H. Miller, MD, medical director/director of Research & Training Institute for DHS, about securing reimbursement for psychological services provided by predoctoral psychology interns. Lisa McNeir, PhD, a member of the Arkansas Psychology Board, joined the effort, and when Ghormley's term ended, the new ArPA president, Patricia L. Griffen, PhD, became a driving force behind the effort. The task force also included Regina Pierce, CEO of South Arkansas Regional Health Center, which has an APA-accredited internship program.
Medicaid reimbursement in other states
Some states such as Oklahoma, Minnesota, Nevada, Alabama, Georgia and Ohio have methods in place to allow for Medicaid reimbursement of psychological services provided by predoctoral interns. If your state allows for the reimbursement of services provided by predoctoral interns or postdoctoral trainees through Medicaid, please notify the APA Practice Directorate's Office of Legal and Regulatory Affairs by phone at (202) 336-5886 or by email.
States design and administer their own Medicaid programs within broad federal guidelines; therefore, there is much variance in how plans are implemented across different states. Even with this variance, Arkansas’s example may provide a template for advocacy in other states looking to achieve similar results.