BCBS-IL and Massage Therapists
The ICS has previously noted Blue Cross BlueShield of Illinois (BCBSIL) announcements regarding the change in procedures for billing of services rendered by licensed massage therapists in the physician office.
- Licensed massage therapists will be required to obtain an NPI and bill all services to BCBSIL under the massage therapist’s NPI, rather than under the supervising provider’s NPI; and
- A “reimbursement differential” would apply to services rendered by a licensed massage therapist.
Following a delay in implementation, BCBSIL now has sent network providers a letter dated April 1, 2015, stating that BCBSIL will require LMTs to obtain an NPI, which the physician provider must submit to BCBSIL “within 30 days of the date of [the] letter,” or by May 1, 2015. BCBSIL has not yet named a date on which it will start accepting these LMT claims, however.
Many chiropractic physicians employ and contract with licensed massage therapists to provide services to the physician’s patients. Since the date of the original announcement last year, the ICS has sought clarification from BCBSIL as to how it intends to handle claims for services that a physician delegates to a licensed massage therapist in the office.
BCBSIL has now responded to the ICS with additional information, which the ICS is passing along to members.
The ICS is also relying on the interpretation of the Illinois Department of Financial and Professional Regulation in sharing the following:
If you utilize LMTs in your office and they are “held out” as LMTs, i.e., they are referred to as “licensed massage therapists,” your office will be required to follow the new BCBSIL protocol requiring direct billing of services provided by the LMT. Note also that the LMT in this situation may only provide services within the scope of massage therapy practice, such as therapeutic massage. The LMT will be required to obtain an NPI, and services must be billed to BCBSIL under the LMT’s NPI.
However, if you have LMTs in your office who are NOT held out as LMTs but instead are used as unlicensed chiropractic assistants, these individuals will not be subject to BCBSIL’s impending requirement to bill services “directly” under the LMT’s NPI. You may continue to treat these individuals as unlicensed chiropractic assistants to whom you may delegate and supervise tasks and bill the services under the physician’s NPI. In this situation, the LMT is not limited to providing services within the scope of massage therapy, so long as the physician complies with the law regarding delegation of tasks to unlicensed assistants.
In this context, it is very important that physicians review their classification of personnel in the office as “employee” versus “independent contractor.” It would be incongruous for a physician to claim an LMT is an “independent contractor” for tax purposes, and to claim the same LMT is a chiropractic assistant who acts as an “arm of the physician” and whose services are billed as the physician’s services.
The ICS continues to seek additional information about BCBSIL’s “reimbursement differential” for services billed directly by LMTs under their own NPIs. We will keep our members apprised of all developments.
The ICS provides a number of tools for assisting members in making the appropriate determinations for all facets of this issue:
This article explains Illinois’ requirements for delegating duties to Licensed Massage Therapists (LMTs) and billing for those services.