Working with Medicare on Headway


We’re thrilled to share that we’re officially accepting Medicare to make mental health care even more accessible across the nation. Currently, Medicare is only available for non-prescribing providers practicing in California on Headway. We’re working to expand access as soon as we can — stay tuned!


Understanding the differences between Medicare and Medicaid

What are Medicare and Medicaid?

Medicare is a federally run program that covers medical expenses for more than 66 million Americans age 65 and older, as well as younger people who qualify because of a disability. Eligibility for Medicare is not based on income or assets, and members cannot be denied coverage or charged more because of preexisting medical conditions. Outpatient mental health services, which are provided through Headway, are covered by Medicare Part B.

Medicaid is run jointly by federal and state governments to provide health care and long-term care coverage for more than 81 million Americans, including children, parents, low-income adults, older adults, and people with disabilities. The federal government sets general standards for Medicaid, but specific eligibility requirements and coverage details vary by state. Your income must fall below certain levels to qualify.

What’s the difference between Medicare Advantage and Medicare?

Medicare, often called “Original”, “Traditional”, or “Fee for Service” Medicare, is provided directly by the government to beneficiaries. If you have Medicare, the federal government is responsible for your coverage. 

Medicare Advantage is provided by private insurance companies. By law, these plans must offer the same minimum benefits coverage as Medicare, but are allowed to offer more benefits and can require higher premiums in exchange.



Eligibility, enrollment, and opting out

Am I eligible to be credentialed with Medicare? What credentials do I need to accept Medicare with Headway?

As of January 1, 2024, the following types of mental health providers are eligible to enroll in Medicare Part B*

  • Psychiatrists
  • Nurse practitioners
  • Physician assistants
  • Clinical psychologists
  • Clinical social workers
  • Clinical nurse specialists
  • Marriage and family therapists
  • Mental health counselors

For now, Medicare with Headway is only available for non-prescribing, California providers. We’re working to expand access beyond California and to prescribers as soon as we can. Stay tuned!

Am I required to enroll in Medicare with Headway?

No – there’s no requirement to enroll in Headway’s Medicare offering. It’s completely up to you.

If you’re not sure working with Medicare is right for you, our team can help.

If I enroll in Medicare with Headway, does that prevent me from billing Medicare with other groups or individually now or in future?

If you enroll in Medicare with Headway, you can start or continue billing Medicare individually or even with other groups.

I opted out of Medicare in the past. Can I still enroll in Medicare with Headway?

Yes – you can change your status. Here’s how:

If you opted out for the first time, you’ll have 90 days to notify your local MAC with a written, signed notice that you are canceling your opt-out. 

If it’s been more than 90 days since your initial opt out, you’ll need to cancel your opt out by sending in a signed notice to your MAC within 30 days of your two-year opt-out period’s expiry date.

I'm independently enrolled in Medicare — what should I do?

Whether you’re independently enrolled in Medicare or not, you should still consider enrolling in Medicare with Headway.

Enrolling in Medicare with Headway won’t affect your ability to bill Medicare individually or with another practice. Plus, porting your existing patients to Headway can simplify your billing process, help you stay compliant with Medicare coding and billing rules, and allow us to guide your patients through any insurance issues.

What does it mean to “reassign benefits” to Headway?

A reassignment of benefits enables Headway to manage billing payments from Medicare on your behalf for appointments billed on Headway, so that you can focus on providing care. You can reassign benefits to multiple groups, so reassigning them to us won’t prevent you from billing with other groups or individually.

How can I fix a mistake on my submitted Medicare application intake form?

Reach out directly to the Headway support team for help making changes on your intake form after submitting.



Documentation and training requirements

What are the training requirements to accept Medicare on Headway?

Accepting Medicare with Headway requires the completion of two annual training courses: 

  1. Fraud, Waste, and Abuse training
  2. HIPAA training

You can access these trainings within Headway Academy at any time.

What are the documentation requirements for accepting Medicare on Headway?

Documenting Medicare sessions can seem intimidating, but Headway is taking the guesswork out of meeting compliance standards.

When billing Medicare patients on Headway, providers are required to use our custom, Medicare-compliant templates, and will receive ongoing personalized feedback on notes from our clinical team to ensure documentation compliance. 

Are there any general differences in documentation requirements for Medicare?

Medicare requires a diagnostic statement in your ongoing progress notes, a treatment plan within 14 days, and review of treatment plan every 3 months. Additionally, documentation of attempts to coordinate care with other healthcare providers is required. 

All of these requirements will be captured in Headway’s documentation templates, so you don't need to worry about forgetting any requirements. 

How will I know if my documentation is compliant?

When you first enroll with Medicare on Headway, a small sample of your notes will be reviewed by our Clinical Team. Our intent is to provide personalized feedback to help you adjust your documentation practices, as needed, to set you up for compliance success with Medicare. 

Once you’re actively seeing Medicare clients, our team will proactively review documentation for Medicare appointments to ensure that all notes meet Medicare’s documentation standards. If we identify any errors, we’ll provide personalized feedback through your provider portal. You will have the opportunity to submit any necessary corrections to ensure that all documentation is compliant. 

What happens if my documentation is found to be non-compliant?

If your documentation is found to be non-compliant, we’ll provide personalized feedback in your provider portal. You’ll have an opportunity to edit and resubmit. Between our proactive reviews and documentation templates, we’re here to make it as easy as possible for you to meet requirements.

Compliant documentation is legally required for Headway to submit Medicare claims. This means that if documentation is not received or doesn’t meet standards, claims will not be submitted and you will not be paid for these sessions. As a best practice, corrections should be submitted within 7 days of receiving feedback. Payment for sessions with non-compliant documentation will be held until the corrections are submitted and approved. 

What Headway training can I use to advance my skill set in working with this population?

We’ve developed a new Headway Academy learning path specifically for Medicare practices to help you feel confident in running a Medicare practice. 

Does the American Medical Association (AMA) recommend additional training to treat Medicare patients?

For low to moderate acuity Medicare patients, the AMA states that no specialized training is required for licensed therapists and psychiatrists.  



Getting ready to see patients with Medicare on Headway

When can I start seeing patients on Medicare through Headway?

You’ll hear from us when you’re eligible to start the credentialing and onboarding process for Medicare. From there, we’ll keep you posted on when you can start seeing Medicare clients. Right now, the earliest will be later this year (2024).

How do I log into my CMS Identity & Access account as part of the Medicare with Headway intake form? 

Every provider has a CMS Identity & Access Management System (CMS I&A) account. Your CMS I&A account login credentials are the same as those you use to log into National Plan & Provider Enumeration System (NPPES) and Medicare Provider Enrollment, Chain, and Ownership System (PECOS) accounts.

If you’ve forgotten your login details, click Retrieve forgotten user ID or Forgot password when accessing the CMS I&A login page, and follow their prompts.

Why do I need to grant Headway access to my CMS I&A account?

We want to make enrolling in Medicare with Headway stress-free. To do so, Headway needs access to your CMS I&A account to fill out and file necessary enrollment forms with CMS on your behalf. If you have any questions about this process, please reach out to our team.

What steps need to be completed to be appointment-ready for Medicare on Headway?

To have your first appointments on Medicare, you’ll need to:

  • Complete the Medicare intake form on your insurance status page.
  • Complete our Fraud, Waste, and Abuse training.
  • Complete HIPAA training, or attest to having completed HIPAA training elsewhere.
  • Successfully complete a note review for five of your commercial clients. 
    • If you don’t yet have commercial clients, your first five Medicare notes will be reviewed instead.

What does the initial note review entail? 

Our team will review five of the notes you submit after March 15, 2024. From there, we’ll let you know how they compare to our clinical documentation standard

If there are any opportunities to improve submitted notes, you’ll receive personalized feedback in your provider portal. You’ll have a chance to review and address the feedback, and any corrections will be reviewed to ensure you’re ready to start seeing Medicare patients. 

How will the initial note review work? What steps do I need to take?

Here's how the note review will work:

  1. Take five notes in Headway templates for any five standard intake or individual psychotherapy appointments (i.e. 90791, 90832, 90834, 90837). These appointments can be for any patient and through any insurance company for. 
    1. To use a Headway template:
      1. Navigate to your Calendar in Sigmund.
      2. Select the appointment you wish to create a progress note for and click Start progress note.
      3. Choose the Fill out a template option and select the appropriate note type from the dropdown.
      4. Sign and submit your note once you’ve filled in all the necessary information.
  2. We will notify you once you have met the 5 note requirement. Please keep in mind that it may take 3-5 business days to process your document status, so don’t worry if there’s a delay between your 5th note submission and our confirmation.
  3. Our team will review your documents to ensure they meet all required standards. Once the review is complete, you’ll see personalized feedback on your notes in Sigmund.
  4. Submit any additional information required to address the feedback via an addendum upload in Sigmund.
  5. Our team will take another look at the additional information required and confirm your Medicare eligibility status within a few weeks.

We will reach out once you have completed all other requirements to ensure you are ready to see Medicare patients in late 2024.

How can I tell whether I’ve completed the onboarding training and successfully completed the initial note review?

You can view the completion of your Fraud, Waste, and Abuse and HIPAA training in Headway Academy, and will receive an email with the outcome of your note review.

Can I charge a cancellation fee for Medicare patients?

There are no differences in how and when you can charge cancellation fees with Medicare patients.



What’s covered by Medicare 

Are any treatment modalities NOT covered by Medicare? 

Some treatment modalities are not covered by Medicare. 

Medicare does not cover: 

  • Environmental intervention or modifications 
  • Biofeedback training (any modality) 
  • Marriage counseling 
  • Pastoral counseling
  • Phone applications (e.g., texting)

Are specific diagnosis (Dx) codes excluded from coverage by Medicare?

There are no specific Dx codes excluded from coverage by Medicare. Medicare follows the industry standard of ICD-10 codes and guidelines when determining billable services. These guidelines are updated annually and changes can be found in our ICD-10 Diagnosis Code Changes article

Are there any service limits I should be aware of?

Medicare currently has no service limits for outpatient mental health. However, Medicare requires all services to be medically necessary, so be sure documentation supports the medical necessity of any services billed to Medicare. 

My Medicare client has multiple insurance plans. Will Headway be able to determine which is primary and bill the plans accordingly?

Yes – Headway determines clients’ primary insurance plan when they present with two insurance plans and will bill accordingly. 



Clinical considerations 

What are some of the key differences in treating Medicare clients?

There is no “typical” Medicare client. However, it’s important to understand there may be additional medical comorbidities and/or social determinants of health that have an impact on your clients’ mental health. 

To manage these additional complexities, it’s best to ask the client if you can reach out to their other healthcare providers — especially any primary caregivers.

How can I best prepare to treat Medicare patients from a clinical perspective?

Medicare beneficiaries are eligible for coverage based on age and disability status, so it’s helpful to communicate with clients mindfully. 

Ask for and try to communicate using their preferred medium and style. 

Additionally, be aware of any other individuals involved in clients’ care, such as family or healthcare providers, as you may need to coordinate care with them.

What are the outcome measure requirements?

While there are no specific outcome measure requirements for Medicare, we encourage providers to use measurement-based care and patient reported outcome measures where clinically appropriate.

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