Working with Original Medicare and Medicare Advantage on Headway


We're thrilled to begin accepting Original Medicare and Medicare Advantage in some states to make mental healthcare even more accessible across the nation! When we're ready to enroll you in one of these plans, you'll receive an email from us.

We're working hard to add new plans, so 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. 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 government funded and managed 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.

Original Medicare offers broad coverage with flexibility in provider choice, but requires additional plans for prescription drugs and supplemental coverage. Medicare Advantage, provided by private insurers, offers everything Original Medicare offers, with potential added benefits like prescription drug coverage and extras such as dental and vision, often at lower out-of-pocket costs. Typically it comes with network restrictions and potential limitations on provider choice.

The decision to choose Original Medicare or Medicare Advantage hinges on factors like cost considerations, desired coverage breadth, and provider preferences.

As a note: Patient populations for Original Medicare and Medicare Advantage are quite similar, and patient eligibility is the same for both.

What do Medicare Advantage plans cover? 

Medicare Advantage Plans must cover all of the services that Original Medicare covers, except for hospice care.

How does Kaiser Permanente NorCal work?

To learn more about working with Kaiser Permanente NorCal on Headway, visit our article: Working with Headway and Kaiser Permanente Northern California.



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

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 three annual training courses: 

  1. Fraud, Waste, and Abuse training
  2. HIPAA training
  3. Writing compliant notes using Headway templates for Medicare

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?

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:

  • Provide Headway access to your PECOS account by adding Headway as a surrogate via your CMS I&A account
  • E-sign your completed Medicare enrollment application / reassignment once Headway has filled out your application
  • Complete the Medicare intake form on your insurance status page.
  • Complete our Medicare Learning Path in Headway Academy
    • Fraud, Waste, and Abuse training [60 minutes]
    • HIPAA training [10 minutes]
    • Writing compliant notes using Headway templates for Medicare [30 minutes]
  • 2 other optional courses

How can I tell whether I’ve completed the onboarding training?

You can view the completion of your Fraud, Waste, and Abuse, HIPAA, and Writing Compliant Notes trainings in Headway Academy.

Can I charge a cancellation fee for Medicare patients?

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

Please note: For Kaiser Permanente Northern California sessions, you are not able to bill a cancellation fee for no shows or cancellations. These additional fees cannot be charged on or off of the Headway platform. Learn more about working with Kaiser Permanente NorCal.



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. Please note, if you intend to reach out to your client’s other healthcare providers, you should obtain consent from the client prior to reaching out. This is a best practice.

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.

As a Headway provider, you also have access to a PESI course titled "The Powerful World of Therapy with Adults 65 and Older: Challenging our Myths About Aging". To get started, visit our Continued Education page.

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.

Learn more in our Assessments and measurement-based care guide

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