Provider responsibility guidelines

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Our goal at Headway is to make billing easier for behavioral health providers and their clients. In order to make this possible, there are responsibilities and standards of operation Headway providers must meet in order to avoid any instance where we may need to recoup payment. 

As a Headway provider, we empower you to provide high-quality, affordable care to clients. With this, we trust that you are abiding by the guidelines and regulations for fair, accurate session billing and provision of services. We’ve listed out guidelines for how to keep this up on your side. 

If there were an instance where there was a chance of us recouping payment, to the best of our ability, we'll reach out to you first. We’re partners, and we will work with you to mitigate this risk.


Keeping progress notes compliant

Keep progress notes in accordance with HIPAA and Payer Guidelines.

Why is this important?

  • Whether you’re keeping notes directly in Headway or on another platform, we encourage you to use DAP (Data, Assessment, Plan) or SOAP (Subjective, Objective, Assessment, Plan) templates. Learn more about our progress note templates here.
  • If you are taking notes somewhere else, we encourage you to upload them as an attachment to the client’s Clinical tab.
  • If you paste your notes to Headway, include an electronic signatures with the credentials and date (shown by "/s/"). If you store your notes on Headway (pasted, uploaded, or using Headway templates), be sure to agree to and check the declaration box. 
  • Providers should assume that any notes kept on the Headway platform are part of the Medical Record. Unsharable, private notes should not be kept on the platform.
  • Make sure your notes are unique to each individual session — no two sessions should have the exact same notes.


Keeping progress notes outside of Headway

If you’re keeping your notes outside of Headway, make sure they are organized and prepared.

Why is this important?

  • If we receive a request for notes from an insurance company, we’re required to share them quickly, so we’ll ask you to produce them within 3 business days.
  • In the event that your notes are missing, incomplete, or missing an important element (i.e. signature), we will reach out to you before the insurance company does to request completion or updates.
  • Headway is responsible for sharing notes directly with the payer — this won’t ever be on you. If you receive a request directly, please send it to us via our contact form.


Scheduling & confirming sessions in a timely manner

Schedule sessions in advance and confirm details promptly after.

Note: If your client is missing valid insurance information, payment details, or acknowledgement of standard forms, you will not be able to confirm the session or be paid until this is complete.

Why is this important?

  • If a session isn’t added to the calendar until after it’s actually occurred, we don’t have an opportunity to check the client’s benefits and eligibility. If this is the case, they may not be covered, and in that case, you may not be paid.
  • If a provider submits a session outside of timely filing limits, the claim may be denied, and Headway may recoup payment.
  • If a timely filing denial is due to a Headway error, we will not recoup from the provider.


If you confirmed a session on the wrong date

Make sure your calendar accurately reflects sessions you’ve held.

Why is this important?

  • In the event that a client says a session did not occur, we may request notes. If the provider indicates that a mistake was made, we will refund the client, send a corrected claim, and remove the provider payout without collecting the notes.
  • If a client disputes a session (i.e. the length or services), we may request notes to be reviewed. The provider must reply with requested materials within 3 business days if notes are not on the platform already.


Billing for sessions if your client is late or leaves early

Only bill clients when you’ve spent time face-to-face or virtually.

Why is this important?

  • Timed CPT codes are meant to reflect the time spent actually receiving care. If a client is 15 minutes late for an hour-long session, the 45 minute code should be used to reflect that.
  • If a client decides to end a session early, the code chosen should reflect the time you spent together.
  • Headway cannot pay providers for the difference in the time anticipated and the actual time spent providing care.


Your responsibility regarding cancellations

Keep up with your messages from clients, especially about cancellation.

Why is this important?

  • As a provider, you’re responsible for setting your cancellation policy and fee, as well as resolving any questions or disputes with clients. We will make sure your client is aware of your cancellation fee in the booking process, as well as in appointment reminders emails, but we strongly encourage you to let them know yourself, too.
  • If a client reaches out to you about a cancellation fee and doesn’t hear back, we will step in to resolve the dispute.
  • If a late cancellation occurs because of an error on Headway’s side, we’ll refund the client the fee, but you’ll still receive payment.
  • If you let us know that we should waive a cancellation fee for a client, you will not receive this payment.


Handling clients who aren't the right match

Always consider if the client is the right match for the type of care you can provide.

Why is this important?

  • As a provider, you are responsible for determining if a prospective client is a valid candidate for in-network care. If you meet with a client who is later found to be unsuitable for treatment with that you (and no billable care has been provided), you will not be paid for those sessions.
  • To reduce the chance of provider-client mismatch, we encourage you to meet with clients via non-billable consultation call first to determine if you can work with the client. Elements to discuss include:
    • Medical necessity: Is treatment for the client’s issue medically necessary?
    • Location: Is the client located in the provider’s licensure state? 
    • Clinical Fit: Is the provider able to perform the service the client is seeking?


Things to keep in mind when coding sessions

  • Documentation requests can happen for any reason, but are more likely in certain scenarios. Always be very thoughtful about noting medical necessity, but especially in the following scenarios:
    • Family Therapy / Couples Counseling
    • Crisis Intervention
    • Regular use of 99205, 99215, 90836, 90837, 90838
    • 90791/90792 billed more than once every 6 months for the same client
    • Adjustment Disorders diagnoses
    • Sessions held more often than once per week with the same client
  • The payer and standard coding rules have “final word” on the codes for the session. If a payer changes the codes used, partially denies a claim, or if a provider uses disallowed codes together, Headway may recoup payout. We will always discuss this with you beforehand.
  • Instances insurance companies may reduce costs / deny without notes request include:
    • Insurance company has “rebundled” a service (removed or changed a code)
    • Insurance company denies the claim or the line-item denies the claim due to coding.
  • Headway’s internal monitoring might flag:
    • Discordant codes used together
    • Client complaints of improper coding
    • Claims monitoring for rebundled codes / denials

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