Hello Everyone. This is a copy of the questions other mental health professionals sent to SCDHHS for the online training SCDHHS hosted eight (8) months ago. And this is SCDHHS's official response. I got a copy of it this morning and wanted to share it with you. Happy reading!

Licensed Independent Practitioner Provider Policy

Frequently Asked Questions

1.     What specific demographic information is required in the assessment (e.g., address)?
We do not have specific requirements but would expect the initial entry in the member’s chart to have some basic demographic information such as name, Medicaid ID, date of birth, age, contact information, and if under age 16, the guardian’s name/contact information.

2.     Assessment and screening tools are needed for the clinical assessment. Is there a comprehensive list of preferred tools or tools that will be insufficient if not used with a particular population?  

Assessment/Screening Tools are not required; however, they are encouraged. These could include screenings for trauma, depression, anxiety, or other areas of concern as indicated by the member’s presenting condition. Behavioral Health Screening (BHS) offers suggested screening tools and requires that they are standardized and approved by DHHS (2025 LIP manual, p. 14).

3.     One of the requirements listed in the manual for the DA is the beginning date of RBHS services.  Since the DA is done to recommend these services and there would not be a scheduled session at that point, what do we note to meet that requirement?  

The RBHS manual utilizes the DA term, and the LIP manual speaks to an Initial Comprehensive Assessment. In the LIP manual, the reference to RBHS services is regarding prior authorization. As this question lacks clarity, please reference the page number in the LIP manual for this requirement and submit a revised question to the following mailbox: behavioralhealth004@scdhhs.gov

4.     If I receive a transfer from another provider and a Comprehensive Diagnostic Assessment (CDA) was already completed (i.e., less than 6 months ago) and shared with me, and the CDA meets RBHS standards, do I need to include my own CDA in the client's chart? Or can I use the other provider's CDA and formulate a new IPOC 30 days from the date of the transfer? Per the LIP manual, “Follow-up assessments occur at any time after an initial assessment, to re-evaluate the status of the beneficiary, identify any changes in behavior and/or condition and to monitor and ensure appropriateness of treatment.”  Additionally, “The LIP should attempt to determine whether another Comprehensive Assessment (initial or follow-up) has been conducted in the last 90 days and efforts should be made to access those records. An assessment should be repeated only if a significant change in behavior or functioning has been noted. When an assessment has not been received from the referral source, the LIP must certify and document through a Comprehensive Assessment that the beneficiary meets the medical necessity criteria for services.”  See 2025 LIP Manual pages 17-18.

5.     Why are LIPs not paid for H0032 (Mental Health Service Plan Development) to develop and review the IPOC? RBHS is paid for this service. This service is not currently available in the LIP fee schedule.

6.     Can the 90-day progress summary be documented separately from the IPOC instead of at the bottom of it? The manual says "on" the IPOC.  Yes, you may document the 90-Day Progress Summary separately, but it is suggested that you attach the progress summary behind the IPOC that it is referencing to reflect continuous progress from one period to the next after the treatment plan has been implemented and to ensure compliance.  

7.     Is a discharge summary required if the client stops before completing all goals?  Yes, it would still require a summary of the overall progress prior to closing the chart.       

8.     For the 90 days that fall due at the same time as a yearly IPOC (which would be a 90-day progress summary #4), are we required to do both a 90-day progress summary and an annual IPOC? OR... does the annual IPOC take place of that last 90-day progress summary due? The IPOC reformulation is due on a yearly basis and includes progress/changes within the past 90 days.

9.     Is there any need for the CDA and the IPOC to always be synchronized within 30 days? For example, I do a CDA on 1/1/24 and IPOC on 1/30/24 but then I reformulate the IPOC on 4/1/24. Can the next year's cycle keep the CDA date as 1/1/25 and IPOC as 4/1/25?  Yes, it does need to comply with 30 days, unless billing is not done on the services during the lapse.  This is simply a way to maintain the policy guidelines with clarity, and it’s about ensuring that the member doesn’t go periods of time without a current plan in place.  So, whether it’s one day or 50 days with no current plan, if services were billed during the lapse, it would result in a non-compliance finding.    

10.  After an original treatment plan has been completed, and the parent of the minor client wants changes to an objective, and another treatment plan is completed, and again the parent wants a change, and a 3rd treatment plan is drawn ... does the parent signature need to be on all 3 treatment plans? The member must sign the IPOC indicating that they have been involved in the planning process and have been offered a copy of the IPOC. If the member does not sign the IPOC or if it is not considered appropriate for the member to sign the IPOC, the reason that the member did not sign the IPOC must be documented on the IPOC and the clinical record. The IPOC must be reviewed and updated as needed according to the member’s progress, but at a minimum every 90 days via the progress summary process identified in the LIP policy manual. It would be relevant to indicate who is involved in the change to the plan, and we accomplish this through the member’s signature. Thus, if the treatment plan is changed three times, the provider needs to ensure that the person involved in making changes to the treatment plan signs off appropriately, whether parent or child, to indicate their involvement.   

11.  What is considered an acceptable condition for a client to not sign a treatment plan? If the member refuses, is not available, or unable to sign due to some other reason. This should be noted in the signature line of the IPOC, and then attempts to obtain the signature should be noted in the clinical service note at the next available appointment.   

12.  Is the five-day signature a requirement also of the supervisor over the provider? As this question lacks clarity, please reference the page number in the LIP manual for this requirement and submit the question to the following mailbox behavioralhealth004@scdhhs.gov

13.  Is the full name listed in the header sufficient or must it be within the note such as "Jane Doe presents with appropriate mood”? If the header of the note identifies the member and the header is a part of the clinical note that is acceptable; however, if the clinical service notes are multiple pages, identification of the member is required on each page accurately reflecting the member receiving the service(s).

14.  Must a new consent form be signed if a client is discharged and returns (e.g., the client discharged in January, but returns for continued services in May of same year)? Per the LIP manual, a new consent form should be signed and dated each time a member is readmitted to services after discharge.

15.  Will there be any trainings on clinical issues such as accepted diagnosis codes accepted by Medicaid?  DSM-5 diagnoses must be identified for behavioral health services to be reimbursed. Z-codes are allowable for six (6) months for members over the age of six (6). The use of Z-codes is not time limited for children ages 0 to 6 of age. Please provide more information related to your question if further guidance is needed. behavioralhealth004@scdhhs.gov 

16.  Can more clarification on Associate levels and Master level student interns be provided? LPC-A, LMFT-A, and LMSW are master’s level practitioners working toward independent licensure under their assigned clinical supervisor(s). As an example, I was an LPC – I (intern) when completing supervision hours for licensure. The Board changed the Intern to Associate for LPC’s and LMFTs.  But all are the same in that the supervision is required.  See question #21 for student interns.

17.  Is it possible to ever have a training with DHHS and all the MCOs to discuss these same topics? It's extremely difficult to keep up with six different provider manuals and requirements especially when there are changes that occur throughout the year. Was just thinking maybe a joint session would help us all. Our goal is to ensure that Providers receive the education and support needed to meet policy requirements, to deliver quality services, and to support opportunities to ensure this occurs.

18.  We use an electronic software system and have found as we use it that there are deficits in that system that we are not able to control. We request changes to the software system, but they don't always make changes unless there are enough requests. We try to make adjustments to make sure we are still meeting requirements, but some of these things don't always get noticed immediately. What suggestions do you have for using electronic systems or should we go back to keeping paper files? We don’t advise or recommend any one system versus another system but advise Providers to utilize the system and/or process that ensures compliance with policies and the delivery of quality services to members.

19.  If having graduate student interns who have not yet achieved their master's degree, it sounds like you are saying LIPs may bill for student intern services even though the student intern is providing the service and not the LIP (if the LIP is available for assistance). Sounds too much like fraud/risk for the LIP to put their name on all documentation (presenting the note/documentation as if the LIP provided the service instead of the student intern). Could we confirm with the program integrity audit/office that they agree with your interpretation of policy (that student interns without a master's degree may provide individual therapy with the LIP available to be billed under LIP's name)? Just would hate for major claw backs, or to be put on a fraud list for Medicaid. For student interns, the licensed therapist would need to be present and leading the service delivery for billing to be submitted. The service must be delivered in conjunction with and direct involvement of the primary provider.  There is no Medicaid provider enrollment type for a non-master’s level provider to render direct services without the LIP provider being involved. LIP Providers should not sign off on any services they were not responsible for delivering.

20.  Can LPC-As see Medicaid clients supervised by an LPC-S candidate? The LPC-A’s clinical service notes must be co-signed by an LPC-S, not an LPC-S candidate.

21.  Does the LIP have to be in the session to bill for a student intern? Or on site and available? See response to question #20.

22.  Does that mean the provider has to be in the room with the client and intern, or just "available" via phone? See response to question #20.

23.  Are licensed LACs able to bill independently? They are identified as LPHAs; however, this was included primarily for the DAODAS section of the RBHS manual.  It will be forthcoming at some point in the future, but Licensed Associate Counselors (LAC) have not yet been added as a provider type to the LIP provider manual. When this becomes available, a provider bulletin will be released.

24.  In Medicaid policy, is there a difference between an LPC-S and an LPC-S candidate as far as their ability to supervise/sign after LPC-As that are providing treatment? Specifically, I am an LPC-S candidate and have LPC-As in my practice that I would like to credential to provide Medicaid services to clients? Medicaid policy currently specifies LPC-S and does not include LPC-S candidates.  

25.  In our state, I've heard that the legal age of consent to treat is 16 for mental health records. Would you want a consent to treat from both the parent/guardian and the 16-year-old client? That is correct. A 16yo may consent to their own medical treatment, including behavioral health services. It is also good practice to have the member identify whether they want the parent/guardian involved and to have the member sign a release of information, as that is required to openly include the parent in treatment decisions. The parent/guardian would not sign the consent to treatment if the member were 16yo and older.

26.  What about new legislation that requires providers to notify parents in writing about pronoun changes? Medicaid does not address this in policy.  

27.  Could you provide some guidance on the use of AI in clinical documentation? Currently, there is no guidance regarding the use of AI in clinical documentation.

28.  Is DHHS looking to merge the LIP and RBHS manuals, and moving to a one payer system? We are constantly looking to update and clarify our manuals when clarity is needed, or when new information is available for our providers.  We also look to avoid redundancy as much as possible, and consolidation of manuals has occurred in other areas to streamline services and avoid inaccuracies. Both LIP and RBHS provider manuals are under review this year for needed updates. When there is information for providers regarding any changes, updates will be provided via Medicaid bulletins and other mechanisms.