This definition reflects several changes that occurred in April 1998. First, these changes removed the requirement that a psychologist have a doctoral degree specifically labeled "clinical psychology." This new definition allows doctoral level psychologists with the appropriate knowledge, training, and experience in clinical psychology to obtain a Medicare provider number, regardless of his/her particular psychology degree label. Second, the specifically stated "2 years of supervised clinical experience, at least one of which is postdoctoral degree experience" has been removed and HCFA has determined that State licensure or certification requirements sufficiently address this issue.

'Independently-Practicing Psychologists' Are Defined By HCFA As Follows:

The diagnostic testing services performed by an 'independently-practicing psychologist' are covered as other diagnostic tests if a physician orders such testing. Medicare covers this type of testing as an outpatient service if furnished by an 'independently-practicing psychologist' who is licensed or certified to practice psychology in the State or jurisdiction where he or she is furnishing services or, if the jurisdiction does not issue licenses, if provided by any practicing psychologist.⁴

Consider psychologists as practicing independently when:

• He/She renders services on his/her own responsibility. This means that when rendering these services, the psychologist is not an employee of a physician, institution, or agency;
  
• The persons she/he treats are her/his own patients; and
  
• He/She has the right to bill directly, collect and retain the fee for his/her services.

Diagnostic psychological testing services performed by persons who meet these requirements are covered by Medicare as "other diagnostic tests." When, however, the psychologist is not practicing independently, but is on the staff of a hospital, these services are bundled into the hospital payment and thus the hospital bills these diagnostic services to the fiscal intermediary. A psychologist practicing in an office located in a hospital may be considered an independently practicing psychologist when both of the following two conditions exist:

1. The office must be confined to a separately identified part of the facility which is used solely as the psychologist's office and cannot be construed as extending throughout the entire institution; and
   
2. The psychologist conducts a private practice, i.e., services are rendered to patients from outside the institution as well as to institutional patients.

Physician Referral UPINs

Psychologists are issued a "provider identification number" (PIN) when they qualify as Medicare service providers. This is different from physicians who are issued a "unique physician identification number" (UPIN). This distinction is important as it relates to claim forms. 'Independently-practicing psychologists' must have services referred by a physician and therefore must list the name and UPIN of that referring physician. "Clinical psychologists" are not required to have their patients referred by physicians for Medicare coverage purposes.⁵ However, if a beneficiary happens to be referred by a physician, even if the referral is made to a "clinical psychologist," the name and UPIN of the referring physician must appear on the claim form.

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