FROM: PAUL SWATSENBARG, Deputy Administrator
Division of Medicaid
Audits of Mental Health Clinic services found that some providers are providing partial care (mental health day treatment) services outside the clinic facility. Some clinic providers were taking clients on field trips, outings or other community activities.
The Code of Federal Regulations defines Clinic Services at 42 CFR § 440.90. According to the CFR, clinic services means services furnished to outpatients “at the clinic”. The only exception are services furnished outside the clinic by clinic personnel under the direction of a physician to an eligible homeless individual who does not reside in a permanent dwelling or does not have a fixed home or mailing address. Clinic Services are facility services and may not be delivered in settings outside the definition of clinic services contained in 42 CFR § 440.90.
Any provision of mental health clinic services, including partial care services, outside the clinic facility must cease. Provision of clinic services including partial care outside of the clinic will be subject to recoupment.
If clients have a need for acquisition of skills in the community, they should be considered for Psychosocial Rehabilitation services. While Mental Health Clinic services are office based, the Psychosocial Rehabilitation option is designed to support community based services for persons with serious mental illness.
In addition, it should be noted that recreational, educational and vocational services are not Medicaid covered Mental Health Clinic services. The Code of Federal Regulations at 42 CFR § 440.90 and Idaho code at 16.03.09.465 indicate that the Department will pay for “preventive, diagnostic, therapeutic, rehabilitative, or palliative” services provided by a Mental Health Clinic. Recreational, educational and vocational services are not included.
If you have any questions, please contact Jack Weinberg at (208) 364-1844.
Thank you for your continued participation in the Idaho Medicaid Program.