Defining Billing Privileges, Direct Billing, Online Billing, and Receipt Submission

Over the years, we have had a few questions surrounding billing privileges, direct billing, online billing, and receipt submissions. As this is an incredibly important part of having a successful massage therapy/manual osteopathic practice, and as fraud can have a long lasting impact on a therapist, this information is meant to make you aware of the definitions of each of these phrases, what they mean to your practice, and how you can prevent being the victim of fraudulent acts committed on your behalf, which you could be monetarily liable for should they occur.

Let’s start by defining each of these phrases.

Billing Privileges are defined as your right as a Full Massage Therapist Member, a Spa Therapist Member, a Registered Massage Therapist Member, an Associate Massage Therapist Member, or a Full Manual Osteopathic Therapist member to issue a receipt containing your CMMOTA membership number for the professional services (massage therapy or manual osteopathic therapy) which you provide to your clientele. This must be done in such a way that you are compliant with the CMMOTA Receipting for Services and or Products Policy for your professional designation (find them here).

Direct Billing only applies to CMMOTA Full Massage Therapist Members, Registered Massage Therapist Members, and Full Manual Osteopathic Therapist members, all other classes of membership do not have the ability to direct bill. Direct Billing is defined as your right to submit a claim on behalf of a client to their insurance provider for direct reimbursement to you as their treatment provider. This right is dependent on a couple of things – first, being registered with the insurance provider to direct bill, second – having the written permission of the client (current within 1 year) to file a claim on their behalf, and to share any requested treatment information with the third party (e.g., treatment notes). Below we will talk about the potential for fraud to be committed on your behalf if you assign your direct billing privileges to a third party (a clinic you work for, a receptionist, etc.). Specifically, when it comes to manual osteopathic therapists, direct billing is currently limited, but growing – for a list of insurance companies that allow direct billing for manual osteopathic therapy, please contact info@cmmota.com.

Online Billing only applies to CMMOTA Full Massage Therapist Members, Registered Massage Therapist Members, and Full Manual Osteopathic Therapist members, all other classes of membership do not have the ability to online bill. Online Billing is defined as your right to submit a claim on behalf of a client to their insurance provider for direct reimbursement to the client or policy holder. Under this scenario, you would collect payment directly from the client and then submit the information on their behalf for reimbursement directly to them. This right is dependent on a couple of things – first, being registered with the insurance provider to direct bill, second – having the written permission of the client (current within 1 year) to file a claim on their behalf, and to share any requested treatment information with the third party (e.g. treatment notes). Below we will talk about the potential for fraud to be committed on your behalf if you assign your online billing privileges to a third party (a clinic you work for, a receptionist, etc.)

Receipt Submission is defined as a client submitting the receipt, which a therapist provides to the client under their Billing Privileges, to their health insurance company for reimbursement to the client or policy holder. Here it is important to note that if you are currently not providing any direct billing, that you may need to take the time to register with the insurance companies as an eligible provider. We will talk more about this a little bit later in this article.

Fraud Prevention Steps – here we are specifically looking for fraud prevention steps that you should be taking if you are assigning your Direct Billing privileges as a therapist to any person or business. As a therapist you need to be aware that if fraud is committed using your direct billing privileges that you may be responsible for repayment of any fraudulent transactions which occurred through Direct Billing to a health insurance company.

One step that you need to take if you are assigning your Direct Billing privileges to a company is to have some sort of written agreement drawn up that allows them to do that on your behalf. A great place to have it included is in your employment/subcontractor contracts. The important piece here is to cover yourself as best you can from a liability standpoint, if anyone you assign to Direct Bill on your behalf commits fraud.

A second step to implement as a best practice is to contact each insurance company on a monthly or quarterly basis and ask for a detailed report of your billing number. You can then compare that list to a list of your actual client/appointment list to ensure that the lists and invoice amounts match, and that no fraudulent charges have been put through.

Steps to take if you think fraud is occurring – if you suspect that fraud is occurring through your Direct Billing privileges, there are several steps that you can take. First, contact the insurance companies to let them know about your concerns – be as detailed as possible. Second, contact the Association and let us know. One thing that CMMOTA can do is to issue you a new membership number, leaving the old number as cancelled, which should alert any insurance company of a fraudulent claim being submitted. Finally, revoke in writing any assignment of Direct Billing privileges that have previously been assigned.

Returning to receipt submission – as a therapist, one of the first steps you will want to take once you are able to start providing receipts to clients once you have obtained your billing privileges as described above is setting up your insurance profiles. You will want to provide each insurance provider with your business information, and CMMOTA membership number so that when your clients start to submit their claims, they will be able to find you in the system and submit their claim. Please keep in mind that this step will still need to be done even if you will not be providing direct billing or online billing services to your clients. For more information on how you can complete this important task, please contact the CMMOTA office at info@cmmota.com.