As most registrants are aware, the coverage of psychotherapy services varies by provider and individual plans. CRPO does not set or enforce requirements for insurance companies and cannot speak to their billing requirements or their remuneration of services. Members of the public and clients need to consult with their benefits provider before beginning services to confirm the details of their coverage. This includes things such as what services are covered by the plan; whether their plan covers services provided by CRPO registrants; and whether the plan extends to their family members and/or significant others.
When clients request receipts for insurance billing purposes, registrants must ensure they are meeting CRPO Professional Practice Standards.
College requirements for financial records are provided in Professional Practice Standards 5.5:, Record-keeping – Financial Records, and 5.3: Issuing Accurate Documents. As well, CRPO has developed a Financial Records Checklist to help registrants conduct a self-review of their financial record-keeping practices and there is a Practice Matters article that discusses fees and billing. (See links in Related Resources below.)
As indicated in Standard 5.5, financial records must include a client’s full name. This becomes a grey area when the client includes more than one person or when parents attend services to support a child client. Because the Standards do not specifically indicate how to identify the client in such cases, registrants must use their professional judgement to determine what is reasonable.
For example, Standard 5.3 requires registrants to provide clients with accurate records and other documents and ensure they do not sign or send documents containing misleading or false information. Therefore, it would be inappropriate to issue a receipt indicating services were provided to someone who was not present during the session. However, it is possible to clearly describe the services provided on an invoice or receipt, e.g., “couple therapy”, “family therapy”, “session with parents regarding their child’s psychotherapy”.
An RP can use discretion to determine who is identified as the client for a particular session for billing purposes. For transparency and to avoid billing issues, the College recommends that registrants determine any requirements an insurance company might have with respect to billing.
Here are some specific examples:
Can I issue a receipt in Client A’s name if I see Client B for individual therapy as a component of Client A and B’s couple therapy?
While receipts must describe the services provided and identify the client to whom service was provided (e.g., “Individual session with Client B regarding their couple therapy with Client A”), it might be possible to issue a receipt in one person’s name, for example, if the person receiving the receipt is the person who paid for the services or if it is acceptable to the insurance company. As noted above, it is best to let clients confirm the details of their benefit plan and whether the plan extends to their family members and/or significant others.
In this situation, it would be inappropriate to issue a receipt implying Client A was at the session.
I am meeting with parents to discuss their child’s progress in therapy. Can I issue a receipt in the child client’s name, even though they were not in the session?
As noted above, receipts must accurately describe the services provided and identify the client to whom service was provided. In cases where a session is provided in relation to another client’s overall treatment, it is important to clearly describe the services on the receipt.
For example, “Family session with parents regarding Child A’s psychotherapy”.