Can CMHCs who are acting as representative payee’s bill MRO billing for the representative payee activities if helping a consumer with their bills is part of their rehabilitation plan?
The answer to this question rests largely on whether the activities associated with acting as a representative payee meet the service definitions of MRO services and whether the consumer is eligible for MRO services based on diagnosis, level of need and ability to benefit from the services (in other words, are the services medical necessary?). This type of service would fall within the defined activities of proposed Skills Training and Development (e.g. development of skills for daily life management). In order to be eligible for reimbursement, all other requirements associated with an MRO service would need to be met (e.g. qualified provider, eligible consumer, service is part of a goal-oriented treatment plan that is updated regularly). However, reimbursement for acting as a representative payee can only occur when the activities coincide with those that would otherwise occur as part of the consumer’s treatment plan. For example, the treatment plan would need to include goals around
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