Professional Documents
Culture Documents
Donald E Wiger
This edition first published 2021
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Library of Congress Cataloging-in-Publication Data
Names: Wiger, Donald E., 1953- author.
Title: The psychotherapy documentation primer / Donald E. Wiger.
Description: Fourth edition. | Hoboken, NJ : John Wiley & Sons, Inc.,
[2021] | Includes bibliographical references and index.
Identifiers: LCCN 2020021962 (print) | LCCN 2020021963 (ebook) | ISBN
9781119709848 (paperback) | ISBN 9781119709923 (adobe pdf) | ISBN
9781119709930 (epub)
Subjects: LCSH: Psychiatric records. | Mental health services—Medical
records. | Mental health services—Management.
Classification: LCC RC455.2.M38 W543 2021 (print) | LCC RC455.2.M38
(ebook) | DDC 616.890068—dc23
LC record available at https://lccn.loc.gov/2020021962
LC ebook record available at https://lccn.loc.gov/2020021963
Cover Design: Wiley
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10 9 8 7 6 5 4 3 2 1
Contents
Preface vii
How This Book Came Into Being: A Lesson in Making
a Really Bad Negative into a Really Good Positive ix
1 Introduction 1
2 The Art and Science of Psychological Assessment and Treatment 9
3 Overview of Current Documentation Procedures and Third-Party
Requirements 15
4 Ethical Considerations in Documentation 45
5 The Biopsychosocial Assessment 59
6 The Clinical Interview: Mental Status Exam 93
7 The Clinical Interview: Validating a Diagnosis 111
8 Formulating a Treatment Plan 135
9 Writing Progress Notes 163
10 Documenting the Need for Additional Services 195
11 Documenting Mental Health Treatment Outcomes for Individuals 201
v
Preface
T
he Psychotherapy Documentation Primer is designed to teach documen-
tal skills for the course of psychotherapy from the initial interview to
the discharge. The major revisions from the previous edition are due
to changes from the Diagnostic and Statistical Manual of Mental Disorders
(DSM)-IV-TR to the DSM-5 and more safeguards from potential procedural
errors and omissions. An appendix on documenting suicidality has also been
added.
The readership is intended for both students and professionals in the men-
tal health field. Several graduate schools have incorporated this text in courses
in which students learn to document clear evidence validating a diagnosis,
effects of psychotherapy, treatment planning, and outcomes. Several expe-
rienced mental health professionals have written that the training has been
quite helpful learning documentation techniques in which they had never
been taught. Graduate training in mental health covers a broad education in
several areas of psychology, psychotherapy, and other subjects related to the
helping professions, but all too often, it does not provide detailed training in
documentation techniques.
The documentation principles discussed in this text are especially helpful in
satisfying the often rigid requirements of third parties, such as insurance com-
panies and regulating agencies. In addition, the same documentation require-
ments satisfy what is typically required by mental health licensing boards.
Documentation, on the surface, appears to be a fairly dry subject. However,
those who learn empirical and succinct documentation techniques find that
the time they spend on this task reduces the time devoted to paperwork. Doc-
umentation is much more than basic “paperwork.” It provides clear evidence
of the effects of mental health treatment. One does not have to be in the field
very long until they experience an audit in which the only evidence avail-
able is what is documented. Documentation skills are an extremely important
aspect of being a therapist.
The first edition covered documentation in the basic areas of clinical ser-
vice. It was well received primarily because there wasn’t much published
vii
viii Preface
on this topic. The second edition was published shortly after several Health
Insurance Portability and Accountability Act (HIPAA) procedures were nec-
essary to document; additional examples were provided. The third edition
provided the same basic paradigms of documentation as the previous edi-
tions, with two additional chapters: (a) The Art and Science of Psychological
Assessment and Treatment, and (b) Ethical Considerations in Documenta-
tion. The current edition incorporates diagnostic criteria of the DSM-5 and
adds a chapter on documenting clinical outcomes and an additional appen-
dix on documenting suicidality.
Donald E. Wiger
How This Book Came Into Being:
A Lesson in Making a Really Bad Negative
Into a Really Good Positive
I
n 1991, I started a solo mental health practice with no clients, very little
money, no office furniture, and no formal business training. However,
I had a surplus of enthusiasm and dedication. I found a three-room office
suite that had been vacant for over a year, so I figured that I could get a
fairly good deal on the rent. The sympathetic, but also hungry landlord and
I worked out a deal in which I wouldn’t have to pay rent for the first few
months. He had nothing to lose because there had been no renters for over a
year. He was glad just to have a renter. The furniture for the office came from
my home. “Open for business!”
I did not take with me any of my clients whom I had seen from my former
employer. I considered that to be an unethical practice. Instead, I transitioned
them to other therapists when I left the practice. Of course, there can be excep-
tions to this rule, but be careful in such cases. I have seen too many thera-
pists start their own practices by taking their clients with them from another
agency. Over the years, I have witnessed many ill feelings between employers
and ex-employees who “took their clients” with them, often without notice!
This can cause much financial havoc for a clinic that has spent an incredible
amount of time, money, and effort to build their practice. Bottom line: Cover
such concerns in an initial contract with the employee or contractor. Be sure
to use an attorney with plenty of expertise in this area. A relatively small
investment up front could save your practice and reputation in the future. It
can be difficult to have balance between being both in business and being in
the helping profession.
To get started, I spent the remainder of my savings and much time estab-
lishing a counseling practice by scheduling talks with different groups,
sending out mailers to several organizations, and letting other mental health
professionals, with whom I had dealt previously, know that I had started a
private practice. Many referrals came from other therapists who had a full
ix
x How This Book Came Into Being
case load, in which they were glad to have a place to send people in need of
services. Even my previous employer sent referrals my way.
Fortunately, growth took place quickly, and within the first year there were
two additional full-time employees. The rate of growth skyrocketed because
we incorporated progressive, but ethical business principles and emphasized
customer service. Now we could afford nice furniture at home and at the
office!
Unfortunately, even though our clinic was on the right track, our quick
growth caught the eye of an insurance auditor. Our rather sudden volume of
business led to high payments from Medicaid. Because the amount of billing
skyrocketed from nothing to quite high in a few years, we were a red flag for
an audit. When I received notice of an audit I wasn’t worried because we had
records for every client and most likely underbilled rather than overbilled. So,
a few weeks later, when the auditors showed up for their scheduled review,
we were naively proud to show them that there were indeed their requested
intake notes, treatment plans, and progress notes. I had written them the
same way in which I was trained, so they must be pretty good!
The finding that complete records existed for every client and the rapid
growth of the clinic was never mentioned as a positive by the auditors. We
weren’t sure what they were attempting to find in our client records. The
auditors copied multiple files and informed us that we would hear from them
in about a month. Because they gave us no immediate feedback, we weren’t
sure whether when they returned we would receive accolades or reprimands.
But, we were quite confident that all was well.
For the next month, we did business as usual and didn’t think much about
the audit. However, when they showed up for the feedback session, our lives
soon changed. The auditors informed us that there were no financial impro-
prieties, and there were no records missing. We had not billed for any dates
of service in which there were no records and we had not overbilled for any
procedures. So far . . . so good. But, then they opened their briefcases with
seemingly hundreds of progress notes in which they said were “not in com-
pliance.” My initial thoughts were, “not in compliance with what?” I was not
taught a specific way to write progress notes in my graduate training, my
internship, or my previous employment. I simply wrote down what we did
in the session, just like at my previous job. But, they had never been audited!
My problem was that I didn’t know what I didn’t know, which is commonly
called “ignorance.” The old saying, “Ignorance of the law is no excuse” was
now staring me in the face. I soon learned that other old adage, “Ignorance is
bliss,” is not true.
The auditors kindly and respectfully explained that our progress notes
stunk. Their point was that just because services took place, it doesn’t mean
How This Book Came Into Being xi
otherwise, we would have gone out of business. At the time the effects of this
audit seemed like the worst thing that could have happened to me. I had no
one to blame but myself. I couldn’t tell the auditors that it wasn’t my fault
because no one had taught me how to appropriately document psychother-
apy; because as a mental health professional it was my responsibility to be
accountable for learning the procedures expected from me.
What surprised me, even more, was that the auditors weren’t mental health
professionals. They were trained in clerical areas. Although it took a while for
me to make the connection, I eventually woke up to realize that if people not
even trained in our profession can learn mental health documentation, I cer-
tainly had no excuses. This insight did not take place overnight!
The lessons learned from the audit inspired me to learn everything I could
about documentation of mental health services. I studied information availa-
ble from accreditation agencies, provider manuals from insurance companies,
journal articles, and a few texts that existed at the time. With this informa-
tion I revised our clinical forms to make sure that the information obtained
accurately covered what was required. After sharing this information with
colleagues, I was asked to present local seminars. This eventually led to pre-
senting this material in several seminars nationally, teaching documentation
skills. Before I knew it, my forms were published. The forms book is currently
in its fourth edition (Wiger, 2010), and I’m working on the next edition. The
auditors clearly did me a favor!
Now I’m glad that my clinic was audited. It changed my life! A negative
experience transformed into something quite positive. Now, when I hear fel-
low clinicians complain about auditors and insurance companies, I don’t nec-
essarily agree with them.
I have learned that when either an evaluation or therapy is being con-
ducted, with a “documentation frame of mind,” the treatment is much more
on target. It keeps me from getting off track with clients. It helps keep the
intervention focused, in which time is not wasted time with the client. I have
heard too many clients complain that, in their previous counseling, they did
too much chit-chat and not enough therapy. Oftentimes, they did not even
know that there was a treatment plan.
Of course, this is not to say that psychotherapy must be rigid and leave
out the “human factor.” Certainly, establishing rapport with the client is both
helpful and necessary, but it is a means to an end. For therapy to truly be
effective, it must progress beyond therapist–client relationship. Or, to put it
in baseball terms, getting to first base is a great first step, but if no further
progress takes place, it isn’t helpful in the long run. Too many clients state that
they go to counseling because it helps them feel good during the session, but
when they go home, nothing changes. But, it does not lead to effective change
How This Book Came Into Being xiii
Introduction
D
ocumentation of all aspects of mental health treatment is crucial in
this age of accountability. It is the only evidence demonstrating the
need and effects of treatment. Simply stating that a client has a cer-
tain diagnosis or claiming that therapy has been helpful to the client is an
opinion but not evidence. Empirical evidence demonstrating that treatment
was necessary and effective is essential. It is possible, and even compulsory,
to document the outcomes of psychotherapy in objective, measurable terms
without mechanizing or dehumanizing the process.
The clinical skills employed in psychological treatment are unrelated to
documentation skills. It is possible to be an excellent therapist but have poor
documentation skills. And, vice versa, one can be quite adept in documenta-
tion but not very helpful as a therapist. Of course, the goal is to be proficient
in each of these realms.
It is not the purpose of this text to teach a particular mode of therapy that
is easily documented, but rather, it is to teach documentation methods and
skills that are useful for any school of thought. Therefore, the focus of this
text is not on the “how to’s” of mental health treatment, but on documenting
the necessity, goals, and effects of therapy. If the examples used in the docu-
mentation training appear to reflect a particular school of thought, it is not
intentional.
We are living in the age of both personal and professional accountability.
In addition to mental health workers, professionals such as politicians, execu-
tives, clergy, educators, and people from most walks of life have increasing
demands placed on them to demonstrate that they have practiced their pro-
fession effectively and ethically. Reading the newspaper or watching the news
on just about any given day substantiates the point of widespread ethical
concerns. Modern political debates have emphasized ethical issues as much
as political issues. An increasing number of well-known public figures have
1
2 Introduction
measurable terms; that have nothing to do with behavioral therapy. The clinician
may conduct psychotherapy from any effective type of treatment (e.g., cogni-
tive, behavioral, dynamic, gestalt, rational-emotive, solutions focused, etc.).
Managed care companies, along with other third-party payers and accrediting
organizations, are open to this variation, provided that there is written evi-
dence of the course of therapy, not just a narrative. The evidence is presented
in terms of objective client behaviors, not opinions or speculation. Evidence
of alleviation of specific client impairments, which are secondary to the men-
tal health symptoms, is required. They question, “What improvements in
mental health or behavioral functioning are taking place as the result of the
present therapy?” It is our job to provide this evidence by means of written
documentation throughout the treatment.
Regulatory agencies require that the same measuring stick is used to assess
the effects of therapy regardless of the treatment modality employed. The
current measurement standards in mental health require that clinical docu-
mentation be observable, measurable, and provide behavioral evidence of
therapeutic progress.
Documentation begins at the first interview. The several documentation
procedures conducted throughout therapy are interrelated. The informa-
tion collected in the initial interview is necessary for writing the treatment
plan. The treatment plan provides a guideline for the course of therapy,
which is documented in the progress notes. Progress notes are necessary for
writing a revised treatment plan. All of the information collected is needed
in writing the discharge summary and assessing outcomes as outlined in
Figure 1.1.
The documentation procedure examples provided in this text represent
a course of treatment for a client with depression. In addition, Appendix
A provides documentation examples for a client with Panic Disorder with
Agoraphobia.
This text begins with teaching the rationale and examples of documentation
for each step of the therapeutic process. In addition, it provides training as to what
documentation is required for third-party payers and accreditation agencies.
HIGHLIGHTS OF CHAPTER 1
●● Accurate and specific documentation procedures are necessary for ethical,
professional, and financial reasons.
●● Third-party payers and accrediting agencies are becoming more stringent
in their required documentation procedures.
●● The intake, treatment plan, progress notes, revised treatment plan, and
discharge summary are interrelated. Although they are independent
documents, they represent a continuous process in therapy and doc-
umentation.
●● Each step in the counseling procedures has specific documentation proce-
dures, if not followed, could be detrimental to the client, therapist, and the
clinic. Likewise, all can benefit with appropriate procedures.
●● Documentation procedures are atheoretical. They do not represent a form
of treatment, but rather, they demonstrate the effects of treatment in objec-
tive, measurable terms.
QUESTIONS
1. In the medical model of documentation, the means by which a therapist
documents therapy
a. depends on the theoretical school of thought.
b. is atheoretical.
c. is not important.
d. incorporates documenting impairments rather than strengths.
2. A current requirement by most third-party payers to cover mental health
services is documenting
a. that personal growth will take place in therapy.
b. that a preexisting condition was not present.
c. proof of insurability.
d. medical necessity.
3. Client files that are audited by a third-party payer that not found to be
compliant with documentation standards
a. typically leads to loss of licensure.
b. is a minor concern to most clinicians.
c. may be subject to repaying funds back to the third-party payer.
d. is a clear violation of confidentiality.
Introduction 7
“There is no pretense that reason and reason alone, or that science and sci
ence alone, can prevail by themselves in any kind of human relationship,
personal or therapeutic.”
(Mann, 1973, p. 48)
M
ental health clients desire a treating professional who is knowleg
able, caring, empathic, and able to help them work through issues.
However, they do not want treatment from someone who fully
“plays it by ear” or says whatever comes into mind. A high degree of pro
fessionalism and knowledge is expected. Otherwise, why would we need
graduate training? On the other hand, clients do not desire working with a
therapist who is so scientific or technical that the human element is lost. A
combination of art and science is necessary in the delivery of mental health
services (Walborn, 1996).
Mental health professionals vary tremendously in their views of how
to accurately collect diagnostic information and conduct therapy. On one
extreme we have those who believe and practice psychology based on
their gut feelings, intuition, and their inner gift of helping others. The other
extreme consists of a close adherence to a rigid scientific medical model. If
one were to observe therapists from each of the two extremes it would seem
as if they were in different professions. Most of us are somewhere in between,
in which we rely on both the lessons of scientific research and our clinical
acumen and insight.
The clinical practices in the field of psychology follow the same pendulum
as other historical trends. Sometimes the pendulum swings toward hard sci
ence, but eventually, when it becomes too regimented; we miss the “good old
days” and gradually return to the softer sciences and less empirical methods.
9
10 The Art and Science of Psychological Assessment and Treatment
But, the further the pendulum swings, we realize that we need more empiri
cal research for our practices, and the pendulum gradually reverses.
The following two sections discuss differences between practicing therapy
as an art vs. science. Therapists are not “one or the other.” Each of us practice
somewhere between the two poles. Thus, it is likely that you adhere to some
aspects of each dimension.
As an Art As a Science
1 2 3 4 5 6 7 8 9 10
the major therapies are compared and contrasted as to their effectiveness. The
focus of the text is that the mode of therapy is not what leads to client change.
Instead, Walborn (1996) lists four process variables, which, if they take place,
no matter what type of therapy (art vs. science), client change will take place.
These variables include (a) the therapeutic relationship, (b) cognitive insight
and change, (c) emotions in therapy, and (d) client expectations. Walborn
(1996) describes how even though the therapies might appear to be quite dif
ferent; they each treat the various components of the process variables. Thus,
it is not the therapies themselves that lead to client change, but transforma
tion takes place from the common therapeutic processes they have in com
mon. This is not to say that all therapies are the same. Although the various
therapies hold different views of what is necessary for client change, the pro
cess variables that lead to client change are common between the therapies.
HIGHLIGHTS OF CHAPTER 2
●● There is clearly no set or standardized means of conducting psychologi
cal services.
●● Those who view psychotherapy as an art hold values such as gut feelings,
intuition, and insight.
●● Those who view conducting psychological services as a science hold val
ues such as the scientific method, in which objective data are incorporated
into treatment.
●● Other schools of thought incorporate a combination of incorporating treat
ment as both an art and science.
●● Although the various theoretical perspectives may seem to be diverse, they
have common process variables in which their commonalities contribute to
client change.
●● No matter what therapeutic orientation a therapist follows, documentation
is atheoretical, in which current standards require an empirical format.
14 The Art and Science of Psychological Assessment and Treatment
QUESTIONS
1. Which of the following best represents a statement from someone who
views psychotherapy as an art? “Today we worked on . . .
a. “. . . identifying why she feels rewarded by excessively washing her hands.”
b. “. . . expressing latent emotions.”
c. “. . . identifying what factors lead to outbursts at work.”
d. “. . . identifying rational behaviors.”
2. Which of the following treatment strategies would most likely be incorpo
rated by someone from a scientific perspective of psychological treatment?
a. Dream interpretation
b. Psychiatric hospitalization
c. A-B-C model
d. Expressing empathy
3. According to this text, documentation
a. is atheoretical.
b. should correspond to the theoretical model used in treatment.
c. it important, thus it requires much of the therapist’s time.
d. All of these.
4. Process variable research
a. maximizes the differences between psychological therapies.
b. suggests that there are very different processes that take place in the
various therapies.
c. suggests that documentation can be either written as an art or science.
d. integrate the similarities between psychological therapies.
5. Because the modes of psychotherapy vary tremendously, documentation
of psychotherapy
a. also differs between them significantly.
b. must clearly represent the theoretical model used in treatment.
c. is useless because it violates the client’s right to privacy.
d. None of these.
Answers: 1b, 2c, 3a, 4d, 5d
CHAPTER 3
I
n the not-so-distant past, documentation consisted of little or no more than
verifying that an interview took place, making a diagnosis, perhaps mak-
ing a treatment plan, and writing rudimentary progress notes. Because
there were few specific standards, documentation was a matter of subjective
opinion. It was not given much attention in graduate schools. Although clini-
cal judgment will always be an extremely important part of understanding
client behaviors, there must be a balance of incorporating universal proce-
dures (e.g., Diagnostic and Statistical Manual of Mental Disorders [DSM]-5 cri-
teria, professional regulations, accreditation standards, third-party payer
requirements, clinic standards, etc.), when documenting services. In the past,
insurance companies that paid for mental health services listed few or no
documentation requirements to validate a diagnosis or the client’s need for
services. Clients receiving mental health services seldom knew their diagno-
sis or even if there was a written treatment plan. Now, the client’s input is an
important part in formulating, following, and revising the treatment plan.
Today, in the age of professional accountability, clinical proficiency is abso-
lutely necessary, but not sufficient, in encompassing all aspects of mental
health services. Third-party payers demand evidence that demonstrates both
the need for and effectiveness of mental health treatment. An insurance com-
pany or an accreditation agency does not interview a client to determine the
effectiveness of services. (However, at times, outcomes surveys are sent to
clients.) The professional board by which the mental health professional is
licensed will likely review a licensee’s records for a client when a complaint
is filed. They all rely on written documentation from the therapist. Therefore,
15
16 Current Documentation Procedures and Third-Party Requirements
if services are not properly documented, the most skillful therapist could
appear, on paper, to be ineffective with clients for the sole reason of inad-
equate documentation. This can lead to significant multifaceted losses (termi-
nation of services, loss of insurance contract, reimbursement to the insurance
company, suspension of licensure) to the therapist. There are cases in which
very poor documentation has been reported to professional boards, leading
to reprimands and required supervision, continuing education, and some-
times, license suspension. Documentation is a necessary part of the training
and continuing education of mental health professionals.
It can be upsetting after seeing a client for a few sessions and then being
required to request an authorization for additional services. However, with
proper training, learning appropriate documentation procedures can both
increase the quality of therapy and save writing time. Good documentation
does not equate with long reports. Brevity, coupled with specificity, can easily
be learned and is preferred by most readers.
If the therapist is not proficient in documentation procedures, it is possible
that further payment for services could be denied, even if the client highly
needs treatment. Thus, learning and following objective documentation pro-
cedures is in the best interest of both the client and the therapist. The case
manager, clinical supervisor, or auditor reviewing the case has no other infor-
mation to review other than the therapist’s written evidence. They do not sit
in on a psychotherapy session to evaluate the effects of treatment. They do
not provide a separate diagnostic interview with the client to verify the infor-
mation. Their only awareness of the client’s concerns is what you document;
that’s it!
When additional services are declined by a third-party reviewer, the rejection
is more likely due to inadequate documentation rather them refusing to allow
a needy client to receive treatment. Your documentation is the evidence for the
need for continued service. The adage, “if it isn’t written down, it doesn’t exist,”
holds especially true for clinical documentation. A client with severe mental
health problems, who receives therapy from a therapist without adequate
documentation skills, could be denied services because of the therapist’s
lack of documentation skills. Thus, poor documents can ultimately lead to
termination of insurance payment of mental health services. All too often,
therapists blame the insurance company when additional services are denied.
Services are generally denied for a reason. . .“lack of evidence.” The evidence
comes from the evidence that the therapist provides, not from the client.
When a file is audited or reviewed, the reviewers do not assume that,
because documents such as the treatment plan and progress notes are pre-
sent, all is well. The information in the chart must clearly paint a picture of
the client’s condition and necessity for treatment. The process is similar to an
Current Documentation Procedures and Third-Party Requirements 17
because his insurance will pay for physical therapist, he is entitled to the ser-
vices of a physical therapist. However, his massage is not medically neces-
sary, even though it makes him feel better. Receiving services from a mental
health professional is not automatically covered because they were provided
by a professional contracted with an insurance company. If there is not a cov-
ered diagnosis and demonstrated medical necessity for services, they are not
covered by insurance. Billing for services that are not covered by an insurance
company can lead to being denied coverage, and if some sessions have taken
place, it can lead to paying back money they have paid you.
One of my first positions as a psychologist was at a large mental health
clinic to which many of the clients came for marriage counseling. The clinic
director told the therapists that the bulk of insurance companies did not pay
for this service; therefore, we were instructed to list one of the partners are
the “identified client.” We were then instructed to give this person an Axis I
diagnosis, so that there would be insurance coverage. And to top it off, we were
required to write the progress notes as if the identified client were the only one
receiving services and make no mention that the other person attended the
session. The rationale given for that was that it was for the overall good of the
family and that insurance companies “should” pay for this service. I left this
job after a very brief period because the practice was clearly an example of
insurance fraud. About one year later, the clinic was audited, the inappropriate
insurance billing was discovered, and the clinic was soon out of business.
into one particular graduate school course. When considering the numerous
required courses, there is usually little or no room for additional courses
in most training programs. Even if documentation procedures are not
taught specifically, it is usually assumed that students will be taught these
procedures during their practicum and/or internship experiences. Often,
though, documentation training does not take place here either, because
typically, in an internship, graduate students see clients pro bono or for
a reduced fee rather than through third-party payment; therefore, their
documentation is not subject to third-party payer regulations. In addition,
their clinical supervision typically has focused on the quality of therapy
and case conceptualization skills, which in themselves are an arduous task
to master. Historically, students’ documentation skills have not always been
scrutinized with the same rigor by their clinical supervisors as they would
be by a third-party payer. Nevertheless, documentation training in graduate
school is on the rise due to the realities in the field.
The diagnosis of a mental disorder should have clinical utility: It should help
clinicians to determine prognosis, treatment plans, and potential treatment
outcomes for their patients. However, the diagnosis of a mental disorder is not
equivalent to a need for treatment. (p. 20)
MEDICAL NECESSITY
The concept of medical necessity has dramatically influenced current third-
party reimbursement procedures for mental health services. Mental health
services are considered medically necessary when the client is significantly
impaired in areas such as social, occupational, educational, behavioral, emo-
tional, or other types of functioning. Plus, without mental health services, the
client is not likely to improve or return to premorbid or adequate functioning.
Thus, mental health services are medically necessary in such cases.
Prior to adopting the medical necessity model, third-party payers paid for
services when qualified clinicians diagnosed clients with a mental health disorder.
This is still part of the process, but receiving a diagnosis alone is not sufficient to
guarantee payment for services. A person who endorses a number of symptoms
of, for example, Major Depressive Disorder, might be functioning adequately
socially, occupationally, and in other areas. Simply experiencing some mental
health symptoms may not fit the third party’s criteria for coverage of mental
health services. That is, services might be helpful but may not be necessary. For
example, if someone is going to work every day, spending time with friends,
and keeping up with typical daily activities but feels sad, it might not meet the
medical necessity criteria of a third-party payer. Thus, if the therapist does not
document impairments, there is no evidence of medical necessity for services,
and payment for services could possibly be denied. This does not contradict the
DSM-5’s similar designation that symptoms, by themselves, are not sufficient to
assign a diagnosis. There must be accompanying impairments described.
One could say that there are two types of counseling services: those which
are medically necessary (which would qualify for insurance payment), and
those which are not necessary (not qualify for insurance payment); both
of which are helpful to the client. One fits the criteria for most third-party
payers, whereas the other does not.
Criteria for diagnosing a mental health diagnosis have also been in tran-
sition. The typical procedure several years ago for making a diagnosis was
simple endorsement of mental health symptoms that defined a diagnosis.
For example, if a client endorses having a number of symptoms of depres-
sion such as weight loss, low appetite, sadness, decreased concentration, and
decreased sleep, it is likely that a diagnosis would be given in the past solely
based on symptoms. However, simply endorsing symptoms is not enough
because it does not imply the degree (i.e., mild to severe) of the symptoms
or their effect on the client’s functioning. Current diagnosis procedures must
validate both the existence and degree of symptoms and demonstrate that
there are resultant impairments as a result of the mental health disorder.
The degree to which symptoms affect the client’s behavior and functioning
is much more significant than acknowledging that symptoms exist. To qualify
22 Current Documentation Procedures and Third-Party Requirements
Without such criteria, there is not clear means of documenting that the ser-
vices being rendered are needed. Although third-party payers’ specific regu-
lations regarding forms, frequency of reports, and so forth may differ in some
areas, the overall information requested is remarkably similar.
Onset
Frequency
Antecedents
Intensity
Duration
Term Description
Onset When symptoms and impairments began
Frequency How often or frequently symptoms and
impairments occur
Antecedents Events or stressors leading to onset/exacerbation
of symptoms
Intensity Severity of symptoms (e.g., mild, moderate, severe, or
scale (e.g., 1–100)
Duration How long (seconds, minutes, hours, etc.) symptoms last
Client with Panic Attacks Mya W. began having panic attacks when she lost
her job (Antecedents) 6 months ago (Onset). Currently, she has an average of
three panic attacks per day (Frequency), which last an average of 5–30 min-
utes (Duration). Panic attacks typically take place when she leaves the house,
when the phone rings, or when someone comes to her door (Antecedents).
She describes the effects as severe, rating them as a 95 on a scale of 1–100
(Intensity).
given here. The DSM-5 lists specific requirements that must be met in order
to make a diagnosis. The specific types of requirements vary by diagnosis;
however, the O-F-A-I-D procedure is helpful in validating or providing sup-
portive evidence that the diagnosis given to a client matches specific DSM-5
criteria. (See Table 3.1)
The DSM-5 notes that it is possible for a person to experience symptoms
of a disorder but not be diagnosed as such because the severity of the symp-
toms is not enough to validate that impairments are prevalent. Insufficient
documentation can make clients appear, on paper, to be less afflicted than
they actually are. If medical necessity is not found to be evident due to insuf-
ficient or inadequate documentation, reimbursement might be denied. Both
symptoms and impairments must be validated to properly assign a diagno-
sis. Simply diagnosing a client by the sole means of a symptom checklist is
insufficient evidence. The resultant impairments must accompany the listed
symptoms. The following examples highlight incidents where medical neces-
sity is not adequately documented:
Depression
●● Poorly Documented Symptoms: “The client is depressed, withdrawn, suf-
fers from lack of sleep and fatigue, feels anxious, and has feelings of
confusion.”
●● Specific Problems in the Documentation: This statement does not provide
adequate documentation for a diagnosis because it lists only symptoms.
The evidence presented does not provide evidence of impairments. It is
possible that the client is functioning adequately because the severity of
Table 3.1
Example of Use of O-F-A-I-D Procedure in Validating a Diagnosis of
Major Depressive Disorder
Depressive symptoms or lack of “Client has been depressed for the past 8
pleasure for at least 2 weeks months.” (onset)
Depressed most of the time “Client states that she is depressed most of the day at
least 5 or more days per week.” (duration and frequency)
No DSM-5 requirement for antecedents for
this diagnosis
Qualifiers of mild, moderate, “Level of depression is severe, due to significant
severe, and other descriptors impairments socially and occupationally.” (intensity)
Panic Attacks
●● Poorly Documented Example: “The client has panic attacks.”
Specific Problems in the Documentation: This statement also does not
provide enough information to warrant a diagnosis of a mental disor-
der. The label “panic attacks” could be explained using the O-F-A-I-D
procedure to provide a clearer picture of the history and level of symp-
tomology. Most people have had at least one panic attack in their lives,
Current Documentation Procedures and Third-Party Requirements 27
but it does not constitute a panic disorder. Others have frequent, debili-
tating panic attacks causing significant dysfunction that interferes with
a wide array of daily activities. The main problem with this statement is
that it could apply to someone with panic attacks of any degree, whether
very mild or severe. The description is missing evidence of the DSM-5
criteria for a panic disorder and the resulting impairments.
●● Properly Documented Example: “The client experiences panic disorder
without agoraphobia. Symptoms last at least 10–20 minutes and have
occurred at least twice per day for the past year. DSM-5 symptoms
endorsed include palpitations, hot flashes, sweating, chest pains, dizzi-
ness, trembling, and fleeing the situation. Panic attacks take place when-
ever he is in any stressful situation and cannot cope. During the past 3
months, panic attacks have increased in duration from an average of
2 per week to an average of 1 per day. Previously panic attacks lasted
no more than 5–10 minutes. Current impairments include avoiding any
new or stressful situations and leaving work early approximately three
to four times per week. He has gone to the emergency room three times
in the past month, believing that he was going to die.”
The client has been experiencing (problem area) for the past (time span)
as evidenced by (list of symptoms that are concordant with DSM-IV) resulting
in (specific areas of impairment) impairment(s) as evidenced by (specific
examples of functional impairments) .
Figure 3.1 Suggested format for documenting client symptoms and functional
impairments
Source: Reprinted with permission of John Wiley & Sons, Inc.
Current Documentation Procedures and Third-Party Requirements 29
does not always mean the driver cannot drive the car. The severity of the
problem depends, in part, on how low tire is on air. A tire that is designed to
have 32 psi (pounds per square inch) of air pressure will likely work fine if
the pressure is anywhere from 25–40 psi. But, if the air pressure is, for exam-
ple 2 psi, it is not drivable, and needs services before the car can be driven
again. Other descriptors, such as how long there has been trouble with the
tire losing air, how often it must be filled up, and the condition of the tire will
help you make a more informed decision about whether to continue driving
the car or to take it in for service. Likewise, listing vague mental health symp-
toms alone does not provide enough specific information to make a diagnosis
or plan treatment.
Figure 3.2 illustrates the difference between simply listing a client’s symp-
toms and documenting the impacts of those symptoms by adding qualifi-
ers to demarcate additional dimensions of impairment. Profile 1 represents
two clients appearing to suffer from the same problem. Notice the difference,
however, when further descriptors are added in Profile 2.
Adding the descriptors of the O-F-A-I-D procedure provides evidence
that Client B is more severely impaired than Client A. Documentation pro-
cedures that address only symptomology miss this important distinction.
For this reason, it is difficult to make a clear diagnosis when only symp-
toms are described. Likewise, it is difficult to convince third-party pay-
ers that a diagnosis (or treatment) is warranted when only symptoms are
documented.
In addition, when documentation of specific functional or behavioral
impairment is lacking, there is meager evidence to use in determining the
type and number of services most appropriate for the client. The DSM-5
(APA, 2013) states, “Therefore, a generic diagnostic criterion requiring dis-
tress or disability has been used to establish disorder thresholds, usually
worded, “the distress causes clinically significant distress or impairment in
social, occupational, or other important areas of functioning” (p. 21).
Appropriate documentation for diagnosis, treatment planning, and reim-
bursement requires specifying the degree to which symptoms are impairing
various areas of the client’s functioning. Current standards in documentation
incorporate the level of functional impairment as the measurement stand-
ard of the effects of mental illness symptoms. Incorporating impairments
and dysfunctions presents a sharper picture of a client’s mental status. Also,
decisions regarding the medical necessity of treatment are more clearly com-
municated, and treatment planning may be written and understood more
clearly when examples of the client’s level of functioning are included in
the report.
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