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reimbursement found that “ State scopes of practice are broad and as a result, provide little guidance that carriers can use to process claims.” (OIG, 2001, p.7) As our analysis has revealed, where they are licensed, the four professions detailed in Tables 1-4 are each authorized to deliver the three identified core mental health services independently in most states.

In addition to these three services, we examined the more narrowly defined services of diagnosis and psychotherapy. As mentioned in our definition section, diagnosis involves the assignment of a diagnostic category from the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (third edition revised or fourth edition). Where reimburse- ment requires that a diagnostic code be submitted with the claim, a clinician legally permitted to diagnose must determine the appropriate diagnosis. We chose to examine diagnosis in greater detail because in the past some insurance companies have used the lack of explicit permission to diagnose as the rationale for denying payment to some master’s level professionals (Strosnider & Grad, 1993). Thus, without directly addressing reimbursement, a licensure law may provide a basis on which a carrier may deny payment. Table 5 indicates that, while each of the four practitioner types is authorized to diagnose in some states, many states do not explicitly address this function. And, although there is variability by profession, in some states the permission to diagnose is not explicitly granted to any of the core mental health professionals (including psychologists).

Similarly, psychotherapy is not explicitly mentioned in many state licensure laws, although none expressly forbid it to the four practitioner types we studied. Like diagnosis, the lack of explicit statutory authorization to engage in psychotherapy with a patient/client may create barriers to reimbursement for some providers. Typically, the CPT codes used for third party reimbursement of mental health services include psychotherapy, not the more general term “counseling.” If a practitioner type is not explicitly authorized to provide psychotherapy, an insurance company may choose not to reimburse that provider type, despite the fact that there may be little or no functional difference between psychotherapy and individual counseling from the patient’s or the provider’s perspective. Table 6 demonstrates that, as with diagnosis, each of the four provider types we studied is authorized to provide psychotherapy services in some states, and no profession is explicitly prohibited from providing them. Table 7 provides total numbers of states that permit diagnosis and psychotherapy for each profession. There is some variation by profession, with psychologists being the most likely to have explicit statutory permission to engage in psychotherapy, followed by social workers. However, not all state

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