Psychologists Practicing Independently

10.2.3.13 – Psychologists Practicing Independently (Rev. 13355; Issued: 08-13-25; Effective: 05-05-25; Implementation: 05-05-25) Pub. 100-02, chapter 15, section 80.2 states that a psychologist practices independently when: • The individual renders services on the individual’s own responsibility, free of the administrative and professional control of an employer, such as a physician, institution, or agency; • The persons the individual treats are the latter’s own patients; • The individual has the right to bill directly, collect and retain the fee for services performed; and • The individual is state-licensed or certified in the state where furnishing services. A psychologist practicing in an office located in an institution may be considered an independently practicing psychologist when both of the following conditions are met: (1) the office is confined to a separately-identified part of the facility that is used solely as the psychologist’s office and cannot be construed as extending throughout the entire institution; and (2) the psychologist conducts a private practice (i.e., services are rendered to patients from outside the institution as well as to institutional patients). Independently practicing psychologists have a more limited benefit under the Medicare program than clinical psychologists. With a degree starting at the master’s level of psychology, independently practicing psychologists are authorized to bill the program directly solely for diagnostic psychological and neuropsychological tests that have been ordered by a physician, clinical psychologist, or non-physician practitioner who is authorized to order diagnostic tests. Independently practicing psychologists are not authorized to supervise diagnostic psychological and neuropsychological tests. Any tests performed by an independently practicing psychologist must fall under the psychologist’s state scope of practice. The contractor shall ensure that all persons who check “Psychologist Billing Independently” in Section 2H of the Form CMS-855I answer all questions in Section 2J2. If the supplier answers “no” to question 1, 2, 3, 4a, or 4b, the contractor shall deny the application. See Pub. 100-04, chapter 12, sections 160 and 160.1 for more information on psychologists billing independently.