If you’re billing PHP rates—but your schedule looks suspiciously like an IOP—you’re not alone. At Capture RCM, we work with programs in fast-growth mode that hit this wall all the time: “Wait… are we billing this right?” If your team is growing faster than your backend can keep up, here’s what to check before you end up flagged, denied, or worse—audited.
Understand the Real Difference Between H0035 and H0015
Let’s get one thing clear: these codes aren’t just interchangeable labels for group therapy hours.
- H0015 (PHP) is typically 5–6 hours per day, often 5+ days per week. It assumes full-day structure with medical oversight.
- H0035 (IOP) is for 2–3 hours per day, often 3–5 days per week. It reflects a lower-intensity level of care.
If your program downsized groups, lost staff, or changed the schedule—but kept billing PHP—you may be headed for recoupment.
Check Your Documentation Against Your Codes
It’s not just about time—it’s about what you’re doing and how it’s documented. Auditors don’t just want timestamps. They want:
- Proof of medical necessity for the higher level of care
- Staff credentials that match the level billed
- Group notes that justify intensity and frequency
Billing intensive outpatient program services under PHP codes without evidence? That’s not a gray area. That’s a target.
Spot the Sneaky Ways IOP Creep Happens
This one’s tricky. Here are a few red flags that your “PHP” might be drifting toward IOP:
- Clients only stay for morning groups and leave
- Medical staff is “available” but not actually engaging with clients daily
- Your team says “It’s a light day” more often than not
- You’re offering 15-20 hours/week but billing H0015
If this sounds familiar, you’re not noncompliant yet—but you’re close. It’s time to reassess before someone else does.
Align Services with the Code, Not the Other Way Around
This isn’t about playing defense. It’s about protecting your clinical credibility.
If you’ve scaled back programming hours or reduced clinical staff, billing IOP (H0035) may be the compliant—and more sustainable—choice. It also reduces your risk exposure in payer reviews, especially if you operate in higher-scrutiny states like North Carolina or Ohio.
And if you’re offering solid evening IOP but your EHR still says “PHP” everywhere? Let’s clean that up.
Talk to Your Billing Partner Before the Payers Talk to You
This is where a smart RCM partner earns their keep. Before you adjust schedules or billing logic, bring in your ops or billing team (hi, that’s us). We’ll help you:
- Map your current programming against code requirements
- Spot mismatches that could trigger denials or clawbacks
- Shift codes or adjust service delivery to stay compliant
We’ve walked programs through this pivot without imploding census or scaring staff.
You Don’t Have to Guess at This Stuff Anymore
Growth doesn’t have to mean guessing—or hoping no one notices. With the right partner, your intensive outpatient program billing strategy can actually match what your team is doing on the ground.
And the truth? That alignment isn’t just a billing win. It’s a compliance one. A clinical one. A sustainability one.
📞 Need Eyes on Your Codes Before They Cost You?
Call (380) 383-6822 or visit our intensive outpatient program billing services page to learn more. We’ll help you catch the cracks before the auditors do—and show you how to course-correct without panic.
