All information about the arrangement model
The SBAP campaigned intensively for many years for the system change of psychological psychotherapy. Together with its partner associations ASP and FSP, it is submitting the petition "Remove hurdles" in 2019. In the summer of the same year, the consultation on the prescription model was opened by the federal government.
On 1.7.2022, the order model was introduced throughout Switzerland. This was followed by a six-month transition period before the delegation model was finally abolished on 1.1.2023. Since then, the SBAP has been campaigning for good conditions with regard to the tariff structure and tax point value. The numerous service providers are individually accompanied in their questions and challenges.
The following answers are based on the current provisional legal situation. Official decisions may lead to new assessments.
To the frequently asked questions of the BAG: Link
Questions about orders, cooperation with psychiatrists
The number of sessions ordered applies regardless of how much time was needed, whether there were breaks, vacations, hospital stays, changes of year or other events in the meantime and whether the insurance or the psychotherapist was changed. As a rule, therapy for the same patient does not start from "zero" again.
This applies per case of illness. In our interpretation (BAG), this would be, for example, the treatment of a depressive episode that ends after a few weeks/months of therapy. If a new episode of the known illness or another mental illness were to be diagnosed by the treating doctor a few years later, then psychotherapy could be ordered again.
Most health insurance companies will inform you of the further procedure when they receive the cost approval. The PsyG only specifies the procedure up to the 30th session. How the health insurance companies proceed from the 30th session onwards is very individually tailored to the patient. If the health insurance company has not sent a specific procedure, you must ask them directly.
The Federal Office of Public Health (FOPH) writes on request: "The cost approval from the 'old' health insurance company is not binding for the new insurance company. The patient must apply again to the new insurer for approval of costs."
The patient has to do this and the psychiatrist or psychologist is often only consulted if necessary.
This is only an interruption and the therapy will obviously continue.
In this context, it also seems irrelevant whether the hospitalization is for an accident, a somatic ailment or for the psychotherapeutically treated illness (and whether psychotherapeutic treatment was possibly also provided in the hospital). Even after a change of year, a vacation of the patients or other circumstances, the therapy would not "start from scratch" again.
Before continuing beyond a total of 30 sessions (in this case 14 before hospitalization + 16 after hospital discharge), health insurance must approve the continuation.
A referral/order for psychotherapy made by name for a specific therapist could possibly be criticized by the patient's health insurance when reimbursing the services provided by another person and thus lead to problems. The ordering physician could issue a follow-up order. It makes sense for the ordering person to remain closely involved and informed, even if there is a change of therapist.
It is not always necessary to order 15 sessions. It is also possible to order fewer sessions, for example, 2-3 sessions at the beginning, then 10, then 8, and so on. Or start via short therapy with an order from a gynecologist etc., later the family doctor takes over the orders of 10+10 sessions.
In this respect, there can also be a third or fourth order. However, before continuing beyond 30 sessions, the approval of the health insurance company is required.
Answer: The order must have been obtained before the initial consultation. For the continuation of psychotherapy after 15 sessions, a second order from the ordering physician must be available. Likewise, for the continuation after 30 sessions, the cost approval of the basic insurer must be available. In summary: Without a valid order, no services may be provided!
Answer: After the 1st order, which is valid for 15 sessions (or for 10 sessions as crisis intervention or brief therapy), a 2nd order can be requested approximately after the 13th session with the same ordering doctor. If the psychotherapy has been carried out with an order for 10 sessions (this can be issued by any doctor with specialist training), a proper order must be obtained after this number of sessions (or shortly before). Here are the forms in D / F / It.
If, after approximately 26 sessions, it is determined that it would be appropriate to continue psychotherapy, another form must be used. You can either send it directly to the psychiatrist assessing the case, or you can send it to the ordering doctor: D / F / It. You have to fill in the first part of the form, the ordering doctor fills in the cover sheet. You can leave the second part of the form to the specialist.
The ordering physician then submits the request, together with the psychiatrist's case assessment, to the health insurance company. The health insurance company undertakes to inform the insured person within 15 working days of receipt of the report to the medical examiner whether and for how long the costs of psychotherapy will continue to be covered. A copy will be sent to the ordering physician.
Answer: Before psychotherapy can be continued after 30 sessions, the insurer must approve the costs. This is regulated in Article 11b paragraph 3 KLV.
This also applies to the continuation of psychotherapy that began as crisis intervention or brief therapy and continued with a regular arrangement. After a cumulative total of 30 sessions (10 sessions of brief therapy/crisis intervention + 20 sessions via regular arrangement), a cost approval from the insurer is required.
The report with the proposal for continuation must be drawn up by the ordering doctor. In the case of psychological psychotherapy prescribed by specialists in general internal medicine or pediatrics and adolescent medicine, this report must include the result of a case assessment by specialists with the advanced training titles of psychiatry and psychotherapy or child and adolescent psychiatry and psychotherapy.
Depending on the patient's individual vulnerability, this case assessment can also take the form of a file assessment.
No additional case assessment is required for psychotherapy prescribed by specialists in psychiatry and psychotherapy or in child and adolescent psychiatry and psychotherapy or with an interdisciplinary specialization in psychosomatic and psychosocial medicine SAPPM.
Since January 1, 2023, doctors with a degree in psychosomatic and psychosocial medicine have also been able to extend psychological psychotherapy beyond 30 sessions without having the case assessed by a psychiatric specialist.
Answer: On the doc24.ch platform, you can filter by canton and specialty. If you click directly into the profile of the specialist, you will see a note on the right side of the screen: "Orders/case assessments for psychological psychotherapy on at red light".
Answer: Actually not, but to be on the safe side, the SBAP recommends obtaining a brief confirmation of the authorization to prescribe in the medical professions register. Under the column "Further training" must be "General internal medicine" or "(Child and adolescent) psychiatry and psychotherapy" or "Child and adolescent medicine". This, for an ordering authority of 15 sessions. A possible additional qualification of the SAPPM can probably only be found on the website of the physicians concerned. This also authorizes the ordering of 15 sessions. All primary care physicians (including general practitioners) are authorized to order 10 sessions in emergency situations or crises.
Answer: It starts "all over again" for each patient from 1.7.22 onwards. There must be one order per patient. As a psychotherapist, it is up to you whether you start billing via OKP later in 2022. It is also possible to "drive in parallel": some patients are already in treatment via OKP, other patients are still in the delegation model. It is important to inform people that psychological psychotherapy is now an OKP service.
Answer: Yes, if the psychological psychotherapist and the psychiatrist, for example, share the same office, this is permitted. A good cooperation is definitely in the interest of the patients. In other words, the psychological psychotherapist may request a case evaluation after the 30th session.
Whether such a close cooperation is also accepted if the doctor is a partner in a joint-stock company and runs the organization of psychological psychotherapy is not entirely clear. It is important that no dependencies arise from an economic point of view.
Even if a general practitioner has made the order and the psychiatrist is in the same practice location as the psychological psychotherapist, he/she may also make the case assessment.
Answer: The rule is to divide by the number of persons present. There must be a valid order for each person. The divisor rule does not apply to family therapy.
Answer: If psychotherapy is to be continued after 30 sessions for services under paragraph 1 letter a, the procedure under Article 3b applies mutatis mutandis. The report with the proposal for continuation is made by the ordering physician. It shall contain a case assessment carried out by a specialist with a postgraduate qualification in psychiatry and psychotherapy or in child and adolescent psychiatry and psychotherapy.
Answer: Whether a patient has to be seen for the psychiatric case assessment or the (child) psychiatrist, based on the report that has to be prepared for the application for cost coverage (written by the treating psychotherapist), is decided by the person who carries out the case assessment, namely the psychiatrist. If the report does not provide sufficient information, further information can also be requested from the ordering physician.
Answer: No, the electronic patient dossier (ePD) has nothing to do with the introduction of the prescription model as of 1.7.22. However, since the commission motion 19.3955 was accepted, the ePD has also become mandatory for all service providers in the outpatient area.
Questions about billing, insurance, rates, etc.
The new regulation only affects OKP (i.e. basic insurance) in accordance with the Federal Health Insurance Act (KVG). It does not lead to changes in the competencies of psychotherapists or to adjustments to other legal bases.
For example, the following remain unchanged:
Most daily allowance insurers still require doctors to issue certificates of incapacity for work.
The PsyG (and not the legislation on health insurance) regulates the professional practice of the psychology professions under their own professional responsibility, professional duties, as well as training and further education.
Article 28 of the Unemployment Insurance Act (AVIG) stipulates that proof of incapacity for work must be provided in the form of a medical certificate.
The cantonal laws or regulations regarding school dispensations remain valid unchanged.
Assignment to care placement is also not related to health insurance. According to the Swiss Civil Code (ZGB), the adult protection authority is responsible for this. According to Article 429 CC, the cantons can designate doctors who, in addition to the adult protection authority, may order placement for a period of time specified by cantonal law.
In the introductory version of the PsyTariff, there is no option to charge for additional test consumables. However, costs for the purchase of test material have been taken into account in the cost model and are therefore covered by the tariff.
Nevertheless, I advise you to try the insurance companies. You can simply write down "test material 3.30" as an example. Many insurance companies will reimburse this.
Yes, from now on, billing via the supplementary insurance (VVG) is also possible with a ZSR number possible. This can be ordered at SASIS be requested by means of this form. Newly it can bebe selected whether via the ocompulsory health insurance (OKP) or is billed via the supplementary insurance (VVG). Both both together is still not possible. Due to the fact that the psychotherapy as of 01.07.22 defined as a primary benefit, supplementary insurances are probably will probably adjust their benefits catalog to the year 2024. We therefore recommend contacting the respective supplementary insurance and obtaining a cost approval.
The changes only affect OKP (i.e. basic insurance) under the Federal Health Insurance Act (KVG), but not supplementary insurance under the Insurance Contract Act (VVG).
These insurers are not regulated by the provisions of the KVG and the associated implementing ordinances (KVV, KLV) and are free to define their benefits.
An insured person can waive insurance benefits (Art. 23 ATSG). The waiver of benefits under the ATSG relates to the relationship between the insured person and the insurance company. For example, a person insured under the KVG has the option of expressly waiving reimbursement of benefits subject to the KVG vis-à-vis their health insurer. A waiver does not render tariff protection under the KVG meaningless, nor does it exclude the relevant service provider from working at the expense of the OKP.
In principle, it is also possible for supplementary insurance plans under the VVG to reimburse psychological psychotherapy services provided by service providers who are not KVG service providers (exclusion). It does not matter whether the service is provided with or without a doctor's referral or order. If a service provider wishes to provide services outside the KVG that are covered by the KVG, they can notify the body designated by the respective cantonal government that they wish to opt out and thus not act as a KVG service provider; in this case, they are not entitled to remuneration under the KVG; if insured persons contact such service providers, they must first inform them of this (Art. 44 para. 2 KVG). It should be noted here that a service provider cannot choose on a case-by-case basis whether or not they wish to work as a KVG service provider at the expense of the compulsory health insurance (OKP). As long as the service provider is active in the KVG service area (i.e. has not opted out) and fulfills the corresponding requirements, the mandatory benefits under the KVG must be billed according to the corresponding tariffs.
Psychological psychotherapists licensed as KVG service providers can also provide services that are not covered by the KVG (e.g. psychological support for everyday problems or difficult life circumstances that do not have the status of an illness). Such services can also be covered by supplementary insurance.
Yes, the consent to the IV contract also applies to military and accident insurance. If you would like to pay for these insurances, you must complete the consent form and send it to the secretariat at info@sbap.ch. This will be sent to the FSIO at the end of each month and is valid for the following month.
Answer: Tiers garants: the invoice data is sent in xml format to a data exchange platform (e.g. Medidata, Medidoc) via the service provider's software and the invoice is sent to the patient. The patient pays the invoice and reclaims a contribution (minus statutory cost sharing) from the insurer via a reclaim document.
Tiers payants: via the service provider's software, the invoice data is forwarded directly to the insurer in xml format. The insurers pay the invoice and claim the deductible from the insured person. Since 1.1.2022, the service provider is legally obliged to send the patient a copy of the invoice.
Answer: Yes, this must also be declared to the canton. A start date is also required on the application for a ZSR number.
Answer: Nothing changes for contract members (who have already joined the IV/UV/MV contract via SBAP); they can continue to charge the "rate of CHF 154.80/hour" to the UV/MV/IV insurers.
The billing of services provided by a psychotherapist in the hospital/clinic will continue to be carried out in accordance with TARMED (TARMED chapter 02.02) and is still possible until December 31, 2024.
Answer: Both basic insurers Assura and Atupri do not accept the tier payant model. In this case, the client pays the entire bill first and then claims the cost sharing from the health insurance company via a reclaim voucher.
Answer: First, consult the tariff browser and read the interpretation behind the position. The handbook in the members area will help as well. If you still have questions, please contact the SBAP Professional Policy Manager.
Answer: Two closely related persons are considered to be a family (even just one parent and one child, for example). In this case, only the index patient is billed. If the index patient does not participate, the session can be billed as coordination with third persons.
Answer: With the introduction of the prescription model, a psychological condition with disease value became a compulsory OKP benefit. This means that, according to the subsidiarity principle, the supplementary insurances are no longer the primary service providers. Therefore, in many cases, they refuse to cover the costs. Nevertheless, it is worthwhile to clarify in advance what applies in the individual case.
Note on SWICA: Under certain circumstances, SWICA will cover the costs of psychotherapy services provided by psychotherapists under the COMPLETA TOP and OPTIMA supplementary insurance plans. In order to be billed via the supplementary insurances, you must, among other things, be recognized as a SWICA psychotherapist. > Info page SWICA
Answer: In the implementation of the KVG amendment, the term "approval of service providers" is used: In principle, only services provided by approved service providers are reimbursed by the OKP. A hospital, an outpatient care facility or an organization of non-physician service providers may also bill the OKP if it employs specialists in further training - provided, however, that the majority of the specialists working there meet the admission requirements and ensure supervision of the activities of the person in further training. Therefore, if a service in the hospital, in an outpatient care facility or in an organization of non-physician service providers is provided by a person in continuing education, the hospital, the facility or the organization has supervisory duties as an approved service provider (supervision by a specialist who fulfills the OKP admission requirements) and must ensure that the services provided are effective, expedient and economical (WZW criteria). The hospital or the institution or organization approved as an OKP service provider is responsible for this and bills the OKP.
Answer: The tax point value of CHF 2.58 per minute has been approved in all cantons. Please keep a copy of your invoices in case of subsequent billing.
Questions about independent psychotherapy work, further training
The effects of the amendment to the SIWF for the recognition of training centers with regard to the regulation in Article 50c KVV concerning clinical experience are presented below.
As, according to the SIWF, this is an editorial adjustment to the categories of training centers, an activity at a training center that will only be recognized within the framework of a specialty (geriatric psychiatry and psychotherapy) from January 1, 2024 onwards will not be recognized. Since, according to the SIWF, this is an editorial adjustment to the categories of training institutions, an activity at a training institution which, from 1 January 2024, only has recognition in the context of a specialty(geriatric psychiatry and psychotherapy, consultation and liaison psychiatry, forensic psychiatry and psychotherapy, psychiatry and psychotherapy of addictive disorders; categories A or B), but no recognition as category C according to the adjusted training programme for psychiatry and psychotherapy, will continue to be recognized as an activity in accordance with Article 50c letter b number 1 KVV.
The FOPH is working on an editorial amendment to the KVV that reflects the changes in the SIWF recognitions of the training institutes and basically enables a seamless transition in the recognition of the clinical experience acquired there for admission to the OKP.
For those working in child and adolescent psychotherapy in the future, there will be no change to the applicable requirements under Article 50c letter b number 2 KVV, as no changes will be made to the "Specialist in child and adolescent psychiatry" training program with regard to the categories of training centres.
You can find the entire letter here.
Supplement from 25.06.2024
"We are pleased to inform you that, as of July 1, 2024, training centers that are recognized by the SIWF as training centers category A or B within the framework of a specialty (geriatric psychiatry and psychotherapy, consultation and liaison psychiatry, forensic psychiatry and psychotherapy, psychiatry and psychotherapy of addictive disorders) will also be included in Article 50c letter b number 1 KVV.
For admissions from 1 July 2024, psychological psychotherapists will therefore also be recognized as having worked in institutions with a focus category A or B as an admission requirement. In addition, reference is made to the revised further training program "Specialist in Psychiatry and Psychotherapy" in the new version of 1 January 2024."
You can find the explanation here.
This has also been added to the BAG website on the new psychotherapy regulations.
Answer: No, you can pay VAT voluntarily, but you don't have to. See here.
Answer: No, if you have more than three years of full-time equivalent clinical work experience, you will not be required to complete the third clinical year.
The transitional rule states that individuals who have not completed a third clinical year at the time of enactment must be able to demonstrate at least three years of professional practice experience (full-time equivalent) in psychotherapeutic-psychiatric care under assurance of professionally qualified supervision. This practical experience can take place independently in one's own professional responsibility or delegated (inpatient as well as outpatient).
Answer: The delegated psychotherapists are requested to find a solution with their delegating psychiatrists/supervisors regarding practice premises, etc. The insurance will no longer pay for services in the delegated system after a transitional period of six months. After a transitional period of six months, the insurance will no longer pay for the services in the delegated system.
Answer: The cantons are responsible for the approval. No, the approval will only be valid for one canton.
Answer: This number has to be applied for at SASIS AG after the authorization by the canton in which the psychological psychotherapy is offered. As an employee of an organization of psychological psychotherapy, a K number is applied for. The entire organization applies for its own ZSR number. Regarding the approval by the cantons, an important information: The cantons are different in the design of their approval processes, please inform yourself at the respective canton in which the psychotherapy practice is operated.
Answer: This can be seen in the PsyReg.
Answer: Yes, this makes sense, because a valid professional license must be available in order for the cantons to review the requirements for licensing. The cantons are at different stages of the licensing process (in the canton of SO, applications can already be submitted; in the canton of ZH, the deadline is not until the beginning of March 2023).
Answer: Yes, it is necessary to purchase software that has an xml interface. This is required for the transmission of electronic invoices to a TrustCenter or to external service providers such as MediPort (data exchange platform). The Ärztekasse still offers a service where service sheets filled out by hand are entered electronically - but you pay accordingly for this.
Answer: There is a possibility for previously insured persons to apply for continued coverage. Depending on the insurance, this applies for the first 30-90 days after termination. Check with your employer's current daily sickness benefits insurance for your options. In some cases, acceptance into an individual insurance plan is possible without a health check.
Answer: Effectively, applications for OKP approval can also be submitted after July 1, 2022. This will also be possible via transitional provisions (however, the deadline by which the conditions had to be met is 1.7.22). Please check with the canton in which your practice is located. For the cantons of AG, SO and ZH, the facts described above apply.
The following table shows the basic innovations:
Previous situation | Situation as of 01.07.22 | |
---|---|---|
Arrangement | - | Any doctor from primary care and psychiatric and psychosomatic care, may make an order. This is valid for 15 sessions. |
Cost absorption | Only those with supplementary insurance can claim part of the costs. Those who cannot make use of a delegated therapy place must bear the costs themselves. | Basic insurance covers the costs of psychotherapy minus the statutory cost sharing (deductible and retention). |
Crisis / brief intervention | - | Individuals from all medical specialties can make an order for 10 sessions. |
Prerequisite for psychotherapists | - | Practice permit of the canton must be available. The title "federally recognized psychotherapist" must be available. Proof of 300 percent of clinical experience. Licensing examination by the canton has taken place (see "Next steps"). The third clinical year applies to persons who start their further training in psychotherapy on 01.07.22 or who are currently in further training to become a psychotherapist. Also, individuals who do not have three years of full-time equivalent clinical work experience by 07/01/22 (for the third clinical year). |
Kostengutsprache | - | When the 15 sessions have elapsed, the same doctor can write a new order for another 15 sessions. After that, a cost approval from the health insurance company is necessary. This must be requested by the ordering person. A case assessment by a specialist with a further training title in psychiatry and psychotherapy or child and adolescent psychiatry and psychotherapy is required. Depending on the individual vulnerability of the patient, the assessment can also be done on a file basis. |
The transitional regulation states that persons who have not completed a third clinical year at the time of the effective date must be able to demonstrate at least three years of professional practice experience (in full-time equivalent) in psychotherapeutic-psychiatric care under assurance of professionally qualified supervision. This can therefore take place independently in their own professional responsibility or delegated, inpatient as well as outpatient.
Those who do not have three years of clinical experience by the time the prescriptive model goes into effect (7/1/2022) must complete at least 12 months in a psychotherapeutic-psychiatric facility that is accredited by the Swiss Institute for Continuing Medical Education and Training (SIWF) Category A, B, or C Adult Psychiatry or Category A, B, or C Child Psychiatry. The addition of C adult psychiatry clinics went into effect on 1/1/2013.
As OKP service providers, you are now also subject to performance audits.
To avoid repayments, it is important to refrain from making common mistakes. These are:
- Services are provided by persons who do not meet the OKP admission criteria. Before persons are employed in an organization of psychological psychotherapy, it is necessary to check the admission criteria.
- Incorrect application of the tariff system: individual tariff items are used incorrectly or inadmissible combinations are used. Anything "incorrectly billed" can be reclaimed from the health insurers.
- procedure for the assumption of costs must be followed without fail. If a medical order is exhausted, nothing will be financed by the health insurance companies. A new order or cost approval must be obtained in good time. Timely means: after the first 13 sessions, an exchange must take place with the ordering physician (can also be verbal). After approx. 26 sessions, a report must be submitted for approval of costs. This is done via the ordering physician, who sends the report for case evaluation by a psychiatrist.
When treating clients who typically have higher costs due to their mental illness, it is important to ensure that the services are well documented. This meticulous documentation can also be ensured in a very user-friendly way via software.
Background information and media releases
- Patient perspective article from SBAP professional policy director is here.
- Article in the Republic from 22.3.21
- Commentary of 22.3.21 in the NZZ.
- Media release, 3/19/21, jointly issued by FSP, ASP and SBAP.
- Article from the voting Friday (19.3.21) in the NZZ
- Article from the voting Friday (19.3.21) in the Tages-Anzeiger
- Historical review of political developments in non-physician psychotherapy from 1981 onwards. Supplement to the article "lettre (très) ouverte" in punktum of the January 2021 issue on the topic of "frustration", Jan. 4, 2021.
- Background information on the expected entry into force of the order model as of 1.1.2023, 14.12.2020
- Media release on the interview with pediatrician Mr. Charles Etterlin, 22.09.2020
- Media release on the state of affairs in the arrangement model, 4.08.2020
- SBAP statement on new regulations for psychological psychotherapy 7.10.2019
- Media release on the submission of the statement, 10.10.2019
- To the consultation documents
- Media release on the opening of the consultation, 26.06.2019
- Summary from the process to achieve the requirement from SBAP, with an explanation of the ordinance change and the consultation process.
- Argumentation: why is system change needed? June 2019
- SBAP article Fulfilling the right to treatment in a timely manner, colon.ch, 04/24/2019.
- Media release Petition handed over: 94,000 demand barrier-free access to psychotherapy, 11.03.2019
- SBAP article Psychotherapy - Recognize profession and remove barriers to entry, FH News, 11/30/2018.
- Media release Psychotherapists demand an end to discrimination against them, 16.11.2018
Next steps:
- The curriculum on the three-year clinical experience (one curriculum for the adult sector and a separate curriculum for the child and adolescent sector) is currently being developed. Planned duration: January 2022 - 2025.
- Currently (2023), data on tariff 581 (=Psy tariff) is being collected in order to have a basis for further collective bargaining.
- The collective agreement with IV was terminated at the end of June 23. Current negotiations are now underway.
The SBAP will provide information on changes via newsletter and website.
Useful documents
- Order psychological psychotherapy.
- Application form for case evaluation after 30 sessions.
- Fact sheet with relevant information (17.06.22).
- The KVV regulation can be found here.
- The annotated ordinance of the KVV and KLV can be found here.
- Patient Information Sheet Order Psychological Psychotherapy
Specialist Group Psychotherapy SBAP
The SBAP Psychotherapy Expert Group deals with topics related to the prescription model and other psychotherapeutic issues. If you, as a member of SBAP, are interested in participating in this group, please contact the office at info@sbap.ch.