Guide to Mental Health Counselling Services

The Guide to Mental Health Counselling Services has been developed jointly by the Non-Insured Health Benefits (NIHB) Program and the Indian Residential Schools Resolution Health Support Program (IRS RHSP). The purpose of this Guide is to outline the general and program-specific terms and conditions, criteria, guidelines and policies under which the NIHB Program's Mental Health Counselling benefit and the Individual and Family Counselling component of the IRS RHSP operate.

This Guide will be updated based on ongoing stakeholder and provider engagement and input.

In the guide you will find information regarding:

  • Provider enrolment process;
  • Client eligibility;
  • Benefit coverage;
  • Prior approval process;
  • Claim submission; and
  • Procedure for appeals.

Non-Insured Health Benefit (NIHB) Program
And
Indian Residential Schools Resolution Health Support Program (IRS RHSP)
Guide to Mental Health Counselling Services

(January 2015)

Table of Contents

1.0 Introduction

1.1 Purpose of the Guide

This Guide has been jointly developed by the Non-Insured Health Benefits (NIHB) Program and the Indian Residential Schools Resolution Health Support Program (IRS RHSP). The purpose of this Guide is to outline the general and program-specific terms and conditions, criteria, guidelines and policies under which the NIHB Program's Mental Health Counselling (MHC) Benefit and the Individual and Family Counselling component of IRS RHSP operate.

While NIHB and IRS RHSP use the same provider enrolment process, it is important to note that the Programs differ from each other in regards to benefit delivery. This guide provides information about the Programs' common requirements for mental health counselling provider enrolment and an overview of the NIHB Program and IRS RHSP in regards to:

  • Client eligibility;
  • Client responsibilities;
  • Benefit coverage;
  • Prior approval process;
  • Claims submission process; and
  • Procedure for appeal process.

In the event that this Guide does not address questions regarding general policies, processing of payment requests, or specific conditions, the provider should contact the Health Canada regional office.

Please note: This Guide does not apply to MHC benefits in North West Territories and Nunavut.

1.2 Overview of Counselling Covered by NIHB and IRS RHSP

The NIHB Program and IRS RHSP operate as part of a continuum of mental wellness programs provided by the First Nations and Inuit Health Branch (FNIHB) which are linked to mental wellness services that are provided by communities, and Provinces and Territories. An overview of other FNIHB mental health programming can be found in section 7.2 of this Guide.

Note that NIHB and IRS RHSP have some differences with respect to policies and requirements. A flowchart to help providers understand how to access NIHB and IRS RHSP can be found in Appendix 1 of this Guide.

NIHB Mental Health Counselling (MHC) Benefit

The NIHB Program's MHC benefit is intended to provide coverage for mental health counselling to address crisis situations when no other mental health services are available and/or being provided. This benefit is intended to support the provision of immediate psychological and emotional care to individuals in significant distress to stabilize their condition, minimize potential trauma from an acute life event, and, as appropriate, transition them to other mental health supports.

IRS RHSP Individual and Family Counselling

IRS RHSP provides eligible former Indian Residential Schools students and their families with access to mental health support services so they may safely address the broad spectrum of mental wellness issues related to the impacts of Indian Residential Schools. IRS RHSP fulfills commitments made in the 2007 IRS Settlement Agreement.

2.0 Mental Health Counselling Provider Enrolment

Enrolment of mental health counselling providers for NIHB and IRS RHSP is managed by the NIHB Program. All mental health counselling providers wishing to serve clients for reimbursement by either of these two Programs must first enroll with the NIHB Program. Providers will be enrolled only if they meet the eligibility requirements.

2.1 Mental Health Counselling Provider Eligibility

To be enrolled, mental health counselling providers must be registered with a legislated professional regulatory body and eligible for independent practice in the province/territory in which the service is being provided. Eligible mental health providers include:

  • Psychologists and Social Workers, with clinical counselling orientation; or
  • Mental health counsellors with education and training comparable to psychologists or social workers.

In exceptional circumstances, other mental health counselling providers who do not meet these requirements may be accepted subject to the following conditions:

  • There are no other mental health counselling providers enrolled with the NIHB Program in the vicinity and access to services is limited; or
  • Where there is an emergency situation such that the health and safety of the client or other persons is at immediate risk.

2.2 Mental Health Counselling Provider Enrolment Process

Enrolment Process

Mental health counselling providers wishing to deliver services reimbursed by NIHB and/or IRS RHSP must complete and submit a Mental Health Counsellor Provider Agreement form to the Health Canada regional office in the Province/Territory where they practice. A complete list of documents required for enrolment is included in the Form.

Please note: Mental health counselling providers are requested to disclose any work that they do with other mental health programs or community organizations providing services to First Nations and/or Inuit.

Upon receipt of the Mental Health Counsellor Provider Agreement form, Health Canada will review the application for approval of eligibility.

A copy of the Mental Health Counsellor Provider Agreement form may be downloaded from the NIHB website. Providers who do not have internet access may contact the Health Canada regional office to request a copy by fax or mail.

Changes in Provider Information

In order to avoid delays in payment requests, and ensure delivery of communication updates via e-mail, fax, or mail, mental health counselling providers should notify their Health Canada regional office of any changes to the information provided in the Mental Health Counsellor Provider Agreement or enrolment process.

Termination of Enrolment

The mental health counselling provider's enrolment may be terminated at any time by either Health Canada or the provider without cause upon providing the other party with 45 days written notice. If providers wish to terminate their enrolment, they must send written notice by fax or registered mail to their Health Canada regional office.

Enrolment will be terminated immediately if there are concerns that the provider has submitted fraudulent claims or engaged in professional misconduct or incompetent practice. In such cases, Health Canada may notify the appropriate police authority and/or professional regulatory body.

Health Canada will not process payment requests from the provider dated after the enrolment termination date.

Termination of provider enrolment does not terminate any rights or obligations of the provider or Health Canada regarding provider audit activities.

Documentation Updates

Mental health counselling providers must adhere to all Program requirements as defined in this Guide.

Health Canada will communicate any updates to this Guide, or related policies and benefits, to clients, providers and stakeholders in a timely manner. It is important that providers retain the most current documentation to ensure that NIHB and/or IRS RHSP requirements are met.

2.3 Provider Roles and Responsibilities

Before initiating counselling, mental health counselling providers must confirm that any services they propose are eligible for coverage by the Programs as defined in this Guide, otherwise they will not be reimbursed. The submission of a payment request by a provider indicates understanding and acceptance of the terms and conditions for receiving payment for services through either the NIHB Program or IRS RHSP.

Mental health counselling providers must:

  • Obtain prior approval before initiating counselling;
  • Confirm that the client is eligible for benefit coverage under NIHB or IRS RHSP;
  • Ensure that the client understands the terms, conditions, and limitations of the applicable Program prior to starting counselling;
  • Complete a client assessment and discuss the recommended counselling and sessions schedule with the client;
  • Complete a treatment plan to be kept on the client's file. As part of the treatment plan, develop an aftercare plan that links the individual to community based mental health services or culturally appropriate services during and/or after the counselling;
  • Keep records of appointments for each client (including date, time and duration) and client confirmation of attendance for audit purposes;
  • Ensure that they do not knowingly submit a claim for payment through NIHB or IRS RHSP for the provision of mental health services that has or will be billed to another plan/program;
  • Cooperate with all Health Canada audit activities based on generally accepted industry standards, and grant access to location and documentation required to determine compliance with the Programs policies outlined in this Guide;
  • Comply with professional regulatory body requirements for security, police record checks, and client files management; and
  • Not represent himself/herself as an agent or representative of Health Canada in respect of any counselling services provided to Health Canada clients.

As part of their ongoing professional development, providers are encouraged to continue to enhance their knowledge of First Nations and Inuit cultures in order to better serve clients. This can include opportunities provided by their professional associations, through First Nations or Inuit communities or organizations, or other related training.

Utilization of Telehealth in Mental Health Counselling

NIHB and IRS RHSP have developed guidelines and procedures for a limited provision of mental health services through telehealth (i.e. the use of information and communications technology, such as video-conferencing or telephone, to deliver mental health services).

When telehealth is considered to deliver mental health counselling, the client must agree to its use and retains the option of face-to-face counselling at any time.

Mental Health Counselling Providers must:

  • Meet the standards and code of ethics of their respective legislated regulatory bodies and Provincial/Territorial regulations in the provision of mental health services through telehealth, including client privacy and confidentiality.
  • Follow the Model Standards for Telepsychology Service Delivery adopted by the Association of Canadian Psychology Regulatory Organizations in provinces or territories where a provider’s regulatory body does not have guidelines for the provision of telehealth;
  • Ensure their ongoing competence with service delivery technologies for mental health, and to mitigate any potential negative impacts of the technologies on clients.
  • Determine the suitability of telehealth services for delivering mental health services to a client. This determination should be based on the provider's professional judgment that takes into consideration such factors as client safety and the accomplishment of therapeutic goals.

Process:

  • Initial client assessments should be undertaken in-person. In exceptional circumstances, assessment via telehealth may be allowable with the approval of Health Canada's regional office.
  • The technology (i.e. video conferencing or telephone) and location (e.g. nursing station, community health center, or other) used to provide counselling services will be determined by the provider based on the client's case and in accordance with the provider's regulation related to the delivery of telehealth services.
  • The provider must have a process in place to confirm the client's attendance through telephone log, attendance sheet, and/ or email confirmation, depending on the modality.
  • Providers will not receive additional compensation for any costs associated with the utilization of telehealth.

Please note: Mental health counselling providers are expected to follow applicable privacy legislation, regulations and professional regulatory body requirements applicable to maintaining their records. Client files are in the control of the provider and not the Government of Canada. In the case of an audit, providers will grant Health Canada access to these files for audit purposes, in a manner that is permissible under the applicable legislation, regulations and the requirements of their regulatory body.

See the terms and conditions as outlined in the Mental Health Counsellor Provider Agreement form.

2.4 Provider Audits

Audit Objectives

The objective of a provider audit is to confirm that payment requests have been submitted in compliance with the applicable Terms and Conditions of the Programs by:

  • Detecting any billing irregularities and recovering payment for ineligible claims;
  • Ensuring appropriate billing as defined by the Health Canada regional office;
  • Ensuring that the services paid for were received by an eligible client;
  • Validating active licensure of providers; and
  • Ensuring compliance with the Programs policies (e.g. completed assessments and treatment plans included in client files).

Health Canada may withhold future payments to providers, pending receipt of monies found to have been paid in error. Providers may contact the Health Canada regional office to clarify the payment error reversal.

If a practice related issue arises during an audit, Health Canada may refer the matter to the appropriate regulatory body.

Provider Responsibilities

The provider shall cooperate with Health Canada in all audit activities based on generally accepted industry practices. Upon request, the provider shall grant access to its location during regular business hours to inspect, review and produce a client's record maintained by the provider.

Please note that when an audit is conducted due to billing irregularities, the provider will not be allowed to continue to provide counselling and submit claim forms until the situation has been resolved. A provider suspended by his or her regulatory body will also not be allowed to provide services and submit claims.

Provider Audit Component

To carry out Claim Form verification and on-site audit components of the Programs, Health Canada requires access to information, including, but not limited to the following:

  • Client identification information;
  • Invoices;
  • First payer statement of benefits if client has additional coverage; and
  • Appointment schedule.

2.5 Privacy

The personal information provided to Health Canada is governed in accordance with the Privacy Act. Health Canada only collects the information needed to administer the mental health counselling services authorized under the NIHB or IRS RHS Programs.

Health Canada requires the provider's personal information to process provider enrolment. In limited and specific situations, the provider's personal information may be disclosed without consent in accordance with subsection 8(2) of the Privacy Act.

In addition to protecting personal information, the Privacy Act gives a person the right to request access to and correction of this personal information. For more information about these rights, or about Health Canada's privacy practices, please contact Health Canada's Privacy Coordinator at 613-954-9165 or by email at privacy-vie.privee@hc-sc.gc.ca. A person also has the right to file a complaint with the Privacy Commissioner of Canada if he or she thinks that his or her personal information has been handled improperly.

3.0 Non-Insured Health Benefits Program

The NIHB Program is a national program that provides coverage to eligible registered First Nations and recognized Inuit for a specified range of medically necessary health related goods and services to which these individuals are not entitled through other plans and programs (provincial/territorial health or social programs, or other publicly and privately funded programs).

The benefits provided under the NIHB Program include: Mental Health Counselling, Pharmacy, Dental Care, Medical Supplies and Equipment, Vision Care, and assistance with Medical Transportation to access medical services not available on-reserve or in the community of residence.

General Principles

To support First Nations and Inuit in reaching an overall health status that is comparable with other Canadians, the NIHB Program covers benefits based on the following principles:

  • Benefits will be provided based on the judgment of medical professionals, consistent with the best practices of health services delivery and evidence-based standards of care;
  • National consistency of benefits, equitable access and portability of benefits and services;
  • Payment and reimbursement for mental health services provided to clients will be made in accordance with Program policies, and consistent with the payment and reimbursement process defined in this Guide;
  • The Program will be managed in a sustainable and cost-effective manner;
  • In cases where a benefit is covered under another health care plan, the NIHB Program may act to coordinate payment in order to ensure that the other plan meets its obligations and that clients are not denied services; and

3.1 Mental Health Counselling

The NIHB Program's MHC benefit provides eligible clients with coverage for mental health counselling to address crisis situations when no other services or funding are available.

NIHB's mental health counselling benefit is intended to fund immediate psychological and emotional care to individuals in significant distress in order to stabilize their condition, minimize potential trauma from an acute life event and, as appropriate, transition them to other mental health supports. A crisis may include the following:

  • Distress manifested by symptoms of physical, cognitive, emotional or behavioral disturbance;
  • Inability to care for self and without individual, family, and/or community support and resources to deal with the issue; and/or
  • Nature of the circumstances requires the individual to resolve the issue urgently.

The mental health counselling benefit is one component supporting mental wellness, and this benefit is intended to address short term crisis management only. It is not a substitute for other forms of mental health services provided by Health Canada or other federal departments and levels of government. The provision of this benefit is part of FNIHB's commitment to work towards the development of a coordinated and comprehensive approach to mental health and addictions programming. MHC is offered in a way that:

  • Recognizes NIHB MHC benefit as a component of a mental wellness continuum that includes other FNIHB, community-based and provincial/territorial mental health programming and services; and
  • Supports culturally competent mental health counselling.

3.2 Client Eligibility

To be eligible for NIHB Program benefits, a client must be a Canadian resident and registered or be eligible to be registered under a provincial or territorial health insurance plan and have the following status:

  • Registered Indian according to the Indian Act; or
  • Inuk recognized by an Inuit Land Claim organizations; and
  • Not otherwise covered under a separate agreement (e.g. a self-government agreement such as the Nisga'a and Nunatsiavut agreements) with federal, provincial or territorial governments.

Roles and Responsibilities of Clients

Clients must access any alternate health coverage that is available to them prior to accessing the NIHB Program. They should also contact their local community organizations (health centre, friendship centre, or primary health care provider) and/or Health Canada regional office to determine if community mental health programs are available.

Only services delivered by a provider enrolled with NIHB are eligible for reimbursement. Clients can contact their respective Health Canada regional office to obtain a list of providers currently enrolled with NIHB.

Clients can make a complaint to the mental health counselling provider's regulatory body if they have concerns about the counselling received.

Clients wishing to appeal a benefit decision by the NIHB Program are required to follow the steps outlined in the appeal procedure section of this Guide. Clients can learn more about the NIHB Program by reading this Guide or by visiting the NIHB website.

Clients are responsible to keep their information up-to-date in order to avoid delays in accessing NIHB benefits. When name and any other personal information changes:

  • First Nations clients should contact their local Band Office or Aboriginal Affairs and Northern Development Canada (AANDC) Registration Services Unit at 1-800-567-9604 to update their status cards.
  • Inuit clients should contact their Land Claim Organization to update their personal information. Inuit living outside the Northwest Territories or Nunavut should contact NIHB_SVS-HICPS@hc-sc.gc.ca

3.3 Benefit Coverage

Benefit Coverage and Frequency Guidelines

The MHC benefit provide up to a maximum of 15 one-hour sessions (with up to five additional one hour sessions, see exceptions) per mental health crisis over a 20 week period, not including the initial assessment.

Eligible services under the MHC benefit include:

  • Initial assessment (maximum of 2 one hour sessions) performed by an enrolled provider; and
  • Counselling sessions on a fee-for-service basis as per Prior Approval Form (e.g. individual, family, or group counselling).

Please note that with the exception of the initial assessment, all services and modalities for the delivery of services must be prior-approved by the Health Canada regional office.

Services submitted for coverage must not already be eligible for coverage by another provincial/territorial, federal, and/or private plan or program.

Exceptions and Criteria for Approval

In addition to the initial 15 sessions, five sessions may be covered in order to support a client's transition to other type of mental health services. A Prior Approval Form must be submitted to the Health Canada regional office to request an extension.

Exclusions

Exclusions are not benefits and are not covered under any circumstances; nor are they subject to the appeal process. Exclusions include, but are not limited to:

  • Psychiatric emergencies for person(s) at risk of harm to self or others;
  • Non-crisis counselling;
  • Services funded by another program or agency including Health Canada’s IRS RHSP;
  • Psychiatric and family physician services;
  • Psychoanalysis;
  • Psychoeducational assessments;
  • Educational and vocational counselling;
  • Substance abuse counselling/therapy;
  • Life skills training;
  • Early intervention programs for infants with delayed development;
  • Assessment services for issues such as fetal alcohol spectrum disorder, learning disabilities and child custody;
  • Expressive arts therapy;
  • Hypnotherapy;
  • Court-ordered assessment services to clients;
  • Services which are part of, or to be used for, legal actions;
  • Sex therapy; and
  • Incarcerated clients.

3.4 Prior Approval Process

Following the initial assessment, mental health counselling providers must obtain prior approval from the Health Canada regional office in the province/territory in which the service is being provided. The Prior Approval Form is available on the Health Canada website. Prior approval will be given when the following conditions have been met:

  • The client is eligible for coverage;
  • The mental health counselling provider is enrolled with the NIHB Program; and
  • The requested service is an NIHB benefit (e.g. is crisis counselling) and falls within the frequency limits.

The following information is required to process a prior approval request:

  • Client identification information, as described in the Section 3.5 Claim Submission; [add link to section 3.5]
  • Start and end date of the counselling;
  • Proposed counselling session schedule;
  • Number of sessions requested (up to a maximum of 15 one hour sessions) and the cost of the counselling proposed;
  • Confirmation that the services proposed meet the definition of crisis counselling as defined in this Guide and that the crisis can be addressed within the number of sessions requested;
  • Confirmation of any previous counselling provided to the client by provider;
  • Confirmation that an aftercare strategy was developed to link the individual to community based mental health services or other local and culturally appropriate services during and/or after the counselling, when appropriate;
  • Confirmation that alternate health coverage has been sought when applicable; and
  • The Prior Approval Form signed by the client/guardian and the provider (and supervisor when applicable) is provided. Stamped copies of signatures are not acceptable.

Please note: If prior approval is granted, a prior approval number will be provided by the Health Canada regional office and this number must be included on all claims submissions. Only then should the provider proceed with the provision of service to the client. Counselling should start within two weeks following the prior approval, unless otherwise approved by the Health Canada regional office.

Client Identification

To facilitate reimbursement, in addition to the Prior Approval Number, the following information must be provided for each payment request:

  • Surname (under which the client is registered);
  • Given names (under which the client is registered);
  • Date of birth (date format YYYY-MM-DD); and
  • Client Identification number.

Identification Numbers for Registered First Nations

One of the following identifiers is required for registered First Nations clients:

  • Aboriginal Affairs and Northern Development Canada Certificate of Indian Status Number;
  • Band Number and Family Number; or
  • First Nations and Inuit Health Branch Client Identification Number (B number).

Identification Numbers for Recognized Inuit

One of the following identifiers is required for recognized Inuit clients:

  • Government of Northwest Territories (NWT) Health Plan Number;
  • Government of Nunavut (NU) Health Plan Number;
  • First Nations and Inuit Health Branch Identification Number; or
  • NWT/NU Health Canada Card or letter (Health Canada letterhead) identifying the individual and accompanied by picture identification.

In cases where there is a discrepancy between the information/documents used to verify a client's eligibility for the NIHB Program and the name presented by the client, the mental health counselling provider is asked to request, in addition to the status card or Inuit eligibility documents, another recognized form of provincial or federal photo identification (providers should keep a record that this was done).

3.5 Claim Submission

Coordination of Benefits

Clients are required to access any public (federal, provincial, or territorial) or private health care funding for which they are eligible prior to accessing the NIHB Program. If the client has other coverage, the provider must submit claims to the other payer first before submitting to NIHB.

Where a client has other coverage, an Explanation of Benefits or other written confirmation from the other carrier will be required before an NIHB claim can be processed. In the case where another carrier is unable to provide this, NIHB may coordinate payment in order to ensure that the other plan meets its obligations and that those clients are not denied services.

Mental Health Counselling Provider Reimbursement

Please note that Health Canada regional offices will reimburse providers when the following criteria are met:

  • Claim has been submitted to any alternate health plans (public or private) to which a client is eligible prior to being submitted to the NIHB Program;
  • Claim has not been submitted for any amount or for work which has already been covered by any other federal or provincial program, for which the provider has received alternate payment via salary or contract;
  • Prior approval has been obtained (providers will not be reimbursed for services that have not received prior approval);
  • Fees charged are in accordance with the ones approved in the Prior Approval Form. Under no circumstances are individual counselling fees to be charged when a client has received counselling as part of group, or family counselling;
  • The Health Canada Mental Health Counselling Appointment Confirmation Sheet is signed by the client or parent/legal guardian and/or in the case of telehealth, other appropriate confirmation (e.g. telephone log, client signature obtained at a nursing centre at the time of the call) as confirmation that the client has received the service; and
  • A signed copy of the Health Canada Mental Health Counselling Claim Form has been submitted to the Health Canada regional office;
  • Please note there will be no reimbursement for missed appointments and Health Canada may withhold payment if attendance cannot be confirmed.

To avoid a delay in payment, providers should submit all Claim Forms for payment within 2 months of the provision of services. Claim Forms submitted more than one (1) year from the service provision date will not be accepted and will be returned to the provider.

Client Reimbursement

Mental health counselling providers are encouraged to submit invoices directly to the NIHB Program so that clients do not face charges at the point of service.

Requests for direct client reimbursement for MHC benefits must be submitted to the Health Canada regional office in the province or territory where the service was provided within one year of the date of service.

The service must be an eligible benefit under the NIHB Program, and the client must demonstrate that they meet all the Program's eligibility criteria, including that the service was provided by a provider enrolled with the Program (see section 2.2).

All requests for reimbursement of eligible benefits must include a completed NIHB Client Reimbursement Form and original receipts. The NIHB Client Reimbursement Request Form is located on the Health Canada website.

4.0 Indian Residential Schools - Resolution Health Support Program

The IRS RHSP is administered by the Health Canada's First Nations and Inuit Health Branch (FNIHB) regional offices or designated health authority in order to provide health support services to former IRS students and their families ("clients") to safely address a broad spectrum of wellness issues related to the impacts of Indian Residential Schools (IRS).

The IRS RHSP objectives are to:

  • Provide mental health, emotional and cultural supports during all stages of the IRS Settlement Agreement process; and
  • Provide emotional and cultural support services to those in attendance at Truth and Reconciliation Commission ("TRC") events or Settlement Agreement commemoration events.

Guiding Principles

The IRS RHSP operates according to a number of guiding principles:

  • There is national consistency in available services and equitable access to services across Canada;
  • All services are provided in a non-judgmental, sensitive and compassionate manner that meets the needs of clients;
  • The IRS RHSP is managed in a sustainable and cost-effective manner; and
  • Administrative processes involve transparency and stakeholder input whenever agreed to with First Nations and Inuit organizations.

4.1 IRS RHSP Individual and Family Counselling

The provision of mental health counselling is described in this section relates to only one component of IRS RHSP, namely mental health professionals providing counselling services to assist clients to find ways of healing from IRS experiences. These services are offered individually or in family sessions as required by needs of the eligible clients for the duration of the Settlement Agreement process.

4.2 Client Eligibility

A client is eligible for IRS RHSP mental health support services if they meet one of the following criteria:

  • Former IRS Student:  A former IRS student regardless of the individual's status (First Nations, Inuit, Métis, non-status, non-Aboriginal) or place of residence within Canada (on or off-reserve) who have received the Common Experience Payments (CEP) or who are resolving their claim against Canada through the Independent Assessment Process (IAP), or are participating in Truth and Reconciliation Commission (TRC) or commemoration events;
  • Family Members: The family of former IRS students is defined as spouse/partner, those raised by or raised in the household of a former IRS student and any relations who have experienced effects of intergenerational trauma associated with an eligible family member's time at an IRS;
  • TRC Event Participants (National and Community Events): Anyone who is in attendance at a TRC event is eligible to access IRS RHSP services during the event; and
  • Commemoration Event Participants: Anyone in attendance at an IRS Settlement Agreement funded Commemoration event is eligible to access RHSP services during the event.

Please note that individuals who are ineligible to receive IRS RHSP counselling services include those who:

  • Attended a school that is not recognized in the 2007 IRS Settlement Agreement, such as former IRS day school students; and/or
  • Have opted out of the IRS Settlement Agreement.

4.3 Benefit Coverage

To access IRS RHSP counselling services, the client or their representative must contact the Health Canada regional office or designated health authority office in their territory or province to confirm client eligibility. Every new client must be verified for eligibility before receiving IRS RHSP services.

All counselling services must be provided by an enrolled NIHB/IRS RHSP mental health counselling provider and receive prior approval by the Health Canada regional office or designated health authority before counselling is initiated.

Up to 20 one-hour sessions in a Prior Approval Form may be covered, not including the initial assessment. Sessions approved must be used within a 12 month period. Eligible counselling services under the IRS RHSP include:

  • Initial assessment (maximum of 2 one hour sessions) performed by an enrolled provider; and
  • Prior Approval Form (e.g. individual or family counselling) Group counselling if included in a Mental Health Counselling Prior Approval Form and only billed at a pre-approved rate and not an individual rate.

Clients may make a complaint to the mental health counselling provider's regulatory body if they have concerns about the counselling received.

Exceptions and Criteria for Approval

Certain types of counselling services are funded on an exception basis and may be considered for coverage by IRS RHSP. These include, but are not limited to:

  • Extension to the number of sessions required to provide on-going support to clients:
    • Should the counsellor and the client identify the need for additional counselling sessions after the expiry of the initial or subsequent Prior Approval Form; a new Prior Approval Form can be submitted for approval.
  • Clients must access counselling services in their home province or territory, with the following exceptions:
    • Should the demand for counsellors go beyond regional capacity;
    • Should the service not be available in the home province; or
    • Should a neighbouring province/territory service provider be the closest.

All exceptions are reviewed on a case by case basis.

Exclusions

Certain types of counselling services will not be provided under IRS RHSP under any circumstances and are not subject to the appeal process.

Exclusions include, but are not limited to:

  • Psychiatric emergencies for person(s) at risk of harm to self or others;
  • Services funded by another program or agency;
  • Psychiatric and family physician services;
  • Psychoeducational assessments;
  • Educational and vocational counselling;
  • Early intervention programs for infants with delayed development;
  • Assessment services such as fetal alcohol spectrum disorder, learning disabilities and child custody which are unrelated to IRS RHSP;
  • Court-ordered assessment/therapy services to clients; and
  • Counselling services for children under the age of six, unless part of family therapy.

4.4 Prior Approval Process

Following the initial assessment, mental health counselling providers must obtain prior approval from the Health Canada regional office or designated health authority in the province/territory in which the counselling services are being provided. The Prior Approval Form is available on the Health Canada website. Prior approval will be given when the following conditions have been met:

  • The client is eligible for coverage;
  • The mental health counselling provider is enrolled with the NIHB Program; and
  • The requested service is an IRS RHSP benefit (e.g. individual or family counselling) and falls within the frequency limits.

The following information is required to process a prior approval request:

  • Client identification information;
  • Start and end date of counselling;
  • Number of sessions requested (up to 20) and the cost of counselling proposed;
  • The Mental Health Counselling Prior Approval Form signed by the client and the provider (and supervisor when applicable) is submitted. Stamped copies of signatures are not acceptable.

Prior approval requests will be assessed within two weeks of being submitted. The Regional office will advise the mental health counsellor of the approval or denial of the funding for counselling. Counselling should start within two weeks following the prior approval, unless otherwise approved by the Health Canada regional office.

4.5 Claim Submission

Provider Reimbursement

Please note that Health Canada regional offices will reimburse providers only when the following criteria are met:

  • Prior approval has been obtained;
  • Fees charged are in accordance with the ones approved in the Prior Approval Form. Under no circumstances are individual counselling fees to be charged when a client has received counselling as part of group or family counselling;
  • Mental health providers submit a signed copy of the Health Canada Mental Health Counselling Claim Form to the Health Canada regional office or designated health authority;
  • A Mental Health Counselling Appointment Confirmation Sheet signed by the client or parent/legal guardian and/or in the case of telehealth, other appropriate confirmation (e.g. telephone log, client signature obtained at a nursing centre at the time of the call) as confirmation that the client has received the service along with the Mental Health Counselling Claim Form is sent to the Health Canada regional office or designated FNHA in order to demonstrate that the client has received the mental health service. In cases of clients under the age of majority, a parent or legal guardian may sign the attendance form. Please note that Health Canada reserve the right to withhold payment if attendance cannot be confirmed; and
  • There will be no reimbursement for missed appointments.

To avoid delay in payment, Mental Health Counselling Claim Forms should be submitted every two months. Claim Forms submitted more than one year from the service provision date will not be accepted and will be returned to the provider.

5.0 Appeal Process

Eligible clients may initiate an appeal process when counselling services have been denied through the NIHB Program or IRS RHSP according to circumstances. A client may have someone act on their behalf to initiate an appeal process as long as written authorization is obtained from the person seeking coverage.

For a case to be reviewed as an appeal, a signed note or letter from the client (parent or legal guardian) accompanied by supporting information from the mental health counselling provider must be submitted to the NIHB Program or IRS RHSP according to circumstances. In many cases, the mental health counselling provider is required to provide part of the information being requested. The usual information required for the appeal process is

  • Reason for which the service is being requested;
  • Confirmation that client accessed other services for which he/she may be eligible (e.g. provincial/territorial services, community services, friendship centres, etc.); and
  • Any additional supporting information.

The letter of appeal and supporting documentation should be submitted by mail, with the indication "APPEAL-CONFIDENTIAL" clearly marked on the envelope. Services that are identified as exclusions in this Guide will not be considered for appeal.

Upon receiving the appeal submission, the case will be reviewed by a health professional for a decision by NIHB or IRS RHSP based on the specific needs of the client, the justification, the availability of alternatives, and the respective Program's policies.

The client or parent/legal guardian will receive a written explanation of the decision within 30 business days of Health Canada receiving the complete appeal documentation. The client, parent or legal guardian may also contact the Health Canada regional office for an update if he/she has not heard from the regional office within one month of submitting the appeal.

NIHB Program and IRS RHSP - Levels of Appeal

LEVEL 1
To initiate an appeal, the client should submit their documentation to the Health Canada regional office:

For NIHB
NIHB Regional Manager and mail it to the Health Canada regional office in the client's province or territory of residence.

For IRS RHSP
IRS RHSP Regional Manager and mail it to the Health Canada regional office or designated health authority in the client's province or territory of residence.

LEVEL 2
If the client does not agree with the Level 1 Appeal decision, the client may choose to have the appeal reviewed at the second level. The submission should be addressed for both Programs to:

FNIHB Regional Executive and mailed to the Health Canada regional office in the client's province or territory of residence.

LEVEL 3
If the client does not agree with the Level 2 Appeal decision, the client may choose to have the appeal reviewed at the third and final level. The submission should be addressed to:

For NIHB
NIHB Director General
First Nations and Inuit Health Branch - Health Canada
Non-Insured Health Benefits Directorate
200 Eglantine Driveway, Tunney's Pasture
Jeanne Mance Building, 9th Floor,
Postal Locator: 1909D
Ottawa, ON
K1A 0K9

For IRS RHSP
Executive Director, Office of Population and Public Health
First Nations and Inuit Health Branch - Health Canada
Population Health and Primary Care Directorate
200 Eglantine Driveway, Tunney's Pasture
Jeanne Mance Building, 20th Floor,
Postal Locator: 1920D
Ottawa, ON K1A 0K9

6.0 Medical Transportation Assistance

Medical transportation assistance may be provided for clients to the nearest appropriate mental health counselling provider. This assistance may include the provision of transportation, meals, and accommodations.

A maximum number of sessions should be arranged in order to minimize costs. All travel must be pre-approved by the respective Program and be in accordance with the NIHB Medical Transportation Policy Framework.

When required, medical transportation assistance may be covered for an escort to accompany the client to access mental health counselling services. Escort travel must be pre-authorized by Health Canada regional office or designated health authority according to the Medical Transportation Policy Framework policies for client escorts.

7.0 Mental Health Counselling Benefits Resources

7.1 Health Canada Regional Offices

NIHB Regional Offices

Atlantic Region (PEI, NS, NB, NL)
Non-Insured Health Benefits
Health Canada
1505 Barrington Street, Suite 1525
Halifax, NS, B3J 3Y6
Telephone (toll-free): 1-800-565-3294
Fax (toll-free): 1-866-963-7700

Quebec Region
Non-Insured Health Benefits
Health Canada
202-200 René-Lévesque Boulevard W, East Tower
Montreal, QC, H2Z 1X4
Telephone (toll-free): 1-877-483-1575
Fax (toll-free): 1-855-244-4470

Ontario Region
Non-Insured Health Benefits
Health Canada
2720 Riverside Drive, AL 6604D
Ottawa, ON, K1A 0K9
Telephone (toll-free): 1-800-881-3921
Fax (toll-free): 1-800-806-6662

Manitoba Region
Non-Insured Health Benefits
Health Canada
391 York Avenue, Suite 300
Winnipeg, MB, R3C 4W1
Telephone (toll-free): 1-800-665-8507
Fax: 204- 983-2160

Saskatchewan Region
Non-Insured Health Benefits
Health Canada
1st Floor, South Broad Plaza
2045 Broad Street
Regina, Saskatchewan S4P 3T7
Telephone (toll-free): 1-866-885-3933
Fax: 306-780-3878

Alberta Region
Non-Insured Health Benefits
Health Canada
9700 Jasper Avenue, Suite 730
Edmonton, AB, T5J 4C3
Telephone (toll-free): 1-800-232-7301
Fax: 780-420-1219

Northern Region (Yukon Office)
Non-Insured Health Benefits
Health Canada
300 Main Street, Suite 100
Whitehorse, YT, Y1A 2B5
Telephone (toll free) 1-866-362-6717
Fax: 867-667-3999

IRS RHSP Regional Offices

Atlantic Region (PEI, NS, NB, NL)
First Nations and Inuit Health Branch
Health Canada
1505 Barrington Street, Suite 1525
Halifax, NS, B3J 3Y6
Telephone (toll-free): 1-866-414-8111
Fax: 902-426-8675

Quebec Region
First Nations and Inuit Health Branch
Health Canada
2nd Floor-200 René-Lévesque Boulevard W, East Tower
Montreal, QC H2Z 1X4
Telephone (toll-free): 1-877-583-2965
Fax: 514-283-8067

Ontario Region
First Nations and Inuit Health Branch
Health Canada
2720 Riverside Drive, 4th Floor
Ottawa, ON, K1A 0K9
Telephone (toll-free): 1-888-301-6426
Fax: 1-877-430-3306

Manitoba Region
First Nations and Inuit Health Branch
Health Canada
391 York Avenue, Suite 300
Winnipeg, MB, R3C 4W1
Telephone (toll-free): 1-866-818-3505
Fax: 204-983-5740

Saskatchewan Region
First Nations and Inuit Health Branch
Health Canada
2045 Broad Street, 5th Floor
Regina, SK, S4P 3T7
Telephone (toll-free): 1-866-250-1529
Fax: 306-780-5965

Alberta Region
First Nations and Inuit Health Branch
Health Canada
9700 Jasper Avenue, Suite 730
Edmonton, AB, T5J 4C3
Telephone (toll-free): 1-888-495-6588
Fax: 780-495-3184

Northern Region (YT, NT, NU)
First Nations and Inuit Health Branch
Health Canada
300 Main Street, Suite 100
Whitehorse, YT, Y1A 2B5
Telephone (toll-free): 1-800-464-8106
Fax: 867-667-3999

First Nations Health Authority
Federal Building
757 West Hastings Street, Suite 540
Vancouver, BC, V6C 3E6
Toll Free: 1-877-477-0775

7.2 Mental Health Programming

Many municipalities or other local governments, and provincial or territorial governments offer mental health programming, for example through non-profit organizations such as the Canadian Mental Health Association or local Aboriginal friendship centres. Please find below a list of some long term mental health counselling or support programs offered to registered First Nations and eligible Inuit by Health Canada (HC) and Aboriginal Affairs and Northern Development Canada (AANDC). More information is available on the internet or at your regional Health Canada or AANDC office.

National Native Alcohol and Drug Abuse Program (HC)

The National Native Alcohol and Drug Abuse Program (NNADAP) seeks to help First Nations and Inuit communities set up and operate programs aimed at reducing high levels of alcohol, drug, and solvent abuse among on-reserve populations. NNADAP supports a national network of 52 residential treatment centres, with some 700 treatment beds.

National Aboriginal Youth Suicide Prevention Strategy (HC)

A key Health Canada priority is the development and implementation of a National Aboriginal Youth Suicide Prevention Strategy that aims to increase resiliency and protective factors, and reduce risk factors associated with Aboriginal youth suicide.

Building Healthy Communities (HC)

The Building Healthy Communities initiative is designed to assist First Nations and Inuit communities to develop community-based approaches to youth solvent abuse and mental health crises, the two components of the program. First Nations and Inuit communities have the flexibility to determine which program component(s) to provide community-based programs, services and/or activities in.

Brighter Futures (HC)

The Brighter Futures initiative is a community-based health promotion and prevention program for First Nations and Inuit communities. The program typically, promotes health and prevents ill-health through learning-related activities that strive to increase awareness, change attitudes, build knowledge and enhance skills.

Family Violence Prevention Program (AANDC)

The Family Violence Prevention Program (FVPP) provides funding to assist First Nations in providing access to family violence shelter services and prevention activities to women, children and families ordinarily resident on-reserve.

Appendix 1 - NIHB and IRS RHSP Flow Chart

Non-Insured Health Benefit Program Mental Health Counselling (NIHB MHC) and Indian Residential Schools Resolution Health Support Program (IRS RHSP) Flow Chart

Appendix 1 is composed of flow chart explaining the step-by-step process for a client to access mental health counselling services under the Non-Insured Health Benefit (NIHB) Program and the Indian Residential Schools Resolution Health Support Program (IRS RHSP). The flow chart is divided into 3 steps, which correspond to the three diamond shaped decision boxes going from top to bottom in the middle row:

  1. Confirm client eligibility to IRS RHSP;
  2. Determine eligibility to NIHB; and
  3. Confirm that the client is facing a crisis.

At the beginning of this process, the first box at the top states: the client requires mental health counselling. This will result in a need to consult an eligible provider. In order to do so, the client is presented with two choices:

  • Meet an enrolled NIHB mental health counsellor; or
  • Contact the Heath Canada regional offices for a list of mental health counsellor enrolled with NIHB.

Both choices will lead to the next step and first level of decision.

(1) Confirm client eligibility to IRS RHSP

Following client assessment, the enrolled provider will confirm if the client is eligible to access IRS RHSP counselling services. If the answer is YES, the provider will submit the prior approval to IRS RHSP. If the answer is NO, then the provider will move to the next decision level.

(2)Determine eligibility to NIHB

If the client was not eligible for IRS RHSP, the provider is now required to confirm if the client is eligible to receive mental health counselling services under the NIHB Program. There are two possible answers to this question:

  • If the answer is NO, the provider will refer the client to community based and/or provincial/territorial mental health counselling services.
  • If the answer is YES, the provider will then move to the fourth and final decision level.

(3) Confirm that the client is facing a crisis

In this final stage, the provider must determine, based on the guidelines defined in the joint NIHB/IRS RHSP Guide to Mental Health Counselling Services, if the client is experiencing a crisis. If the answer to this question is NO, the provider will refer the client to community based and/or provincial/territorial mental health counselling services.

If the answer to this question is YES, the client may access NIHB benefits and the provider will submit a prior approval to the NIHB Program.

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