Billing for Limited Permit Holders in New York

Last reviewed: October 8, 2026.

In New York, a supervisee with a limited permit (LCAT, LMHC, LMFT, or LCSW/LMSW permit) cannot be credentialed and bill as an independent provider. An LMSW providing psychotherapy is in the same position. Their sessions can only be billed under the licensed supervisor, through the PLLC or group that employs both of them, and only with payers that publish a supervised-billing route.

NY Medicaid publishes that route for LMHC, LMFT and LCSW supervisors. Aetna and Cigna publish conditional rules. Optum requires prior approval in New York. Nothing comparable is published for LCAT permit holders, so most of this article is about checking each payer before the first session.

Two separate questions: NYSED decides whether the supervisee may practice, where, and under whom. Each payer decides whether it will pay for that work and whose NPI goes on the claim. Meeting NYSED supervision rules does not by itself make a session billable.

What NYSED requires before a permit holder sees clients

A limited permit is for someone who has applied for licensure and met every requirement except the exam and/or the supervised experience. The rules below come from the Office of the Professions pages for each profession.

• The permit is tied to a site and a supervisor. For LCATs, permits are issued only for specific practice sites in New York, under a qualified supervisor the Department accepts, and the permit holder may not practice until the permit is issued. The LCAT permit is valid for two years and may be extended for up to two one-year periods. NYSED: LCAT limited permits.

• A PLLC or professional corporation can be the setting. The LCAT and mental health counselor supervised-experience pages list a professional corporation, registered limited liability partnership, or professional service limited liability company among the acceptable settings, along with a sole proprietorship owned by a licensee.

• Supervision has a minimum and a cap. The supervisor must provide at least one hour per week or four hours per month of in-person individual or group supervision, and no supervisor can supervise more than five limited permit holders. The supervisor is responsible for oversight of all services the permit holder provides. NYSED: LCAT supervised experience · NYSED: mental health counselor supervised experience.

• The supervisor must be qualified for that profession. An LCAT permit holder can be supervised by an LCAT, or by a physician, physician assistant, psychologist, LCSW, or registered nurse or nurse practitioner who is competent in creative arts therapy. Mental health counselor permits follow a similar list, with an LMHC in place of the LCAT.

LMSWs follow different rules

An LMSW holds a full license, not a permit. However, NYSED says an LMSW may provide clinical social work (diagnosis, psychotherapy, and assessment-based treatment planning) only under supervision. Qualified supervisors are LCSWs, licensed psychologists, and psychiatrists. An LMSW cannot open a private practice or professional entity to provide clinical services, and cannot hire or contract with their own supervisor. The employer provides supervision. NYSED: social work licensure and practice FAQ.

The same FAQ covers the LMSW and LCSW limited permits. They are issued for a specific employment setting that the permit holder does not own, are valid for one year, and cannot be renewed.

NY Medicaid: who bills for a permit holder

The NY Medicaid fee-for-service manual for LCSWs, LMHCs and LMFTs (July 2025) is the clearest published payer rule for this setup:

• LMHCs and LMFTs in a private or group practice who are enrolled in NY Medicaid can bill for services by LMHC or LMFT limited permit holders they supervise, using their own NPI as the attending/rendering provider.

• LCSWs can bill for services by LMSWs and by LCSW or LMSW limited permit holders they supervise, using the supervising LCSW's NPI. The manual allows an LCSW to supervise up to six LMSWs.

• Limited permit holders cannot enroll in Medicaid, and an LMSW cannot enroll or participate independently.

• The manual pairs each permit with the same licensed profession: LMHC permits under an LMHC, LMFT permits under an LMFT, LCSW and LMSW permits under an LCSW. If your supervisor's license type is different from the permit type, confirm with the payer before billing.

• The supervising LCSW, LMHC or LMFT must be enrolled in NY Medicaid fee-for-service to be paid for both fee-for-service and Medicaid managed care members.

NY Medicaid LCSW, LMHC and LMFT Policy Manual. Fee-for-service enrollment is the first step. Medicaid managed care plans have their own credentialing and may have their own rules for supervised services, so confirm with each plan.

LCATs are not in this manual. It covers LCSWs, LMSWs, LMHCs and LMFTs only. Do not assume an LCAT, or an LCAT permit holder, has a Medicaid fee-for-service billing route in private practice. Ask the payer for its written rule first.

Commercial insurance: payer by payer

New York's Insurance Law lists the outpatient mental health providers that certain policies must cover. In 2023, a chapter amendment removed creative arts therapists from that list, leaving LCSWs, mental health counselors and marriage and family therapists. A 2025 bill to add them back passed both houses and was vetoed on December 19, 2025. NY Senate: S1355 (2023) · NY Senate: A3319 (2025).

That does not mean no plan covers LCAT services. It means coverage and credentialing for LCATs are left to each payer and plan. Before planning supervised billing for LCAT permit holders, ask each payer whether it credentials LCATs in New York at all. If it does not credential the supervising LCAT, there is no supervisor to bill under with that payer.

For LMHC, LMFT and LMSW supervisees, the large national payers publish these rules:

• Aetna (commercial): in-network only. The supervisee must have finished the education for their target license, be accumulating hours toward independent licensure, and receive regular supervision. The supervisor must be independently licensed, credentialed and contracted with Aetna, and employed by the same group. The supervisor is reported as rendering. An LMSW who is not working toward the LCSW does not meet the hours condition. Aetna Fall 2024 bulletin.

• Cigna / Evernorth: allows billing for supervisees' services when state licensing rules permit the arrangement, with the fully credentialed provider identified as rendering. Evernorth Behavioral Health Administrative Guidelines.

• UnitedHealthcare / Optum: Optum reimburses supervised outpatient behavioral health services broadly only in California, Colorado, Hawaii, Iowa and Massachusetts. New York is not on that list. Elsewhere, Optum requires prior approval in the provider or group's agreement or in writing. Where approval exists, every line needs modifier U5 and the claim carries the supervisor's name, credentials and NPI. Optum supervisory reimbursement policy · Optum billing reference guide.

• Other plans: regional Blue plans, Medicaid managed care plans and other commercial plans each set their own rules. Get the answer in writing, or note the call reference, before the first session.

Payer-specific detail: Aetna, Cigna, UnitedHealthcare. Medicare uses its own incident-to rules, which are a different framework.

How to set up the claim

Where a payer allows supervised billing, the claim usually follows this pattern. The payer's own instructions take priority.

1. Billing provider: the PLLC or group, under its Type 2 NPI and tax ID.

2. Rendering (attending) provider: the supervising licensed clinician's individual NPI, never the permit holder's. NY Medicaid, Aetna and Cigna all put the supervisor in this field.

3. Payer-specific fields: add any required modifier or supervisor information, such as U5 and the supervisor details for Optum where approval exists.

4. Supervisor enrollment: the supervisor must be credentialed with that payer and on the group's roster for the date of service.

5. Clinical record: keep the permit holder as the treating clinician who writes the note. Do not change the session's author in the EHR to make the claim go through.

Keep the file that proves the arrangement: the NYSED permit for that site and supervisor, supervision logs, the supervisor's payer approvals, and, for LMSWs, a record that clients were told the LMSW practices under supervision. NYSED's social work FAQ puts that disclosure on the supervisor or employer. What to keep for an audit of a supervised-billing arrangement.

Checklist before the first insured session

• Limited permit issued for this PLLC or group and this supervisor.

• Supervisor credentialed with each payer the supervisee will see clients under, and rostered to the group.

• Each payer's supervised-billing rule confirmed for this license type in New York, in writing.

• For LCAT permit holders: confirmation that the payer credentials LCATs in New York.

• For Medicaid: supervisor enrolled in NY Medicaid fee-for-service, and each managed care plan's rule confirmed.

• EHR set up so the supervisor's NPI is the rendering provider and any required modifier is added.

Bomi checks these rules payer by payer for each supervisee before claims go out, and handles credentialing and billing for New York group practices. Billing is 4% of net collections; credentialing is $50 per payer per clinician, with the first four free on Bomi Billing. See pricing or talk to us.

Related supervised-billing guides

• California: which payers pay for AMFT, ASW and APCC sessions

• Texas: billing for LPC Associates

• Georgia: supervised billing for associate counselors

• Setting up supervisee claims in SimplePractice and TherapyNotes

• Your supervisee just got licensed: what to update

• Can a pre-licensed associate get their own contracts?

Frequently Asked Questions

Can a limited permit holder in New York get their own insurance credentialing?

Not as an independent provider. NY Medicaid states that limited permit holders cannot enroll, and commercial payers generally credential clinicians whose license allows independent practice. Supervisees are billed under a credentialed supervisor where the payer allows it.

Can I bill an LCAT permit holder's sessions under my LCAT license?

Only if the payer credentials you as an LCAT and allows supervised billing for LCAT permit holders. NY Medicaid's practitioner manual does not cover LCATs, and New York's insurance law does not require covering creative arts therapists, so confirm each payer in writing.

Whose NPI goes on the claim for an LMSW in New York?

For NY Medicaid, the supervising LCSW's NPI is the attending/rendering provider and the group is the billing provider. Commercial payers set their own rules; Aetna and Cigna report the supervisor as rendering, and Optum requires prior approval in New York.

Does Optum pay for supervised therapy sessions in New York?

Not by default. Optum's supervisory policy reimburses supervised outpatient services broadly only in California, Colorado, Hawaii, Iowa and Massachusetts. In New York it requires prior approval through the provider or group agreement or written confirmation from Optum.