Billing

Can LMSWs, LACs and LAMFTs Bill Arkansas Medicaid?

By Bomi Health • October 30, 2026

Yes, through the eligible certified-agency pathway. Arkansas Medicaid’s Counseling and Crisis Services manual lists LMSWs, LACs and LAMFTs among non-independently licensed clinicians who can perform qualifying services under supervision. It requires them to serve as rendering providers through a certified agency; it does not tell the practice to replace their identity with the supervisor’s. Reviewed October 30, 2026 against the official Code of Arkansas Rules publication.

Sections

Which licenses qualify, and where?

Section 210.200 names Licensed Master Social Workers (LMSWs), Licensed Associate Counselors (LACs), Licensed Associate Marital and Family Therapists (LAMFTs), Licensed Psychological Examiners (LPEs), Provisionally Licensed Psychologists (PLPs) and Provisionally Licensed Master Social Workers (PLMSWs). Each must hold the relevant license, practice within its scope and receive required supervision.

The clinician must be employed or contracted by a certified Behavioral Health Agency, Community Support System Agency, or an eligible Department of Education-certified school-based mental-health provider. Section 202.000 separately allows independently licensed practitioners and their groups to enroll without agency certification. That exception does not erase the certified-agency condition for non-independent clinicians. A private office address, or an LPC supervising an LAC, does not alone satisfy the Medicaid provider requirement.

Whose NPI is reported as rendering provider?

Report the person who actually furnished the service. Section 210.200 expressly requires the staff member who performed the service to be identified as rendering provider. The CMS-1500 instructions in Section 256.510, item 24J, call for that individual’s Arkansas Medicaid provider ID or NPI. This is an actual-performer billing pathway with clinical supervision, rather than a general supervisor-as-rendering exception. Enrollment and agency affiliation must support the claim.

Does that include individual psychotherapy?

Section 252.111 expressly includes the non-independently licensed master’s/doctoral category among allowable providers for Individual Behavioral Health Counseling. The service must meet its clinical, age, documentation and utilization conditions. The manual describes 30-, 45- and 60-minute services and restricts billing to one individual-counseling encounter per client per day across those codes. Use the current linked counseling procedure-code table for the exact payable code and any service-specific modifiers; do not import an intern modifier from another payer.

The record must support the service: date, start and stop times, place, diagnosis and relevant history, clinical observations, treatment rationale, response and progress, next-session plan, and staff signature with credentials and date. A supervision agreement cannot replace the service documentation or a required authorization or extension of benefits.

Can an unlicensed student use this route?

The named category requires licensure. An unlicensed student or graduate is not an LMSW, LAC or LAMFT merely because a licensed therapist supervises the work. This manual does not establish a general student pathway for these counseling claims. Separate training, service or setting provisions would need their own authority.

Scope and source

This answer covers the state Counseling and Crisis Services program, not an automatic authorization for every PASSE contract, other Medicaid provider type or commercial plan. The official publication’s relevant staff and performer rules are dated July 1, 2024, and its CMS-1500 instructions January 1, 2024. A proposed rule or final-posting packet was not used as proof of adoption.

Official Arkansas Counseling and Crisis Services manual — Sections 202.000, 210.200, 252.111 and 256.510

Frequently Asked Questions

Can an Arkansas LAC bill under an LPC’s NPI?

The cited Medicaid agency pathway requires the actual staff member who performed the service as rendering provider. Supervision does not authorize replacing that clinician with an LPC on the claim.

Does an ordinary private group qualify just because it employs an LMSW?

Not on that fact alone. The non-independent clinician pathway requires the eligible certified-agency arrangement and the applicable enrollment, service and supervision conditions.

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