DC Medicaid: Can LGSWs and LGPCs Provide MHRS Counseling?

Yes, in the certified MHRS program

DC’s Mental Health Rehabilitation Services rules list licensed graduate social workers (LGSWs) and licensed graduate professional counselors (LGPCs) as qualified counseling practitioners. The currently linked Medicaid State Plan also lists both for Counseling/Therapy. This supports a specific certified-program pathway, not independent private-practice billing merely because a supervisor is available.

Which service does the rule cover?

Chapter 34 section 3420 governs individual, group and family counseling within MHRS. The provider must hold the required Department of Behavioral Health certification. The state plan’s Counseling/Therapy section requires authorization under applicable regulations. A qualified clinician is one condition; the member’s treatment needs, program participation and service requirements still govern payment.

A graduate license is not independent practice

Section 3416 requires qualified practitioners to stay within their license, certification or registration and follow applicable supervision law. In particular, DC’s current LGSW statute distinguishes psychotherapy from other social-work functions: psychotherapy requires supervision by an LICSW. The existence of an LISW elsewhere in a program staffing list does not remove that psychotherapy-specific restriction.

Can an unlicensed student use the same pathway?

Not simply by working under an LGSW or LGPC supervisor. Those are licensed practitioner categories. Chapter 34 distinguishes credentialed nonlicensed staff and limits them to permitted service components that do not require professional licensure. The counseling practitioner list does not establish general student or unlicensed-graduate psychotherapy permission.

Does the supervisor become the rendering provider?

The reviewed service and qualification rules do not establish a universal supervisor-NPI substitution or trainee modifier. Do not turn a staffing list into a claim-field rule. Use the certified provider’s enrollment, applicable billing instructions and the patient’s actual payer arrangement. MHRS eligibility does not establish every managed-care contract or another benefit’s private-practice coverage.

Current evidence, not the 2020 demonstration grid

Reviewed October 30, 2026 against DBH’s published Chapter 34 and the Medicaid State Plan supplement linked from DHCF’s current services index. The Counseling/Therapy pages carry approval January 22, 2024 and effective November 1, 2023. The older 2020 demonstration grid is not the basis for this answer. Later program, contract or claim changes still require the relevant current instructions.

Primary sources

DBH Chapter 34 — sections 3401, 3416 and 3420

DC Medicaid State Plan — Counseling/Therapy, printed pages 5–6

Current DHCF services index

DC LGSW scope and psychotherapy supervision

Frequently Asked Questions

Does DC Medicaid name LGSWs and LGPCs for counseling?

Yes, within its certified MHRS program and subject to lawful scope, supervision, authorization and other service requirements.

Can an LGSW provide psychotherapy under any listed MHRS practitioner?

No. DC law requires LICSW supervision for an LGSW’s psychotherapy. A program staffing list does not broaden that authority.