Does Hawaii Medicaid Cover Unlicensed Therapy at FQHCs and RHCs?

Can an unlicensed therapist provide Hawaii Medicaid care?

Conditionally in the FQHC/RHC pathway described by Med-QUEST memo QI-2131. This is not general private-practice permission. The memo also says QUEST Integration health plans need not cover unlicensed-provider services when their networks already provide sufficient access. Confirm the actual member’s program and plan agreement.

Which graduate and supervisor qualify?

The unlicensed provider needs a master’s degree in psychology or a human-services-related field and at least three years of behavioral-health experience, which may include practicum. A student without the completed degree does not meet this pathway. The supervisor must be a Hawaii-licensed psychologist or psychiatrist, active with Medicaid and contracted with the plan or employed by its contracted provider. The supervisor may oversee no more than ten unlicensed providers.

What supervision is required?

Weekly individual supervision must address therapy for each patient and be documented. The clinicians ordinarily share a physical location. A specialty-board-approved alternative communication method is allowed when the other conditions are met, including continuous supervisor availability and an in-person supervision session at least every 30 days. This is a supervision provision, not blanket permission for patient telehealth.

Treatment records and signatures

The supervisor and treating provider develop the care plan together and reassess it at least every six months. Both sign the care plan and therapy notes; the supervisor signs and dates supervisory notes kept in the patient record. Applicable practice laws and the memo’s selection, monitoring and confidentiality requirements remain in force.

Which fee-for-service claims and modifier?

For the memo’s eligible FFS arrangement, the supervisor is the provider of record and submits individual clinic therapy with HO: 90832, 90834 or 90837. Payment is 50% of the Medicaid FFS rate rather than PPS for the unlicensed service. The provider or clinic must give MQD the unlicensed-provider list and master’s-degree copies and update changes. Psychiatric evaluations, group, family and conjoint therapy are excluded from this unlicensed pathway.

Avoid a duplicate PPS or FFS encounter

The memo has separate same-day prescriber and licensed-supervisor face-to-face provisions. A qualifying prescriber visit at the FQHC/RHC may be the PPS behavioral-health claim, without an additional unlicensed/supervisor claim. When the licensed supervisor personally performs the qualifying encounter’s key portions and documents them, support work is included in that encounter rather than separately billed. Review the exact encounter before choosing PPS or FFS.

Date and limits

Reviewed October 30, 2026. The current Med-QUEST memo index still links QI-2131, dated December 29, 2021, replacing ADM-1201. This answer follows that memo’s qualifications, FQHC/RHC setting and explicit FFS reimbursement provisions; it does not guarantee a QUEST plan contract or expand into another practice setting.

Med-QUEST QI-2131: FQHC/RHC supervision and payment

Current Med-QUEST provider memo index

Frequently Asked Questions

Does a Hawaii master’s student qualify automatically?

No. This memo requires a completed relevant master’s degree and three years of behavioral-health experience, which may include practicum.

Can any licensed therapist supervise this pathway?

No. QI-2131 specifies a Hawaii-licensed psychologist or psychiatrist active with Medicaid and meeting its contract and supervision requirements.

Does HO guarantee payment from every QUEST plan?

No. HO appears in the memo’s specified FFS reimbursement route; the memo separately preserves health-plan coverage discretion when access is sufficient.