Can LPCAs, CSWs and MFTAs Bill Kentucky Medicaid?
By Bomi Health • October 30, 2026
Yes, conditionally through the applicable Kentucky Medicaid fee-for-service billing-supervisor pathway. Appendix H of the current billing instructions names LPCAs, master’s-level CSWs and MFTAs among practitioners whose covered services require a billing supervisor. The supervisor’s NPI goes in the unshaded CMS-1500 Box 24J, with the applicable modifier identifying that an associate performed the service. This is not permission for any unlicensed person to bill psychotherapy.
Sections
Which associates are named?
Appendix H includes Licensed Psychological Associates (LPAs), Certified Social Workers at master’s level (CSWs), Licensed Professional Counselor Associates (LPCAs), Licensed Professional Art Therapist Associates (LPATAs), Marriage and Family Therapist Associates (MFTAs), Licensed Behavioral Analyst Associates (LABAs), Licensed Clinical Alcohol and Drug Counselor Associates (LCADCAs), CADCs and certified psychologists. Each profession still needs its own lawful scope and covered service; a behavioral-analysis credential does not authorize ordinary psychotherapy.
Registered nurses and psychiatric registered nurses in the table have a CMHC/CCBHC-only restriction. The table separately marks LADC and Behavioral Health Associate entries as pending regulatory approval; this article does not treat those entries as active permission. Nor does the list establish a general student-intern pathway.
Whose NPI and modifier should the practice use?
The state’s August 2026 PT81 LPCC and PT89 psychologist manuals both include Appendix H’s billing-supervisor instruction. For the paper claim, use the billing supervisor’s NPI in unshaded 24J. The PT81 instructions explicitly use U4 for an LPCC’s LPCA services; PT89 likewise uses U4 for an LP’s LPA services. Their independently licensed service modifiers are HO and AH respectively. Do not extend those examples into an unsupported modifier rule for every associate or every service.
The manuals identify these field instructions as paper-claim guidance. Electronic claims require the applicable Kentucky companion guide; do not assume the paper form alone establishes every electronic loop or qualifier. The KYMMIS index says its billing instructions are for FFS providers only. A managed-care plan’s contract and claim instructions require separate verification.
Does the billing supervisor replace the licensure supervisor?
No. Appendix H requires a monthly supervisory note recording case consultations and the supervisor’s evaluation of services. It expressly says the billing arrangement must not violate or substitute for either profession’s clinical-supervision rules.
The approved billing-supervisor categories include physicians, psychiatrists, APRNs, physician assistants, psychologists, psychological practitioners, LCSWs, LPCCs, LMFTs, LPATs, LBAs, LCADCs and certified psychologists with autonomous functioning. A name appearing on that list does not establish that every supervisor can clinically supervise every listed associate. Confirm the applicable board requirements and provider arrangement before care.
Which source version is this based on?
The current KYMMIS index links PT81 version 2.9 and PT89 version 3.0, both dated August 13, 2026; accessibility footers are dated September 2026. These replace the older July 2025 links. The answer is about eligible covered services under those FFS provider instructions, not automatic approval for all settings, products or procedure codes.
Frequently Asked Questions
Can an LPCA use an LPCC’s NPI for Kentucky Medicaid FFS?
The PT81 manual describes LPCA services billed with the billing supervisor’s NPI in unshaded Box 24J and U4. Enrollment, covered-service and clinical-supervision conditions still apply.
Does Medicaid billing supervision replace board supervision?
No. Appendix H expressly preserves professional-board clinical-supervision requirements and requires a monthly supervisory note.
Sources and scope
Reviewed October 30, 2026. These are program-specific rules, subject to current enrollment, member eligibility, service coverage, authorization and applicable professional supervision requirements.
KYMMIS current FFS billing-instructions index
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