Can Maryland Medicaid Pay for LGPC, LMSW and Student Therapy?

Can an LGPC or LMSW bill Medicaid under a private-practice supervisor?

No under the individual and group practice rules in the current Carelon Maryland PBHS manual. Section 2.06 says non-independently licensed practitioners cannot enroll individually or receive payment for services in an individual or group practice. Its group-practice rule also bars reimbursement to supervisors for services delivered by non-independent supervisees. A supervisor’s Medicaid participation does not turn that private-practice visit into a payable supervised claim.

Which licenses does the restriction address?

The manual expressly names LGPC and LMSW, among other non-independent credentials. Its group-practice list also names LGMFT and LGADC. Maryland’s LCSW and LCSW-C are different credentials: the manual places LCSW in the non-independent list, while COMAR 10.09.59.04 names the clinical social worker qualification for individual specialty mental-health practice. Do not treat a graduate license, a master’s degree, and independent clinical licensure as equivalent.

Can an approved outpatient mental health clinic use supervised staff?

Yes, through the separate facility/program pathway, subject to its requirements. Manual page 16 allows facility reimbursement for services delivered by non-independently licensed individuals under appropriately licensed staff’s direct supervision. The facility must satisfy its licensing, accreditation, Medicaid enrollment and authorization requirements. An ordinary group practice is not automatically an approved outpatient mental health clinic (OMHC), and changing the billing NPI alone does not create that status.

Are graduate students and interns allowed in an OMHC?

COMAR 10.09.59.04B(4) expressly includes graduate-level students and interns in OMHC staffing. They may deliver services under a licensed mental health professional’s supervision, and a licensed mental health professional must co-sign all documentation of participant contact. That is an OMHC provision, not permission for a student to bill independently or for every private practice to bill an intern’s work. Applicable professional-board and service requirements still apply.

Whose NPI and which modifier should appear?

The current manual requires facility organizational NPIs and Medicaid numbers for the relevant provider type and location. The reviewed current provisions do not supply a complete, universal OMHC trainee rendering-NPI or supervision-modifier map. Keep the rendering-field question separate from the supported facility eligibility rule. Do not use a supervisor NPI to bypass the explicit individual/group prohibition, or import another payer’s HL, HN or U5 rule.

Does this apply to every HealthChoice or commercial claim?

This answer concerns Maryland’s Public Behavioral Health System specialty mental-health pathways, reviewed October 30, 2026 against Carelon PBHS manual version 5 and current COMAR. Other benefits, MCO responsibilities, FQHC arrangements and commercial contracts have separate rules. Permission for an approved facility is not blanket permission for an individual or group practice.

Primary sources

Carelon Maryland PBHS Provider Manual, version 5, pages 15–16

COMAR 10.09.59.04: individual and OMHC provider requirements

Frequently Asked Questions

Can my LCPC supervisor bill my LGPC private-practice sessions?

The reviewed PBHS individual/group rules do not allow that supervisor-reimbursement route.

Are OMHC student services automatically excluded?

No. COMAR explicitly permits the scoped OMHC pathway with professional supervision and co-signature of all participant-contact documentation.