Can Associates or Interns Bill Insurance? Payer Guide
By Bomi Health • October 16, 2026
“I am hiring an associate or intern, and I accept BCBS Illinois, Cigna and UHC. Can my new hire’s sessions be billed to those insurers?” Start with that hiring decision. The answer depends on the clinician’s actual credential or student status, the member’s benefit and the insurer’s supervised-service conditions. Being contracted yourself is only one part of the answer.
Sections
- An Illinois practice accepting BCBSIL, Cigna and UHC
- Keep three hiring categories separate
- Find your insurer’s hiring requirements
- More payer and setting guides
- Anthem medical incident-to is not associate permission
- Colorado oversight and U9
- Point32Health commercial product boundaries
- Virginia commercial and Medicaid rules
- EAP and network routes
- Shared routing does not identify the benefit
- Other documented policy distinctions
- Medicare Advantage is a plan-specific inquiry
- Medicare supplements: resolve the primary service first
- When the administrator has no verified supervisory rule
- Destination directory
- More insurer-specific hiring answers
- Commercial insurers
- Administrators, networks and employer plans
- Behavioral health administrators
- Medicaid products
- Traditional Medicare routes
- Medicare Advantage products
- Medicare supplements
- Employee assistance programs
- Federal programs
- Identity and source holds
- Before sending the first supervised-service claim
- Frequently Asked Questions
An Illinois practice accepting BCBSIL, Cigna and UHC
Hypothetical planning example: an Illinois practice is choosing between a licensed associate, an unlicensed graduate and a student still completing a degree. The same supervision agreement does not establish the same billing pathway for all three insurers. This comparison identifies the documented decision points; it is not approval of an individual hire or member claim.
Insurer | Associate or unlicensed graduate | Student intern | Before assigning insured clients |
|---|---|---|---|
BCBS Illinois | Use the actual category: a formal qualifying trainee pathway differs from other providers’ own-NPI arrangements. | A qualifying master’s-/doctoral-level trainee may fit; a school placement or job title alone does not establish eligibility. | Confirm the applicable category, contracted supervisor and required direct/personal supervision. |
Cigna / Evernorth | Published supervisee pathway where state licensing regulations permit the services; credentialed provider is rendering. | Student-intern eligibility is not established by the cited general supervisee provision. Obtain a category- and product-specific Evernorth determination; state permission and a school placement alone are insufficient. | Confirm the state-permitted relationship, administrator/product and credentialed supervisor. |
UHC / Optum | Commercial/exchange pathway has five state exceptions; other states need previous approval. Non-licensed BH clinicians need at least a master’s. | A student without the required master’s does not meet the cited commercial minimum; degree holders still need the remaining conditions. | For an Illinois arrangement, establish prior approval before budgeting on this pathway; confirm the actual product. |
BCBS Illinois: can associates or interns bill?
Cigna/Evernorth: can associates or interns bill?
UHC/Optum: can associates or interns bill?
BCBSIL trainee eligibility and supervision
BCBSIL rendering and direct/personal supervision
Evernorth professional services, printed page 46
Optum commercial state and approval requirements
Optum provider eligibility, reference guide pages 5–7
Keep three hiring categories separate
A licensed associate holds a specific state credential but may not yet practice independently. An unlicensed graduate has completed a degree but may need registration, an exemption or another legal authority to deliver services. A student intern is still in a qualifying training placement and may not have earned the degree a payer requires. Insurer terms such as “intern,” “extender” and “limited-license clinician” must be matched to their definitions rather than treated as synonyms.
A conditional pathway below means the insurer has documented an eligible arrangement, with requirements still to meet. “Not established” means the reviewed evidence does not support a reliable hiring-revenue assumption; it is not a refusal or a clinical-practice prohibition. A restriction applies only to the named category, program or setting. Confirm the new hire’s individual eligibility before promising an insurance caseload.
Policy research reviewed October 17, 2026. Find the policy that governs the clinician and benefit, then choose the claim identity. An EDI destination is an electronic address, not approval to bill under a supervisor.
Choose the insurers your practice accepts and compare the new hire’s actual credential and training status. Named payer and card pages answer specific hiring questions even where some filing rules overlap. Regional Medicare addresses share a federal benefit guide. Administrator cards need the governing employer plan identified; their entries preserve the exact evidence still needed.
Find your insurer’s hiring requirements
Aetna: same-group supervisor and completed education
Determine whether the in-network pathway fits the supervisee and supervisor employment arrangement before using the supervisor as rendering.
Cigna/Evernorth: supervisee services versus credentialing delays
Separate a state-permitted supervisee arrangement from a fully licensed clinician awaiting participation.
Optum/UHC: state exceptions, approval, U5 and DQ
Apply the July 2026 five-state list and approval conditions before constructing the supervised-service claim.
BCBS Illinois: actual clinician versus formal trainee exception
Licensed nontrainees generally retain their rendering identity. The formal trainee exception has separate conditions; the published notice says not to append the planned HL modifier until implementation is announced.
BCBS Michigan: office restriction and OPC transition
The March 2027 office restriction has a conditional letter-of-intent accommodation for practices completing OPC enrollment. It is not a universal six-month delay.
Priority Health: license, supervisor and modifier pairings
Match LLMSW/LMSW/AJ, LLC/LPC/HO, or TLLP/LP/HO and the applicable product. The limited-license pathway excludes Medicare Advantage.
Premera Washington: associate is rendering
Use the associate identity; distinguish group loading, the bounded pending-license allowance, and full-license credentialing.
Moda Oregon/Idaho: contract and supervised-provider registration
The commercial program requires enrollment and uses the supervised therapist’s own NPI. It expressly rejects substituting the supervisor as rendering.
Select Health: initial evaluation and 2027 enforcement
Schedule the initial evaluation with a credentialed/contracted provider; separate provisional clinicians, students, and grandfathering.
CareFirst: supervised credentialing applications
Identify the qualified supervisor and complete the supervised clinician’s application route rather than assuming the supervisor’s participation is sufficient.
BCBS Kansas: explicit incident-to restriction
An ineligible psychotherapy provider does not become eligible through supervision. Do not import a different Blue plan’s trainee exception.
Oregon Medicaid: July 2027 setting transition
Use the existing OHP guide for board-registered associates and COA setting requirements, rather than applying Moda’s commercial program.
UPMC and Community Care Pennsylvania: different benefits
The existing guide distinguishes commercial participation questions from Community Care’s Medicaid provider restrictions and setting exceptions.
Traditional Medicare: eligible billing category and incident-to conditions
Start with the federal benefit and qualified practitioner category. Regional claim routing does not create twelve different clinical permissions.
More payer and setting guides
Horizon NJ: Supervised Therapy, Approved Plans and HO
The board-approved named supervisor and HO requirement govern this New Jersey pathway.
IBX: Supervised Therapy, AJ and Credentialing Changes
AJ, written consent and the exam-to-credentialing transition require an IBX-specific review.
Regence and Asuris: Supervised Therapy and SA
Compare SA and same-group supervision; preserve separately documented state and product boundaries.
Lucet Alabama and Florida: Supervised Therapy Claims
The commercial approval and supervised-intern fields must be read alongside named employer nonapprovals.
Carelon Massachusetts: WellSense and Fallon Supervision
WellSense group/facility and Fallon facility provisions do not create one national Carelon rule.
Magellan: California Associates and Idaho Claim Conflicts
California modifier instructions differ from IBHP; Idaho billing-identity and modifier conflicts remain explicit.
AZ Blue: Supervised Therapy Intake and NPI Rules
Supervisor intake, financial relationship and contracted rendering identity change the arrangement.
Blue Cross of Idaho: Mental Health Extender Claims
Distinguish direct contracts from sponsored extenders and billing from performing NPIs.
Quest: Licensed Associates, Claim NPIs and 2026 Changes
Quest requires the treating provider; licensed associates and EAP routing must be checked against employer transition dates.
OSU Health Plan: Supervised Therapists and Trainees
A published OSU plan policy distinguishes licensed practitioners, excluded trainees and qualified psychology trainees.
Illinois Medicaid: Supervised Therapy by Practice Setting
Private practice, approved agencies and FQHC/RHC encounters have separate qualification and enrollment rules.
Wyoming Medicaid: Provisional and Student Therapy Claims
In-person provisional and qualifying student/resident categories use different NPI/HL paths; telehealth remains separately qualified.
Kaiser Washington: Associate NPIs and Supervised Billing
Use the actual associate rendering identity; qualified supervisor billing and the contract-specific fee basis are separate checks.
Anthem medical incident-to is not associate permission
The current C-11002 policy, effective December 2, 2025, defines its nonphysician practitioners as nurse practitioners and physician assistants. Its history records removal of auxiliary personnel. The older 2024 auxiliary-personnel discussion therefore cannot establish a current associate-therapist pathway. The current policy also excludes direct-eligible practitioners waiting for an NPI or health-plan eligibility.
Within that medical policy, Colorado is exempt from both the payment reduction and SA; Georgia and Kentucky are exempt from the reduction. These are scope-limited medical-policy differences, not instructions to file an associate therapist’s claim with SA. Obtain the applicable behavioral-health authority before choosing a therapist’s rendering identity.
Anthem C-11002, current policy, definitions, state exemptions and revision history
Colorado oversight and U9
Colorado’s October 2026 behavioral-health update abandons the proposed state Box 19 requirement while retaining U9 for applicable claim lines from July 1, 2026. RAE-specific requirements still need checking. Colorado Access’s June 2026 town hall gives a one-hour-per-twenty-service-hours oversight ratio for the unlicensed workforce; that passage does not establish the ratio for every prelicensed clinician. Supervision oversight and the claim’s rendering identity remain separate questions.
HCPF October 2026 behavioral-health update
Colorado Access June 2026 town hall, slides 11 and 13
Point32Health commercial product boundaries
Point32Health’s shared commercial policy supports a product-scoped comparison for Harvard Pilgrim and Tufts. Its supervised-clinician modifier grid distinguishes license levels, including HL, HO, HN and HM. Apply only the category and product that the policy actually covers; the grid does not establish eligibility for an otherwise unapproved clinician. Direct, Together, RITogether and delegated products need their own applicability review. A shared administrator name does not select a rendering NPI or make an old Optum arrangement current.
Point32Health commercial behavioral-health payment policy and applicability grid
Virginia commercial and Medicaid rules
Sentara’s commercial manual describes a supervisor individual-NPI rendering pathway for board-approved counseling residents and social-work supervisees. Virginia Medicaid’s practitioner and clinic rules instead require a separate assessment of LMHP-R, LMHP-RP or LMHP-S qualifications, enrollment, service setting and documentation. The cited Medicaid chapter requires dated clinician and supervisor signatures and supervisor co-signature within one business day. It does not turn Sentara’s commercial identity rule into the FFS or managed-care claim rule.
Sentara commercial provider manual, resident and supervisee provision
Virginia Medicaid psychiatric-services chapter V
EAP and network routes
First Choice Health’s current EAP enrollment criteria require fully licensed master’s or doctoral behavioral-health clinicians who do not require supervision. Its EAP and PPO networks are separate. The linked EAP manual is the 2020 edition and describes authorized cases and EAP payment forms; it does not establish associate eligibility for every PPO employer benefit. Aetna EAP likewise requires its own authority rather than automatic adoption of Aetna’s commercial supervisory bulletin. Quest’s BH/EAP guide above shows why ordinary EAP modifiers and routing must be distinguished from supervised-provider permission.
First Choice EAP network criteria
First Choice separate-network applications
Shared routing does not identify the benefit
The same electronic route can serve several benefits. HealthPlus payer 45302 has an officially documented MLTC use; the route alone does not select all HealthPlus benefits. Centene’s 68068 and 68069 serve multiple subsidiaries and programs, with documented MHS Indiana use. That example is not proof that every claim on either route follows Indiana’s rules. Confirm the member product, administrator, service date and contract before selecting a clinical policy.
Other narrowed identities still need plan evidence: Benefit Health Plan’s public material connects MBA and 52682; Everence distinguishes commercial administration from Medicare supplements; U.S. Networks uses USN01. These facts help locate the controlling agreement but do not grant supervisory permission. The additional unresolved HealthLink route is retained separately rather than silently assigned another HealthLink destination’s identity or policy.
Other documented policy distinctions
BCBS Oklahoma and BCBS New Mexico publish trainee-related guidance, but it should not be flattened into one nationwide Blue rule. Oklahoma’s FAQ discusses formal supervisory relationships and outpatient modifier handling; reconcile it with the applicable version of RP029. New Mexico’s reminder describes direct/personal supervision and contractual requirements. Confirm the clinician category and product, including any FEP or Medicaid distinction. Two Oklahoma EDI routes do not establish two policies.
BCBS Oklahoma behavioral health billing FAQ
BCBS Oklahoma RP029, October 2, 2026 version
BCBS New Mexico May 2026 claims reminder
Texas LPC associate guide: state authority and payer differences
Geisinger’s Pennsylvania notice addresses LSWs specifically. It does not establish permission for every LPC awaiting credentialing. Wisconsin ForwardHealth’s outpatient mental health materials describe qualified treatment trainee categories and billing arrangements; do not replace those categories with a generic supervisor-NPI rule.
Geisinger: LSW billing under supervision
Wisconsin ForwardHealth outpatient mental health handbook
TRICARE distinguishes certified mental health counselors from supervised mental health counselors. Its certification and supervision requirements are not a general prelicensed-therapist exception. Establish the actual program and provider category; TRICARE East, West, and For Life are not grounds for three near-identical supervision articles. CHAMPVA and VA Community Care remain separate programs and require their own determinations.
TRICARE West mental health counselor certification application
Medicare Advantage is a plan-specific inquiry
Do not treat a Medicare Advantage claim destination as another Original Medicare contractor address. Establish the plan’s provider eligibility, participation, authorization, and billing requirements. The directory routes these products to the verification workflow; the Original Medicare guide supplies background, not the plan’s supervisory approval.
Medicare supplements: resolve the primary service first
An AARP, Cigna, Medico, or Mutual of Omaha supplement route does not create an independent commercial supervisory pathway. Establish whether the policy is Medigap and whether Medicare is primary, then resolve Medicare provider eligibility and the primary claim before secondary coordination. A product carrying the same brand as a commercial insurer is not automatically governed by that insurer’s commercial supervision bulletin.
Medicare: how Medigap works with Original Medicare
Use the existing Medicare incident-to guide
When the administrator has no verified supervisory rule
For destinations marked “Supervisory permission not established,” the linked resource is an administrative starting point, not evidence of approval or prohibition. Identify the employer plan, behavioral health administrator, network agreement, clinician category, and service state. Request the policy and a written determination that addresses both enrollment and claim identity.
Use the plan-verification worksheet and exact questions
Destination directory
Look up the name on the claim route, then read the linked guide’s scope. Guide links may be shared deliberately. These are researched routing labels, not a list of payer approvals. Four names remain identity/source holds and have no article link. Resource links for unresolved entries are labelled accordingly.
More insurer-specific hiring answers
Can Associates or Interns Bill Anthem California?
Can Associates or Interns Bill Asuris?
Can Associates or Interns Bill BCBS Alabama?
Can Associates or Interns Bill BCBS New Mexico?
Can Associates or Interns Bill BCBS Oklahoma?
Can Associate Therapists Bill Blue Shield California?
Can Associates or Students Bill BlueCare and TennCareSelect?
Can Associates Bill Fallon Health Through Carelon?
CareSource Indiana: Can Associates or Interns Bill?
Colorado Access and CCHA: Hiring Supervised Clinicians
Can Psychology Trainees Bill Community Care HealthChoices?
Can Associates or Interns Join ComPsych’s Network?
Can Associates or Interns See First Choice Health EAP Clients?
Can Associates or Registered Interns Bill Florida Blue?
Can Registered Interns Bill Florida Medicaid?
Can Associate Therapists Bill Geisinger Health Plan?
Can Associates or Interns Bill Harvard Pilgrim?
Can Supervised Therapists Bill Highmark Health Options?
Highmark NY Medicaid: Can Interns or Permit Holders Bill?
Can Associate Therapists Bill Highmark Pennsylvania?
Humana Louisiana: Can Provisional Clinicians Provide CPST?
Can Associates or Interns Bill Innovation Health?
KanCare: Can Associates Bill Healthy Blue or UHC?
Can Associate Therapists Enroll With MedCost?
Can Licensed Associates Bill Molina Apple Health?
Can Associates or Interns Bill Oscar Through Optum?
Can Associate Therapists Bill Regence Idaho?
Can Associate Therapists Bill Regence Oregon?
Can Associate Therapists Bill Regence Washington?
Can Supervised Therapists Bill Sentara Commercial?
Can Associates or Interns Bill TRICARE?
Can Associates or Interns Bill Tufts Commercial?
Can Residents and Supervisees Bill Virginia Medicaid?
Can QTTs or Student Interns Bill Wisconsin Medicaid?
Can Associates or Interns Treat WPEE Fund Members?
Commercial insurers
Aetna
Licensed associate: Qualified license-eligible clinicians who have completed all education and are actively accumulating independent-licensure hours may qualify in network. No universal provisional-license minimum is stated.
Unlicensed graduate: An unlicensed graduate can qualify if all educational requirements are complete, they are actively accumulating licensure hours and the state permits the arrangement.
Student intern: A current student who has not completed the target license educational requirements does not meet this pathway.
Before assigning insured clients: Verify completed education and active supervised-hours status. Use an independently licensed, Aetna-contracted supervisor employed by the same group/facility; supervision may be virtual. Confirm the actual in-network behavioral health product and all participants’ applicable network status.
Applies to: In-network behavioral health bulletin; no automatic extension to Aetna EAP, Medicaid, Medicare, Meritain or every employer arrangement.
Read this insurer’s hiring requirements
Anthem California
Licensed associate: The 2026 8VC4 Prudent Buyer PPO EOC recognizes ASW, AMFT and APCC services when delivered pursuant to California law. This supports benefit eligibility for that plan; it does not itself establish the practice’s participation or supervisor billing arrangement.
Unlicensed graduate: A degree alone is insufficient. The candidate must fit a named lawful associate, registered psychological assistant or supervised psychology category; the EOC does not create an unrestricted category for any unlicensed graduate.
Student intern: The same EOC expressly includes MFT trainees, PCC trainees and psychology trainees/persons supervised under California law. A qualifying student trainee is therefore not excluded merely for still being a student. This does not include every student placement or automatically establish social-work student eligibility.
Before assigning insured clients: Match the actual member to the 8VC4 benefit language or obtain the governing EOC for a different product. Verify the candidate’s named associate/trainee status and legally permitted supervision arrangement. Establish the group’s accepted participation/roster arrangement and obtain therapist claim identities before assigning insured clients; the EOC is not a claims manual.
Applies to: Named 2026 California commercial Prudent Buyer PPO 8VC4 only. Do not extend to all Anthem California, Medicaid, Medicare or other-state products.
Verified card/routing references: Anthem Silver PPO HSA/H 8VC4; 040. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Anthem Colorado
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. Colorado exempts both the reduction and SA. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 050. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Anthem Connecticut
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. No exemption for this state is listed. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 00060. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Anthem Georgia
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. Georgia exempts the reduction, not SA. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 00601. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Anthem HP route
Licensed associate: HealthPlus product-specific associate eligibility is not established; the HP name and shared route cannot select the governing benefit. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Student eligibility is not established for the unidentified HealthPlus product. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: Official MLTC FAQ instructs payer45302 for DOS12/1/2022 onward; earlier approvals specify their route. Current NY EDI page also lists45302. This confirms MLTC is a real use of this route, not that every45302 claim is MLTC. HP name and shared45302 route cannot distinguish Medicaid/HARP, Essential or MLTC benefits. Even the new C-11002 HP footer is commercial-policy identity, not MLTC therapist coverage. No product-bound associate filing permission established.
Verified card/routing references: 45302. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
MLTC claims FAQ — p1 date-of-service payer-ID table
Anthem Indiana
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. No exemption for this state is listed. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 130. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Anthem Kentucky
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. Kentucky now exempts the reduction, not SA. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 00660. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Anthem Ohio
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. No exemption for this state is listed. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 00834. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Anthem Virginia
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. No exemption for this state is listed. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 423. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Anthem Wisconsin
Licensed associate: C-11002 does not authorize associate therapist billing: its current NPP definition is NP/PA and its auxiliary-personnel provision was removed. A separate behavioral-health permission is needed; this is not a company-wide therapist ban.
Unlicensed graduate: Graduation or waiting for credentials does not create eligibility under C-11002. Obtain a behavioral-health policy that names the graduate credential and setting.
Student intern: A student therapist cannot rely on this NP/PA medical incident-to policy. No separate student therapy pathway is established in these sources.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Do not substitute a physician NPI or import SA merely because C-11002 provides that pathway for eligible NP/PA services.
Applies to: The current 12/02/2025 edition expressly removes auxiliary personnel; NPP is defined as NP or PA. It does not establish permission for associate therapists. Supervising physician involvement and service review are required. No exemption for this state is listed. Current p2 excludes direct-eligible types waiting for NPI or plan eligibility. The former general auxiliary/pending-NPI allowance is absent; credentialing delay does not establish incident-to eligibility. For applicable NP/PA incident-to claims only, supervising physician NPI and nonsurgical SA are specified, subject to listed exemptions. No therapist-specific 1500/837P mapping or telehealth eligibility is established. Interactive supervisor availability is not a telehealth billing authorization.
Verified card/routing references: 450. A payer ID identifies routing and does not establish clinician eligibility.
See the “anthem medical incident to is not associate permission” section above.
Asuris Northwest Health
Licensed associate: Asuris Northwest Health expressly supports board-registered master’s/doctoral licensure-track behavioral-health associates and state-qualified LMSWs under its Adm148 exception. A qualified licensed, credentialed supervisor must be in the same group and have equal or greater education. This is a documented eligibility pathway despite incomplete claim-field mapping.
Unlicensed graduate: A graduate who has the required state-board registration and formal licensure track can fit the policy even before independent licensure. A degree-only, unregistered graduate is not established as eligible. This is not permission for unlicensed practice prohibited by state law.
Student intern: The policy names completed graduate preparation and state board registration/formal licensure track. It does not establish a pre-degree student placement benefit. The separate residency/fellowship exclusion also needs review for any overlapping training program.
Before assigning insured clients: Verify completed qualifying degree, active board registration/formal licensure track or LMSW status, lawful state scope and actual product coverage. Use a licensed, credentialed same-group supervisor with equal/higher education; document treatment review, meetings and consultation availability. Check any residency/fellowship overlap: Asuris separately excludes those training-program services. Resolve any roster/advance approval and exact claim-role allocation; prepare SA service-line reporting and supervisor name/identification without inventing rendering-field placement. For a Washington LMHCA, verify approved state supervision and no independent fee-based practice; separately satisfy Asuris’s same-group supervisor condition. This is clinical-law evidence, not payer enrollment.
Applies to: Asuris’s own Adm148 is commercial only; similar Regence policy does not add MA coverage.
Verified card/routing references: Asuris Northwest Health. A payer ID identifies routing and does not establish clinician eligibility.
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Incident To Services Adm148 — pp.1–3, commercial scope; psychological behavioral health requirements
1500 Reference Instruction Manual version13 — pp.2,26–27,44,55
Mental Health Counselor FAQ — What is an associate / independent services / progress notes
AZ Blue
Licensed associate: AZ Blue names licensed associate counselors, associate marriage/family therapists, associate substance-abuse counselors and master social workers among credentials that may use its incident-to arrangement. It also has a separate employment-based branch for independently contract-eligible nonphysicians. All supervision and financial conditions still apply.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Have the supervising provider establish the relationship, perform the initial service for the condition and create the treatment plan; the supervised-intake exception ended for new patients January 1, 2026. Make the clinician a direct financial expense of the supervisor/group and document ongoing treatment involvement, lawful scope and readily available physical or real-time audiovisual help; audio-only supervision is insufficient. Confirm the contracted rendering provider and NPI/TIN combinations are registered before claims.
Applies to: Use the actual AZ Blue product, benefit and network contract. No adoption by other Blue plans or unrestricted government-product eligibility follows.
Verified card/routing references: AZ Blue. A payer ID identifies routing and does not establish clinician eligibility.
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Incident-To Services — pp. 1–2; credential/employment, supervision, submitting claims
BCBS Alabama
Licensed associate: Lucet’s current BCBS Alabama appendix, including its Southern Company entry, approves interns/provisionally licensed professionals subject to state law, benefits and the supervised arrangement. This is behavioral-health approval, not a general APP supervisor-billing rule. The current general entire-session presence clause must be reconciled with availability/appendix wording before budgeting remote-only oversight.
Unlicensed graduate: A degree alone does not establish the required state credential/registration or plan-approved provisional category. The manual does not supply blanket approval for unregistered graduates.
Student intern: The manual uses intern alongside applicable state licensure/registration and degree-based coding. It does not expressly establish college practicum placements. A registered post-graduate intern must not be treated as equivalent to an actual student.
Before assigning insured clients: Identify the exact plan/product and employer appendix before relying on approval; the general Lucet section is conditional. Use a Lucet-credentialed, state-qualified supervisor in the same organization; provide disclosure/contact information and obtain consent before care; verify credentials/background. Reconcile current PDF p.73’s entire-session presence condition for intern/provisional billing with §2’s availability wording and the applicable appendix approval before budgeting remote-only oversight; no state exception or modality definition is established. Do not arrange payment from supervisee to supervisor in exchange for supervision; confirm the applicant’s actual state credential fits the plan-approved category. Maintain a physical Alabama practice location/address for each TIN, including telehealth-only arrangements. That location requirement does not reconcile the current general entire-session presence clause with the availability/appendix wording.
Applies to: BCBS Alabama behavioral-health network through Lucet, subject to exact product and member group; do not transfer Florida product decisions or unrelated Alabama APP rules. Sources: regional-10-s1. Current July 2026 PDF p.73 also retains an entire-session presence condition for intern/provisional billing. Applicable reconciliation with §2 availability wording and appendix approval is required before budgeting remote-only oversight; no state exception or modality definition is established.
Verified card/routing references: Blue Cross and Blue Shield of Alabama. A payer ID identifies routing and does not establish clinician eligibility.
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BCBS Illinois
Licensed associate: Illinois LPC/LSW licensed noncredentialed categories may be added to a group and bill using their own rendering NPIs; they are distinct from unlicensed trainees billing through a contracted supervisor.
Unlicensed graduate: An unlicensed graduate must actually qualify as an eligible trainee, such as a postdoctoral fellow; graduation alone does not establish this status.
Student intern: Master’s/doctoral interns can use the formal trainee pathway when working toward clinical state licensure under a fully licensed contracted clinician, with required direct supervision.
Before assigning insured clients: Classify licensed nontrainees separately from unlicensed trainees and complete the applicable group setup. For trainees establish a formal relationship, state-law compliance, direct supervisor accessibility throughout service and applicable trainee limits. Do not implement planned HL until BCBSIL announces implementation; verify the date-of-service notice.
Applies to: Illinois BCBSIL guidance; do not apply to another Blue plan or assume every public-program/FEP product uses this route.
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BCBS Kansas
Licensed associate: The eligible-provider manual rejects incident-to reimbursement and does not make an ineligible psychotherapy practitioner eligible through supervision. Confirm any actual licensed associate category against the eligible-provider list.
Unlicensed graduate: An unlicensed graduate cannot use a supervisor NPI to bypass the manual’s exclusion.
Student intern: Unlicensed psychotherapy practitioners are not reimbursed under the cited manual; supervision does not create eligibility.
Before assigning insured clients: Match the actual clinician category to the manual’s eligible-provider list and applicable benefit before hiring for insured psychotherapy. Do not plan incident-to claims to cure an ineligible practitioner; credential eligible clinicians and establish effective participation separately.
Applies to: BCBS Kansas, not BCBS Kansas City or other Blue licenses. File name says 2025, reviewed PDF is January 2026.
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BCBS Massachusetts
Licensed associate: A public historical BCBS Massachusetts update confirms a mental-health incident-to policy existed and discussed supervisor availability, but it does not establish current covered credentials or product conditions. The detailed current policy is login-restricted.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Obtain the current full mental-health incident-to policy and applicable contract through an authorized plan source; identify the exact license and product. Resolve current supervisor qualifications, availability, enrollment and claim identity before assigning insured clients; the 2022 summary cannot serve as a current filing rule.
Applies to: Historical public update is not current commercial, Medicare or Medicaid permission. ABA modifier references are a different service.
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BCBS Michigan
Licensed associate: Commercial office-based incident-to remains a time-limited pathway: SA from September 1, 2026; office restriction March 1, 2027. Eligible currently contracted practices may pursue the OPC LOI accommodation through September 1, 2027. Qualifying facilities remain separate.
Unlicensed graduate: The notices do not establish eligibility for every unlicensed graduate; match the named category and current setting/transition pathway.
Student intern: Trainees are discussed, but a generic college placement is not a defined eligible category. Establish exact trainee qualifications and setting; do not project office reimbursement beyond the transition.
Before assigning insured clients: Budget hiring against the March 1, 2027 office restriction rather than indefinite supervisor billing. For eligible current practices pursuing OPC, submit the LOI by March 1 and complete enrollment by September 1, 2027; verify actual acceptance and facility requirements. Use SA on applicable incident-to service dates from September 1, 2026 and preserve supervisor/trainee records.
Applies to: BCBSM commercial notice, with BCN/Medicare Advantage distinctions; do not treat the temporary OPC accommodation as universal postponement.
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BCBS New Mexico
Licensed associate: BCBSNM explicitly allows supervisory billing with a formal relationship; the clinic director/supervisor may be rendering when the supervisee is under a trainee license and there is actual direct supervision consistent with state rules.
Unlicensed graduate: Graduation alone is not a documented qualification; verify whether the graduate fits the payer’s trainee-license relationship and state-law scope.
Student intern: The cited guidance does not define every college student as a qualifying trainee. Establish whether this actual student holds the applicable trainee status and lawful scope; do not turn trainee into an automatic student approval.
Before assigning insured clients: Arrange formal supervision and contractual compliance before relying on the trainee exception. Plan direct/personal supervision in the immediate vicinity throughout service; the May 2026 notice states 100% of the time. Resolve modality-specific implementation rather than importing another state’s accessibility interpretation. Use ordinary nontrainee rendering identity when appropriate; do not append planned HL until implementation is announced.
Applies to: BCBSNM local guidance; exact member benefit, state scope and participation contract remain controlling. No nationwide HCSC, FEP, Medicaid or other Blue adoption is established.
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BCBS Oklahoma
Licensed associate: BCBSOK explicitly allows supervisory billing with a formal relationship; the clinic director/supervisor may be rendering when the supervisee is under a trainee license and there is actual direct supervision consistent with state rules.
Unlicensed graduate: Graduation alone is not a documented qualification; verify whether the graduate fits the payer’s trainee-license relationship and state-law scope.
Student intern: The cited guidance does not define every college student as a qualifying trainee. Establish whether this actual student holds the applicable trainee status and lawful scope; do not turn trainee into an automatic student approval.
Before assigning insured clients: Establish actual trainee license, lawful direct supervision, and a real supervisor-supervisee relationship, even if a clinic director is rendering. Arrange accessibility to intervene/join in the delivery modality throughout the service; the FAQ says no outpatient modifier. Retain actual therapist credentials, appropriate signatures and time-based documentation under current RP029; document promptly, normally within 24–48 hours. RP029 is documentation authority, not a new eligibility restriction.
Applies to: BCBSOK local guidance; exact member benefit, state scope and participation contract remain controlling. No nationwide HCSC, FEP, Medicaid or other Blue adoption is established.
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BCBS Oklahoma 00840 route
Licensed associate: BCBSOK explicitly allows supervisory billing with a formal relationship; the clinic director/supervisor may be rendering when the supervisee is under a trainee license and there is actual direct supervision consistent with state rules.
Unlicensed graduate: Graduation alone is not a documented qualification; verify whether the graduate fits the payer’s trainee-license relationship and state-law scope.
Student intern: The cited guidance does not define every college student as a qualifying trainee. Establish whether this actual student holds the applicable trainee status and lawful scope; do not turn trainee into an automatic student approval.
Before assigning insured clients: Establish actual trainee license, lawful direct supervision, and a real supervisor-supervisee relationship, even if a clinic director is rendering. Arrange accessibility to intervene/join in the delivery modality throughout the service; the FAQ says no outpatient modifier. Retain actual therapist credentials, appropriate signatures and time-based documentation under current RP029; document promptly, normally within 24–48 hours. RP029 is documentation authority, not a new eligibility restriction.
Applies to: BCBSOK local guidance; exact member benefit, state scope and participation contract remain controlling. No nationwide HCSC, FEP, Medicaid or other Blue adoption is established.
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BCBS Tennessee
Licensed associate: The BCBST commercial APHCP/incident-to guidance does not establish a therapist associate pathway. A separate TennCare policy permits defined unlicensed master’s-level staff services in a licensed outpatient mental-health agency whose MCO agreement permits the service. BlueCare links that policy, but the commercial card destination cannot automatically become BlueCare.
Unlicensed graduate: For TennCare only, PRO22-002 allows defined unlicensed master’s-level staff in an appropriately licensed mental-health outpatient agency when its MCO contract permits it. Temporary licensure is recommended. This does not establish ordinary commercial group-practice or independent graduate billing.
Student intern: BlueCare separately links PRO22-001 for qualified graduate students. The reviewed PRO22-002 master’s-staff policy is not a student authorization; obtain and apply the actual student policy and MCO arrangement.
Before assigning insured clients: Identify whether the member actually has BCBST commercial or a TennCare/BlueCare product before selecting a policy. For the TennCare branch, verify agency licensure, MCO contract permission, completed degree/discipline, lawful supervision and the policy’s documentation requirements. For students, obtain PRO22-001 rather than applying PRO22-002; for commercial therapists, obtain actual written credential permission instead of copying SA.
Applies to: Commercial BCBST versus BlueCare/TennCare agency services are separate product and setting decisions; no route-based transfer.
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BehavioralHealthServices FurnishedbyUnlicensedMaster'sLevelStaff,PRO22-002Rev3 — pp1–2 sections1–4.2
BCBS Texas
Licensed associate: BCBSTX permits a formal supervisor-trainee relationship; its FAQ expressly permits a clinic director/supervisor as rendering when the supervisee holds a trainee license and there is real direct supervision under state rules.
Unlicensed graduate: A degree without the applicable trainee credential and lawful supervision does not establish this pathway.
Student intern: A student placement without the specified trainee-license status is not established by the FAQ.
Before assigning insured clients: Verify the clinician’s actual trainee license and a direct lawful supervisor relationship. Arrange supervisor accessibility throughout care, including the ability to join in the delivery modality. Verify product participation and applicable service/claim rules; the FAQ states no outpatient modifier.
Applies to: BCBSTX FAQ and Texas context; do not import Illinois’s separate LPC/LSW treatment or expand to every Blue/FEP/public-program product.
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BCBS Wyoming
Licensed associate: BCBS Wyoming’s reviewed public credentialing and generic claim guidance do not establish a provisional therapist or student payment pathway. An indexed independent-practitioner rule and blocked policy access cannot prove all supervised services are prohibited.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Obtain the current credential-specific BCBSWY policy and actual network/benefit agreement; record which provisional credential is accepted and how it is approved. Resolve the approved performer, supervisor identity and enrollment route before configuring claims; generic CMS-1500 field instructions do not supply permission.
Applies to: Exact BCBSWY product and agreement unresolved; no other Blue plan’s policy transfers.
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Credentialing Guidelines — IndexedWhoNeedsCredentialing andApplicantCriteria; directaccessblocked
Blue Cross NC
Licensed associate: Blue Cross NC’s commercial incident-to policy requires physician employment, credential-ineligible auxiliary personnel and a nonfacility setting, but does not name a psychotherapy associate pathway or establish a nonphysician therapist-supervisor exception. SA alone does not answer whether this hire is eligible.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Obtain candidate-specific office psychotherapy approval and qualified-supervisor instructions; test the actual credential against the policy’s auxiliary/credential-eligible distinction. Do not substitute PHP/IOP/RTC facility per-diem staffing rules for office psychotherapy coverage.
Applies to: Commercial nonfacility incident-to differs from facility behavioral-health programs; no inferred Medicaid or Medicare adoption.
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BundlingGuidelines — IncidentToServices;Application;historyJuly15,2026
FacilityBehavioralHealth — Description,perdiemguidelines,Application
Blue Cross of Idaho
Licensed associate: PAP900 expressly provides a pathway for Idaho LMSW, LPC, LAMFT and LPA clinicians, through an actual direct contract or an enrolled sponsored-extender arrangement. The possibility of direct contracting is not confirmation that this applicant has a contract.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Determine whether the candidate will have a direct contract or sponsored-extender enrollment, and complete the enrollment packet and performing-provider designation. For sponsorship, use an eligible MD, DO, psychologist, LCSW, LMFT or LCPC; the last three need required supervisory credentials. Verify state scope and supervision. Load the billing and performing NPIs correctly; generic electronic claim instructions supplement, rather than create, extender eligibility.
Applies to: PAP900 contract and covered-service conditions; no automatic adoption by Regence BlueShield of Idaho, BlueCard home plans, Medicare or Medicaid.
Verified card/routing references: Blue Cross of Idaho. A payer ID identifies routing and does not establish clinician eligibility.
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PAP247 Covered Providers — Service extenders; Covered providers; Non-covered providers
Blue Shield of California
Licensed associate: The March 2026 transition FAQ permits associate therapy supervised by a licensed therapist for commercial and Medi-Cal members when Blue Shield is financially responsible. It expressly excludes Medicare Advantage. Associates are rostered rather than directly contracted.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Verify financial responsibility for the member and the practice’s contracted product participation; delegated HMO claims go to the assigned IPA/group. Place the associate on the required roster and arrange licensed-therapist supervision; associates are not directly contracted. Confirm supervisor billing configuration without guessing the rendering-field NPI; resolve candidate credential and any telehealth combination before scheduling.
Applies to: Q75 commercial/Medi-Cal where Blue Shield bears financial responsibility; Medicare Advantage excluded. Delegated IPA/group arrangements require their own authority.
Verified card/routing references: Blue Shield of California. A payer ID identifies routing and does not establish clinician eligibility.
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Capital Blue Cross
Licensed associate: Capital’s 2026 manual requires practitioners to be credentialed, approved and added to the agreement’s Exhibit B. Its use of associated providers describes a contractual relationship, not permission for LAPC or LAMFT license holders. A current associate-specific psychotherapy pathway was not established.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Resolve the applicant’s exact license eligibility with Capital and secure approval, credentialing and addition to Exhibit B as applicable before covered services. Use Capital’s own member benefit and provider agreement; Highmark and Independence associate policies are separate payer decisions.
Applies to: Capital agreement and member product; PA geography does not import Highmark or IBX rules.
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CareFirst Maryland
Licensed associate: CareFirst offers supervisory credentialing for listed graduate/associate categories after completion of master’s requirements, with an appropriate independently licensed, actively credentialed/contracted supervisor. Application is not approval.
Unlicensed graduate: A completed graduate degree alone is insufficient; match a listed license/registration category and complete supervisory credentialing.
Student intern: Ordinary students still completing the required graduate education are not established by this supervised-credentialing section.
Before assigning insured clients: Match category and supervisor pairing in the profession table. Complete CAQH, authorize CareFirst access and submit its online questionnaire. Confirm approval, group affiliation, geography/product and effective participation date before assigning in-network visits.
Applies to: Manual section concerns listed categories and jurisdictional credentials; do not generalize across Maryland, Virginia, DC or every CareFirst product.
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Cigna / Evernorth
Licensed associate: Evernorth permits supervisee professional services as state licensing regulations allow, with a fully credentialed provider reported as rendering. Fully licensed clinicians retain separate credentialing requirements.
Unlicensed graduate: An unlicensed graduate can fit state-permitted supervisee services; confirm lawful scope, actual supervision and the applicable product/participation arrangement.
Student intern: The cited general supervisee provision does not establish student-intern eligibility. Obtain a category- and product-specific Evernorth determination; state permission and a school placement alone are insufficient.
Before assigning insured clients: Verify the actual clinician’s lawful supervised practice and service scope, including any student educational placement conditions. Use the fully credentialed provider and establish applicability of the Evernorth professional-services section to the product. Reassess independent credentialing when full licensure is earned.
Applies to: September 2026 Evernorth administrative guidelines, professional services p.46; no automatic adoption for every Cigna-logo EAP, public-program or employer benefit.
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ConnectiCare
Licensed associate: ConnectiCare Medicare delegation to Optum does not establish commercial supervisory permission; assess the actual product separately. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: No student pathway is established for ConnectiCare Medicare by the commercial Optum protocol. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Treat the Medicare manual as Medicare evidence; obtain separate commercial/exchange adoption before applying Optum U5 supervisory billing.
Applies to: The 2026 Medicare manual identifies Optum BH coordination and BH paper routing. This is affirmative Medicare delegation, not evidence that the Optum commercial U5 supervision protocol governs these members. Stedi YCFYQ maps to101259 and is labeled Medicare, with multiple aliases. A clearinghouse directory label cannot establish an individual member product/state or grant commercial supervision permission. Retain accepted Optum mapping only when applicable commercial/exchange administration is independently established: supervisor24J/2310B; DQ17/17b/2310D; U5; solo supervisor or group33/33a. Five-state July2026 eligibility, minimum master's/training/state scope (QRGp7), E/M exclusion (policyp3QA4), ABA/entity/nonroutine exclusions remain. Medicare-specific rules require separate assessment. Medicare benefit delegation does not prove commercial supervised telehealth applicability or a member-specific combination of state/contract modifiers. When commercial2020RP503A applies, p2 member-location POS02/10 in24B; video93/95/GT informational. QA3p3 requires93 with02/10 for covered audio-only, FQ limited FQHC/RHC. QA7p4 conditions audio-only on mandate/benefit. These rules do not apply automatically to2026 ConnectiCare Medicare members or independently establish supervised associate eligibility.
Verified card/routing references: 101259. A payer ID identifies routing and does not establish clinician eligibility.
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2026 Medicare Provider Manual — pp.5–6,55
ConnectiCare Provider Orientation December 2025 — p.25 Behavioral Health
Help & Support — Commercial / Behavioral Health Program lines 15–28; most plans; footer 9/24
Billing and Claims — public billing resource hub
Denver Health Medical Plan
Licensed associate: DHMP publishes a 2026 supervisory billing notice and suggested identity fields, but the reviewed evidence does not bind a particular candidate license and product to payment. Its public contracting page says the network is closed to new contract agreements; an existing-group situation still requires its own determination.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Establish whether an existing agreement can add this applicant; the closed-new-contract notice does not by itself decide an existing-group addition. Obtain credential/product acceptance and document the actual supervision arrangement before scheduling insured services.
Applies to: DHMP’s actual product and existing contract; suggested claim syntax does not prove all candidate credentials are payable.
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Provider Manual 2026 — pp.7–8, Supervisory Billing Notice; CMS-1500; Documentation
Excellus BCBS
Licensed associate: Excellus’s nonphysician application lists LMSW and requests practitioner NPI and group/collaborating-physician information. That is useful enrollment evidence, but it does not establish which LMSW psychotherapy services are covered or whether an LCSW can replace the form’s physician role.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Resolve the precise LMSW psychotherapy benefit and permissible collaborating/supervising professional under the actual agreement; do not replace the application’s physician with an LCSW by assumption. Complete approved practitioner/group enrollment and obtain the applicable claim-identity instructions before insured assignments.
Applies to: Excellus application category does not establish all commercial products, Medicare or Medicaid payment.
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Tips for Completing the CMS-1500(2.12)Form — Fields17/17b,24J and33a; actual4pagePDF
Florida Blue
Licensed associate: Florida Blue PPO and the named county-specific HMO entries approve interns/provisionally licensed professionals subject to benefits. FEP, Medicare Preferred HMO and named employer exceptions are not approved; the PPO entry excludes Medicare Advantage. The current general entire-session presence clause must be reconciled with availability/appendix wording before budgeting remote-only oversight.
Unlicensed graduate: A degree alone does not establish the required state credential/registration or plan-approved provisional category. The manual does not supply blanket approval for unregistered graduates.
Student intern: The manual uses intern alongside applicable state licensure/registration and degree-based coding. It does not expressly establish college practicum placements. A registered post-graduate intern must not be treated as equivalent to an actual student.
Before assigning insured clients: Identify the exact plan/product and employer appendix before relying on approval; the general Lucet section is conditional. Use a Lucet-credentialed, state-qualified supervisor in the same organization; provide disclosure/contact information and obtain consent before care; verify credentials/background. Reconcile current PDF p.73’s entire-session presence condition for intern/provisional billing with §2’s availability wording and the applicable appendix approval before budgeting remote-only oversight; no state exception or modality definition is established. Do not arrange payment from supervisee to supervisor in exchange for supervision; confirm the applicant’s actual state credential fits the plan-approved category. Check Tampa General Hospital and Polk County Public Schools exclusions even if the routing ID is 00590; confirm county-labelled HMO applicability.
Applies to: PPO and the Hillsborough/Palm Beach HMO entry are scoped approvals; FEP/Medicare Preferred and Tampa General Hospital/Polk County Public Schools are explicit nonapprovals. No statewide HMO or MA permission. Sources: regional-11-s1, regional-11-s2. Current July 2026 PDF p.73 also retains an entire-session presence condition for intern/provisional billing. Applicable reconciliation with §2 availability wording and appendix approval is required before budgeting remote-only oversight; no state exception or modality definition is established.
Verified card/routing references: Florida Blue; 00590. A payer ID identifies routing and does not establish clinician eligibility.
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Freedom Life
Licensed associate: Associate eligibility is unestablished; confirm a covered mental-health benefit first, since the cited historical Ohio product excludes it. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Student eligibility is unestablished; the historical Ohio exclusion does not establish every Freedom Life product’s benefits. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Read the current member certificate and riders for an actual mental-health benefit; the Ohio Health & Wellness PLUS exclusion is a limited historical product example.
Applies to: Official Ohio SecureAdvantage brochure identifies Freedom Life as underwriter and contains a Health & Wellness PLUS exclusion for diagnosis/care/treatment of mental/emotional disorders and alcohol/drug abuse. This older form-specific example proves coverage must be checked before supervisor billing; it does not prove all62324 products exclude BH or that this form governs a current member. Exact62324 route is confirmed, but current member certificate/riders/state and covered BH benefit are unknown. No supervised-license contract, enrollment or field mapping established.
Verified card/routing references: 62324. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
Geisinger Health Plan
Licensed associate: Geisinger explicitly directs Pennsylvania LSWs, LAPCs and LAMFTs to its incident-to process rather than independent directory listing/billing. It cites CMS section 60; establish a qualifying supervising practitioner and all arrangement conditions rather than assuming any licensed supervisor works.
Unlicensed graduate: The notice does not establish permission for a graduate without the named state credential.
Student intern: The notice addresses licensed categories, not a generic student intern.
Before assigning insured clients: Verify the hire’s actual Pennsylvania LSW/LAPC/LAMFT credential and proposed supervision. Resolve incident-to practitioner, initial professional service, treatment plan, continuing involvement and actual product requirements before scheduling under this route. Plan independent empanelment after the required training, supervised hours and professional licensure are completed.
Applies to: Notice is tagged All plans, but its CMS reference is not a universal declaration that every therapy supervisor has a Medicare incident-to benefit. Resolve product, practitioner and setting; do not silently promise Medicare Advantage/Medicaid payment.
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Harvard Pilgrim
Licensed associate: The July 2026 Point32Health commercial BH policy expressly considers supervised practitioners and clinicians pursuing licensure for reimbursement when billed by a credentialed, participating supervisor. Implement the policy’s supervision, disclosure, consent and documentation requirements.
Unlicensed graduate: A graduate pursuing licensure can fit the stated supervised-clinician pathway, subject to lawful scope, participating supervisor, covered services and contract requirements. A degree without that arrangement is insufficient.
Student intern: The modifier table includes HL (intern), but the policy does not define every eligible student placement. Do not infer that every pre-degree student qualifies from the modifier alone; confirm the specific program, credential and lawful service scope.
Before assigning insured clients: Confirm the member is in a checked commercial product and the supervisor is credentialed and participating. Document the supervisory relationship, screening protocols, patient disclosure, supervisor contact information and written treatment consent. Obtain group/supervisor loading instructions using the BH enrollment process; generic CAQH forms do not prove that every supervisee requires independent credentialing. Obtain precise renderer/supervisor field instructions and the appropriate supervisee-level modifier; do not import NP/PA SA.
Applies to: Harvard Pilgrim commercial products covered by the policy’s applicability grid. Tufts Health Direct, Together, RITogether, One Care and senior products are not checked. Harvard Pilgrim Passport administration must be separately resolved.
Verified card/routing references: Harvard Pilgrim Health Care. A payer ID identifies routing and does not establish clinician eligibility.
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Behavioral Health providers — joining networks — forms and CAQH enrollment requirements
Billing and Reimbursement — Claims Submissions — printed F.5 generic group/individual NPI table
Health Alliance Illinois
Licensed associate: Health Alliance ceased all lines of business January 1, 2026; prior coverage ended by December 31, 2025. It is not a current new-hire patient-panel opportunity. Pre-2026 services still require legacy claim/runout review rather than an assumption they cannot be paid.
Unlicensed graduate: Current new-hire coverage is not available under the cessation announcement; historical graduate services remain a separate unresolved claim question.
Student intern: No current Health Alliance insured panel is established after cessation. Student services for a historical date require separate date-specific evidence.
Before assigning insured clients: For legacy patients, establish the actual pre-2026 service date, coverage and provider agreement before reviewing claims. Preserve runout instructions and portal access dates; provider FAQ says contracts terminated January 1, 2026 and portal access ends December 31, 2026.
Applies to: All ceased lines versus pre-January 2026 runout; historical credentialing list is not a live 2026 participation offer.
Verified card/routing references: Health Alliance. A payer ID identifies routing and does not establish clinician eligibility.
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Health Alliance cessation announcement — Announcement and priorcoverage paragraph
Basic Credentialing Documentation Needed — p1 LPC/LSW and allied practitioners
Highmark Pennsylvania
Licensed associate: Current RP068 expressly includes PA commercial LAMFT, LAPC and LSW services, when covered, with the actual licensed clinician as rendering. This is an own-NPI enumeration pathway; the withdrawal of commercial incident-to billing does not erase it.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Secure the clinician’s completed enumeration and confirmation; use the PA commercial APP process and fully executed group contract for affiliation. Verify lawful licensed supervision and the actual member benefit/contract before assigning patients. Budget against the policy’s 75% fee-schedule category unless a contract-specific exception governs; confirm the clinician is welcomed into the intended group affiliation.
Applies to: Pennsylvania commercial only for this associate answer. RP068’s WV column is Medicare Advantage, and PA MA does not list LAMFT/LAPC/LSW as the PA commercial grid does. November 2026 RP010 is future guidance.
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Highmark West Virginia
Licensed associate: The reviewed Highmark sources do not establish a West Virginia commercial provisional-therapist pathway. RP068’s WV grid is Medicare Advantage, whereas its commercial scope lists PA, DE and NY. This evidence gap is not a prohibition on every form of supervised licensed care.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Obtain the WV commercial policy and actual agreement naming the applicant’s permitted credential and enrollment route; do not submit using PA eligibility. For an MA patient separately verify Medicare-recognized credential, enrollment and benefit coverage; the WV MA grid cannot authorize a commercial provisional clinician.
Applies to: WV commercial is unresolved; PA commercial and WV Medicare Advantage remain distinct.
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Horizon New Jersey
Licensed associate: Horizon’s supervised-practitioner policy supports a conditional New Jersey supervised pathway with a board-approved supervision plan and the named contracted, credentialed supervisor in the member’s network. The actual approved credential and plan must be matched; HO does not authorize an otherwise ineligible hire.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Verify the applicant’s actual credential is within Horizon’s policy and secure the state-board-approved supervision plan naming the eligible supervisor. Ensure the supervisor is contracted, credentialed and in the member’s network before assigning Horizon patients. Before service, implement Horizon’s screening, assessment and assignment protocols for supervised care; disclose the supervisory relationship, provide the supervisor’s contact details, obtain the member’s written consent and document the required information and consent in the member’s chart. Apply these conditions within the actual named credential and board-approved state supervision-plan scope. Configure supervisor rendering and HO according to payer policy; verify NPI/tax ID and obtain missing electronic or telehealth-specific directions. Confirm the actual member product and exclude Braven Health Medicare Advantage, coordination-of-benefits cases and Horizon-secondary-to-Medicare products from this policy pathway.
Applies to: The policy covers insured and ASO accounts, including SHBP and SEHBP. It expressly excludes Braven Health Medicare Advantage, coordination-of-benefits cases and products where Horizon is secondary to Medicare, such as Medigap. Do not infer adoption by Horizon NJ Health, FEP or another product from a shared brand or New Jersey license.
Verified card/routing references: Horizon Blue Cross Blue Shield of New Jersey. A payer ID identifies routing and does not establish clinician eligibility.
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Professional claim submission instructions — Claim preparation; NPI and taxID paragraphs
Independence Blue Cross
Licensed associate: IBX permits commercial supervised LSW/LMSW, LAMFT and LAPC services under its contracted, credentialed supervisor pathway. It requires member disclosure and written consent, AJ and candidate training verification. The pathway continues after passing the independent exam while IBX credentialing is pending.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Use a contracted, credentialed and legally qualified IBX supervisor; screen, assess and assign patients appropriately and verify the clinician’s education/training. Disclose supervision, provide supervisor contact information and obtain the member’s written consent before treatment. Verify commercial benefit applicability, register NPI/trading-partner affiliation for electronic claims and keep the supervised pathway until credentialing is completed.
Applies to: Commercial only; excludes Medicare Advantage, IBX secondary coverage and cases with coordination of benefits. Employer behavioral-health administration must be checked.
Verified card/routing references: Independence Blue Cross. A payer ID identifies routing and does not establish clinician eligibility.
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Innovation Health
Licensed associate: If the Innovation Health member agreement adopts the applicable Aetna commercial supervisory standard, qualified license-eligible clinicians may bill through an eligible in-network supervisor. Innovation’s provider page links its manual to Aetna contracts; exact member agreement adoption still needs confirmation.
Unlicensed graduate: Under the adopted Aetna standard, graduates with completed education who are accruing independent-license hours and receiving regular qualified supervision can qualify; a provisional license is not universally prescribed by the bulletin, but state requirements still apply.
Student intern: The Aetna standard requires completion of all education for the target license; a student still completing that education does not fit this pathway.
Before assigning insured clients: Confirm actual Innovation contract adoption, member benefits and in-network arrangement. Use a supervisor employed by the same group/facility, independently licensed and actively credentialed/contracted; arrange supervision proportionate to caseload. Verify contract execution/system loading for contracted-rate claims; the Virginia general credentialing paragraph is not itself a trainee exception. List the licensed supervisor as rendering clinician under the adopted standard; resolve additional required fields and telehealth separately.
Applies to: Conditional Innovation Health commercial agreement adopting Aetna standard; not automatic from payer 40025 and not Aetna EAP.
Verified card/routing references: Innovation Health; 40025. A payer ID identifies routing and does not establish clinician eligibility.
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Provider manual State Supplement — printedp41 Virginia; cover7/26, manual hubAugust2026
Kaiser Colorado
Licensed associate: Kaiser Colorado identifies Carelon for Northern/Southern Colorado HMO behavioral-health network access. That concrete branch does not establish LPCC/MFTC/SWC payment. Carelon’s Colorado addendum is Anthem-specific and cannot authorize Kaiser associates.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Identify HMO geography, member product and actual Kaiser/Carelon agreement; do not assign a candidate using an Anthem-only addendum. Obtain current candidate acceptance, enrollment and claim-role requirements; public access-plan links labelled 2026 retrieved 2025 editions.
Applies to: Carelon access for named Colorado HMO regions is not all Kaiser Colorado products or adoption of Anthem rules.
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First Quarter2026 Provider Insider — 4 pages, contents and updates; no supervisory billing
Q3 2023 newsletter — p.11 Colorado Kaiser network status; older supplemental lead only
Kaiser Northern California
Licensed associate: Kaiser Northern California’s KP Direct outpatient network and professional-group roster rules do not establish external AMFT/APCC/ASW or psychological-associate psychotherapy eligibility. Carelon-referred patients are a separate claim branch; Lucet’s referral platform does not establish Lucet payment-policy adoption.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Identify KP Direct versus an actual Carelon referral and use the corresponding agreement; technology platform does not select payment policy. Maintain the required professional-group roster and credentialing approval as applicable; the notice exempts some license/certificate types, so obtain the candidate-specific determination. For Medi-Cal, use the relevant supplement and actual service category; screening/BHT staffing language is not a supervised psychotherapy approval.
Applies to: KP Direct, Carelon-referred outpatient services and Medi-Cal are distinct; Washington associate policy and Lucet general manual do not transfer.
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Northern California Provider Information — Provider manuals and 2026 Medi-Cal supplement
Q3 2025 newsletter — p.15 Northern California: Submitting Claims to Carelon
Kaiser Northwest
Licensed associate: Kaiser Northwest’s external commercial materials do not establish associate eligibility. An internally marked Medicare FAQ discusses unlicensed associate trainees under direct supervision, but cannot establish a current external commercial hiring pathway or 2026 patient-video rule.
Unlicensed graduate: An internal Medicare FAQ discusses unlicensed associate trainees; its audience, product and supervision/time-period boundaries prevent treating it as a current external commercial graduate-billing approval.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Identify Northwest member product and external-provider agreement, and obtain a current credential-specific authorization for the candidate. Keep Dual Choice PPO payer identifiers in their actual table roles; do not use Northwest routing or Washington’s policy to establish candidate permission.
Applies to: Northwest commercial/external-provider status distinct from internal Medicare guidance and Washington regional policy.
Verified card/routing references: 21313; 93079; 100178. A payer ID identifies routing and does not establish clinician eligibility.
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Kaiser Foundation Health Plan Northwest — Primary100178; aliases include93079; website and837P
Northwest Mental Health — Public mental-health page; no associate policy found
Kaiser Washington
Licensed associate: Kaiser Washington commercial expressly supports supervised LMFTA, LMHCA and LICSWA services, billed by a qualified provider while preserving the associate’s rendering name/NPI. The policy’s FAQ contains a broad nonpayable sentence; the July 2025 reminder corroborates supervised reimbursement but is not an explicit erratum.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Verify the Washington commercial product and qualified credentialed supervisor; referrals go to the supervisor, as associates do not qualify for direct credentialing/referrals. Have the treating associate disclose associate status and approved supervision at first professional contact. Resolve associate loading, group/supervisor billing identity and FAQ inconsistency in writing; budget using 85% of applicable physician schedule unless otherwise contracted with a nonphysician schedule.
Applies to: Washington and Washington Options commercial only; Medicare/Medicaid unselected. No transfer to Northwest, Colorado or Northern California.
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Associate Level Mental Health Care — pp.1–3, Scope, Policy, Prerequisites, FAQ, Revision History
July 2025 Provider eNews — p.2 Reminder regarding Associate Level Mental Health Care reimbursements
Moda Health
Licensed associate: Moda RPM079 permits approved associates/residents employed by a directly contracted entity in Oregon/Idaho commercial arrangements, outside State Approved Programs.
Unlicensed graduate: A graduate may qualify only through the defined board-approved supervised-practice category, employment and Moda program approval.
Student intern: The program definitions require the completed master’s or doctoral degree. A predegree student is outside this pathway; SAP arrangements are separate.
Before assigning insured clients: Ensure contract language authorizes supervised providers, not just ordinary group participation. Submit roster and contracted-entity attestation and wait for actual program loading/effective approval; 30–45 days is the stated processing estimate. Budget the reduced program allowance; notify Moda and submit credentialing within 60 days after full licensure.
Applies to: Directly contracted Oregon/Idaho commercial program; SAP/COA providers are expressly separate.
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Oscar Health
Licensed associate: Oscar’s April 2026 manual delegates behavioral health to Optum. Under Optum’s July 2026 policy, the supervised-services pathway applies in California, Colorado, Hawaii, Iowa and Massachusetts (CA, CO, HI, IA, MA); in other states, Optum must have previously approved the arrangement. The member’s commercial or exchange benefit and the provider agreement must be governed by this policy; Oscar’s delegation alone does not establish eligibility. This pathway excludes ABA, nonroutine services and services provided by state-licensed entities; supervised E/M services are also excluded.
Unlicensed graduate: A nonlicensed master’s graduate may qualify with required training, lawful scope and supervision under the applicable commercial/exchange member and provider agreement. Under Optum’s July 2026 policy, the supervised-services pathway applies in California, Colorado, Hawaii, Iowa and Massachusetts (CA, CO, HI, IA, MA); in other states, Optum must have previously approved the arrangement. This pathway excludes ABA, nonroutine services and services provided by state-licensed entities; supervised E/M services are also excluded. Graduation alone is insufficient.
Student intern: Optum’s guide requires at least a master’s degree for nonlicensed BH clinicians. A student still earning that degree does not fit this route; an advanced student who already holds it still must meet all training, state and contract requirements.
Before assigning insured clients: Confirm the applicable Oscar commercial/exchange member benefit and provider agreement. Under Optum’s July 2026 policy, the supervised-services pathway applies in California, Colorado, Hawaii, Iowa and Massachusetts (CA, CO, HI, IA, MA); in other states, Optum must have previously approved the arrangement. Establish previous Optum approval before relying on this pathway outside those five states. The April 2025 QRG geography is incomplete relative to the July 2026 policy; this is not a newer state exclusion. Validate supervisee degree/training/state scope and supervisor eligibility before assigning covered routine outpatient services. This pathway excludes ABA, nonroutine services and services provided by state-licensed entities; supervised E/M services are also excluded. Confirm the intended service and entity are within scope before assigning clients. Configure the documented U5 and supervisor claim fields only after applicability is established; apply telehealth rules separately.
Applies to: Oscar BH delegation to Optum, conditional on the applicable commercial/exchange member benefit and provider agreement. Under Optum’s July 2026 policy, the supervised-services pathway applies in California, Colorado, Hawaii, Iowa and Massachusetts (CA, CO, HI, IA, MA); in other states, Optum must have previously approved the arrangement. This pathway excludes ABA, nonroutine services and services provided by state-licensed entities; supervised E/M services are also excluded. OSCAR medical routing does not establish this permission.
Verified card/routing references: Oscar Health; OSCAR. A payer ID identifies routing and does not establish clinician eligibility.
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Peak Health
Licensed associate: Peak Health here is the West Virginia-based insurer/administrator linked to peakhealth.org, not Colorado Peak Health Alliance. The reviewed ASO/MA manuals and bounded public policy discovery do not establish associate psychotherapy eligibility or an explicit exclusion.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Match the exact insurer/administrator and ASO or MA product before requesting candidate-specific covered-provider determination. Obtain current credential eligibility, supervision and enrollment requirements through an authorized policy/contract source; unauthenticated library bootstrap failure is not a prohibition.
Applies to: West Virginia-based Peak institution, ASO and MA separate; directory geography is not clinical coverage.
Verified card/routing references: Peak Health; PEAK0. A payer ID identifies routing and does not establish clinician eligibility.
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Peak Health payer directory — WKNCM primaryPEAK0; websitepeakhealth.org; aliases and other names
Public client bootstrap resources — Unauthenticated GET
Provider Manuals — 2026 ASO/MA manual links; footer insurer WV and TPA WV/PA/KY
Public policy library — DocTract policy listing
Premera Washington
Licensed associate: Premera Washington permits associate billing with the associate as rendering; network status follows the billing TIN. Associate license pending claims are accepted for up to 120 days from the policy introduced October 1, 2025.
Unlicensed graduate: A graduate must fit the associate or supported pending-license status; completed education alone is not sufficient.
Student intern: The associate FAQ does not establish ordinary student eligibility. RAAC agency provisions are a separate credentialed-agency pathway, not a private-practice student permission.
Before assigning insured clients: Confirm associate license/pending status and the group TIN’s network participation. Add the associate through claim receipt or provider-update request; determine individual timing of any 120-day pending allowance. Use the associate rendering NPI and apply for full credentialing once independent licensure is active.
Applies to: Washington associate FAQ; agency-affiliated counselor rules require a credentialed behavioral health agency and are separate.
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Priority Health
Licensed associate: Priority permits specified limited-license services for commercial and Medicaid members under matched fully licensed/credentialed supervisors; these services are excluded for Medicare Advantage.
Unlicensed graduate: An unlicensed graduate without a named limited-license credential is not established by this manual.
Student intern: The limited-license route does not establish an unlicensed student benefit.
Before assigning insured clients: Verify the limited license and discipline-matched supervisor before assigning members. Document supervisor review of each visit’s notes within one week. Separate commercial/Medicaid from excluded Medicare Advantage and configure the category-specific modifier.
Applies to: Priority commercial/Medicaid limited-license route; Medicare Advantage is explicitly excluded.
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Providence Health Plan
Licensed associate: Providence RP5 requires directly eligible commercial practitioners to bill their own work under their own NPI, even when supervised. Its auxiliary-personnel exception does not name a current psychotherapy associate pathway, so the rule establishes neither blanket associate permission nor blanket associate exclusion.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Determine whether the candidate is recognized for direct claims or is in an allowed auxiliary category under the actual contract; an NPI alone settles neither. Obtain candidate-specific supervision and billing confirmation before insured assignment; RP5 direct/general BH supervision references need arrangement-specific resolution. Identify Providence product and any YCCO involvement separately; the provider hub records YCCO’s internal-management transition rather than a transferable associate authorization.
Applies to: Providence commercial versus Medicare Advantage/OHP and YCCO; no route-based product or associate approval.
Verified card/routing references: Providence Health Plan; PHP01. A payer ID identifies routing and does not establish clinician eligibility.
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Regence Idaho
Licensed associate: Regence BlueShield of Idaho expressly supports board-registered master’s/doctoral licensure-track behavioral-health associates and state-qualified LMSWs under its Adm148 exception. A qualified licensed, credentialed supervisor must be in the same group and have equal or greater education. This is a documented eligibility pathway despite incomplete claim-field mapping.
Unlicensed graduate: A graduate who has the required state-board registration and formal licensure track can fit the policy even before independent licensure. A degree-only, unregistered graduate is not established as eligible. This is not permission for unlicensed practice prohibited by state law.
Student intern: The policy names completed graduate preparation and state board registration/formal licensure track. It does not establish a pre-degree student placement benefit.
Before assigning insured clients: Verify completed qualifying degree, active board registration/formal licensure track or LMSW status, lawful state scope and actual product coverage. Use a licensed, credentialed same-group supervisor with equal/higher education; document treatment review, meetings and consultation availability. For an Idaho LMSW, arrange a clinical supervision plan and at least half of clinical supervision with an LCSW; current DOPL guidance does not require supervisor registration. Resolve any roster/advance approval and exact claim-role allocation; prepare SA service-line reporting and supervisor name/identification without inventing rendering-field placement.
Applies to: Regence Adm148 labels commercial and Medicare Advantage; commercial supervisor examples do not establish every Medicare-recognized role or service. State law and contract remain separate.
Verified card/routing references: Regence BlueShield of Idaho; 00611. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Behavioral health providers — Claims & reimbursement; FEP contact distinctions
Supervision and Supervisor Information — LMSW clinical-supervision FAQ
Regence BlueShield of Idaho payer directory — Payer name, primary payer ID and website
1500 Reference Instruction Manual version13 — pp.2,26–27,44,55
Regence Oregon
Licensed associate: Regence BlueCross BlueShield of Oregon expressly supports board-registered master’s/doctoral licensure-track behavioral-health associates and state-qualified LMSWs under its Adm148 exception. A qualified licensed, credentialed supervisor must be in the same group and have equal or greater education. This is a documented eligibility pathway despite incomplete claim-field mapping.
Unlicensed graduate: A graduate who has the required state-board registration and formal licensure track can fit the policy even before independent licensure. A degree-only, unregistered graduate is not established as eligible. This is not permission for unlicensed practice prohibited by state law.
Student intern: The policy names completed graduate preparation and state board registration/formal licensure track. It does not establish a pre-degree student placement benefit.
Before assigning insured clients: Verify completed qualifying degree, active board registration/formal licensure track or LMSW status, lawful state scope and actual product coverage. Use a licensed, credentialed same-group supervisor with equal/higher education; document treatment review, meetings and consultation availability. Maintain active Oregon associate registration and a board-approved practice plan. The board may permit an outside supervisor, but that does not satisfy Regence’s same-group requirement. Resolve any roster/advance approval and exact claim-role allocation; prepare SA service-line reporting and supervisor name/identification without inventing rendering-field placement.
Applies to: Regence Adm148 labels commercial and Medicare Advantage; commercial supervisor examples do not establish every Medicare-recognized role or service. State law and contract remain separate.
Verified card/routing references: Regence BlueCross BlueShield of Oregon; 00851. A payer ID identifies routing and does not establish clinician eligibility.
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Behavioral health providers — Claims & reimbursement; FEP contact distinctions
Associate Registration — Registered Associate Supervision / Place of Practice
Regence BlueCross BlueShield of Oregon payer directory — Payer name, primary payer ID and website
1500 Reference Instruction Manual version13 — pp.2,26–27,44,55
Regence Washington
Licensed associate: Regence BlueShield of Washington expressly supports board-registered master’s/doctoral licensure-track behavioral-health associates and state-qualified LMSWs under its Adm148 exception. A qualified licensed, credentialed supervisor must be in the same group and have equal or greater education. This is a documented eligibility pathway despite incomplete claim-field mapping.
Unlicensed graduate: A graduate who has the required state-board registration and formal licensure track can fit the policy even before independent licensure. A degree-only, unregistered graduate is not established as eligible. This is not permission for unlicensed practice prohibited by state law.
Student intern: The policy names completed graduate preparation and state board registration/formal licensure track. It does not establish a pre-degree student placement benefit.
Before assigning insured clients: Verify completed qualifying degree, active board registration/formal licensure track or LMSW status, lawful state scope and actual product coverage. Use a licensed, credentialed same-group supervisor with equal/higher education; document treatment review, meetings and consultation availability. Use approved Washington supervision; associates may not independently provide services for a fee. Resolve any roster/advance approval and exact claim-role allocation; prepare SA service-line reporting and supervisor name/identification without inventing rendering-field placement.
Applies to: Regence Adm148 labels commercial and Medicare Advantage; commercial supervisor examples do not establish every Medicare-recognized role or service. State law and contract remain separate.
Verified card/routing references: Regence BlueShield; 00932. A payer ID identifies routing and does not establish clinician eligibility.
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Behavioral health providers — Claims & reimbursement; FEP contact distinctions
Mental Health Counselor FAQ — What is an associate / independent services / progress notes
Regence BlueShield of Washington payer directory — Payer name, primary payer ID and website
1500 Reference Instruction Manual version13 — pp.2,26–27,44,55
Select Health
Licensed associate: Select Health Policy #3 FAQ permits provisionally licensed clinicians’ subsequent incident-to care when a credentialed/contracted clinician actually performs the initial evaluation and controls official plan changes; enforcement begins January 1, 2027.
Unlicensed graduate: A graduate without provisional licensure does not qualify merely through supervision; do not treat existing-patient grandfathering for provisional clinicians as an unlicensed-provider waiver.
Student intern: Unlicensed students do not qualify under the FAQ’s provisional-provider incident-to route.
Before assigning insured clients: Have a credentialed/contracted provider perform the initial evaluation; later chart review cannot replace it. Arrange general mental-health supervision and supervisor responsibility for official plan changes. Inventory January 1, 2027 transitions: provisional existing-patient grandfathering versus unlicensed cases requiring a new qualified evaluation and a valid ongoing care route.
Applies to: Select Health Policy #3 FAQ; confirm full policy/product. Fully licensed enrollment-pending clinicians have separate out-of-network considerations.
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Sentara Health Plans
Licensed associate: Sentara’s commercial manual expressly permits Residents in Counseling and Supervisees in Social Work under their clinical supervisor, with services limited to populations for which that supervisor is credentialed.
Unlicensed graduate: A graduate may qualify after obtaining the board-approved residency/supervisee arrangement described by the manual. An unregistered graduate is not established as eligible.
Student intern: The resident/supervisee section does not establish a general student internship pathway. Its mention of educational-facility oversight does not make every pre-degree student an eligible resident.
Before assigning insured clients: Verify board-approved status, supervisory contract and supervisor credentials for the intended populations. Arrange supervision responsibility, required participation, documentation and note review under licensing/educational oversight requirements. Confirm group loading and product panels without assuming the generic add-provider form requires independent credentialing for every resident. Use the supervisor’s individual NPI as renderer; resolve additional filing/telehealth requirements for psychotherapy separately.
Applies to: Sentara commercial manual pathway, not blanket Sentara Medicaid/Medicare or every associate discipline. Offsite supervision is contemplated; telehealth claims still need their own rules.
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Provider Updates March31,2026 — p.2 Telehealth Audio Only—Modifier93
St. Luke’s Health Plan
Licensed associate: St. Luke’s permits incident-to only when the professional is ineligible for its credentialing; credential-eligible professionals cannot use that route. The reviewed sources do not classify each therapist-associate license, so a specific candidate’s payable pathway remains unresolved.
Unlicensed graduate: A graduate degree without the required license or registration does not establish eligibility under the reviewed sources. Obtain a candidate-specific covered-provider determination before budgeting insured visits.
Student intern: The reviewed sources do not establish payment for an actual student placement. A graduate or licensed-associate provision cannot be applied to a student solely because the practice calls the role an intern.
Before assigning insured clients: Obtain the candidate’s exact credentialing eligibility determination; do not assume lack of current credentialing means ineligible for credentialing. For an approved incident-to arrangement, use the credentialed supervisor and retain both practitioners’ record authentication. Distinguish local SLHP/SLHN/BrightPath arrangements from the out-of-area Cigna PPO wrap, whose providers are directed to their network for management.
Applies to: Local St. Luke’s policy versus separately managed Cigna PPO out-of-area wrap; network rename is not blanket carrier-partner adoption.
Verified card/routing references: St. Luke’s Health Plan; 92170. A payer ID identifies routing and does not establish clinician eligibility.
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Provider Manual — pp.9,12–13,17–18,24; Incident To Billing p.18
Health care providers — Stick to standards; join-network link redirects to renamed SLHN
2023 initial credentialing application — Indexed credentialing eligibility/application
St Luke Health Plan Inc — PayerID92170 and website
1500 Reference Instruction Manual version13 — pp.2,26–27,44,55
Surest
Licensed associate: After confirming that this member’s behavioral-health benefit actually adopts the Optum policy, the commercial/Individual Exchange pathway can cover qualified supervised clinicians. July 2026 names CA, CO, HI, IA and MA; other states require qualifying prior Optum approval, not an ordinary new group contract.
Unlicensed graduate: After confirming that this member’s behavioral-health benefit actually adopts the Optum policy, a nonlicensed graduate with at least a master’s degree can fit the pathway when lawful practice, supervision, applicable state/approval and all product conditions are met.
Student intern: A pre-master’s student does not meet the reference guide’s minimum completed master’s degree. A doctoral student who already has the qualifying degree still needs all state/practice/product conditions; student status alone grants nothing.
Before assigning insured clients: Verify actual behavioral-health administration and applicability to this member/product; same-brand routing is insufficient. Confirm master’s-level training, legal practice scope, regular documented one-to-one supervision, and independently licensed credentialed or UBH-written-approved supervisor. Outside CA/CO/HI/IA/MA retain existing executed supervisory agreement on/before September 30, 2024, separate written confirmation or other documented Optum approval; out-of-network supervisory reimbursement is limited to the five states. Prepare claim preview with U5 and DQ supervisor data; separate claims if different supervisors apply.
Applies to: Commercial/Individual Exchange only within actual adoption; ABA, E/M by supervised practitioners, specified nonroutine outpatient/agency arrangements and state-licensed entities excluded. Medicaid/CHIP follows state rules; MA follows federal program requirements. The five-state list is not universal student or every-discipline eligibility.
Read this insurer’s hiring requirements
Tufts Health Plan
Licensed associate: The July 2026 Point32Health commercial BH policy expressly considers supervised practitioners and clinicians pursuing licensure for reimbursement when billed by a credentialed, participating supervisor. Implement the policy’s supervision, disclosure, consent and documentation requirements.
Unlicensed graduate: A graduate pursuing licensure can fit the stated supervised-clinician pathway, subject to lawful scope, participating supervisor, covered services and contract requirements. A degree without that arrangement is insufficient.
Student intern: The modifier table includes HL (intern), but the policy does not define every eligible student placement. Do not infer that every pre-degree student qualifies from the modifier alone; confirm the specific program, credential and lawful service scope.
Before assigning insured clients: Confirm the member is in a checked commercial product and the supervisor is credentialed and participating. Document the supervisory relationship, screening protocols, patient disclosure, supervisor contact information and written treatment consent. Obtain group/supervisor loading instructions using the BH enrollment process; generic CAQH forms do not prove that every supervisee requires independent credentialing. Obtain precise renderer/supervisor field instructions and the appropriate supervisee-level modifier; do not import NP/PA SA.
Applies to: Tufts Health Plan commercial products covered by the policy’s applicability grid. Tufts Health Direct, Together, RITogether, One Care and senior products are not checked. Harvard Pilgrim Passport administration must be separately resolved.
Verified card/routing references: Tufts Health Plan Commercial. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Behavioral Health providers — joining networks — forms and CAQH enrollment requirements
Billing and Reimbursement — Claims Submissions — printed F.5 generic group/individual NPI table
UnitedHealthcare
Licensed associate: the commercial/Individual Exchange pathway can cover qualified supervised clinicians. July 2026 names CA, CO, HI, IA and MA; other states require qualifying prior Optum approval, not an ordinary new group contract.
Unlicensed graduate: a nonlicensed graduate with at least a master’s degree can fit the pathway when lawful practice, supervision, applicable state/approval and all product conditions are met.
Student intern: A pre-master’s student does not meet the reference guide’s minimum completed master’s degree. A doctoral student who already has the qualifying degree still needs all state/practice/product conditions; student status alone grants nothing.
Before assigning insured clients: Verify actual behavioral-health administration and applicability to this member/product; same-brand routing is insufficient. Confirm master’s-level training, legal practice scope, regular documented one-to-one supervision, and independently licensed credentialed or UBH-written-approved supervisor. Outside CA/CO/HI/IA/MA retain existing executed supervisory agreement on/before September 30, 2024, separate written confirmation or other documented Optum approval; out-of-network supervisory reimbursement is limited to the five states. Prepare claim preview with U5 and DQ supervisor data; separate claims if different supervisors apply.
Applies to: Commercial/Individual Exchange only within actual adoption; ABA, E/M by supervised practitioners, specified nonroutine outpatient/agency arrangements and state-licensed entities excluded. Medicaid/CHIP follows state rules; MA follows federal program requirements. The five-state list is not universal student or every-discipline eligibility.
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UnitedHealthcare StudentResources
Licensed associate: StudentResources school, policy year and administrator must be identified; the reviewed certificate does not establish associate billing. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Student health insurance does not establish student-clinician eligibility; the reviewed certificate supplies no supervised-student pathway. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: University of Richmond2026–27 certificate policy2026-1443-1 is a Virginia plan. Its Physician definition (printedp40/PDF42) includes licensed counselor, psychologist, clinical social worker and MFT acting within license scope; it does not expressly establish a supervised associate claim pathway. Assigned StediWVPHC resolves74227. It cannot select school, policy year, state, BH administrator or prove Optum commercial QRG adoption. New Virginia certificate does not cure absence of assigned plan identity. School-specific certificate full-text search and targeted StudentResources/ProviderExpress supervisory searches did not establish a universal StudentResources U5/DQ, supervisor-rendering, enrollment or telehealth protocol. Need exact policy/endorsements and administrator instructions.
Verified card/routing references: 74227. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
University of Richmond2026–27 Certificate — Cover; printedp40/PDF42 Physician definition
UPMC Health Plan
Licensed associate: UPMC commercial psychotherapy by an LPC awaiting credentialing cannot simply be billed through a psychologist; both credentialing and contracting must be complete for reimbursement. No general prelicensed psychotherapy exception is established.
Unlicensed graduate: This commercial manual does not establish a routine unlicensed-graduate psychotherapy pathway.
Student intern: This commercial manual does not establish a routine psychotherapy student-intern reimbursement pathway.
Before assigning insured clients: Complete individual credentialing and contracting and verify the effective date before assuming participating reimbursement. Distinguish commercial psychotherapy from specified advanced-practice and primary-care collaborative-care arrangements.
Applies to: UPMC commercial behavioral health; Medical Assistance/HealthChoices, CHIP and Medicare require separate authority. Community Care’s involvement is not by itself the product identity.
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Administrators, networks and employer plans
AdminOne
Licensed associate: AdminOne public administration materials do not establish whether a licensed associate may deliver reimbursable psychotherapy for this card. Bind the actual carrier certificate and benefit product before budgeting associate insurance revenue.
Unlicensed graduate: No inspected source establishes a pathway for a graduate without a clinical license. Degree completion and the limited-medical versus major-medical benefit question remain separate.
Student intern: No inspected AdminOne source establishes payment for a college or graduate-school placement intern. A supervisor relationship alone does not establish covered-provider status.
Before assigning insured clients: Identify the carrier-issued certificate, covered mental-health benefit, employer/product, state and service dates; AdminOne administration does not identify those terms. Obtain the applicable provider definition and supervision/enrollment requirements for the candidate’s exact license or student placement before assigning insured clients.
Applies to: 87871 identifies the directory transaction entry. AdminOne administration may involve different carrier/product arrangements; no blanket major-medical or limited-medical supervision rule is established.
Verified card/routing references: AdminOne; 87871. A payer ID identifies routing and does not establish clinician eligibility.
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Overview — Simplifying Benefits Administration; Comprehensive Solutions (web lines 0–11)
Services — Claims Adjudication; Additional Services; Member & Provider Support
Allegiance
Licensed associate: Allegiance’s Cigna access and Clearity resources identify administrative arrangements, but do not establish that a particular associate therapist is payable. The member’s adopted behavioral-health terms must decide that question.
Unlicensed graduate: No unlicensed MSW or other graduate pathway was established. Provider identifiers shown in an eligibility inquiry example do not confer licensure or payment eligibility.
Student intern: No college-placement or other student intern eligibility was established; Cigna network access alone does not authorize an intern.
Before assigning insured clients: Identify whether the card is Clearity, another Allegiance-administered Cigna-access plan, or another employer product; obtain the current contract and behavioral-health provider definition. Confirm candidate and supervisor participation and supervised-service eligibility under the adopted plan, rather than assuming the historical Montana Cigna-access FAQ applies. Resolve the Clearity flyer’s operative date/version and exact claim identity instructions before preparing claims.
Applies to: The Clearity flyer describes Cigna OAP medical/behavioral coverage administered through Allegiance; historical 2012/2013 arrangements do not establish current product adoption. The flyer has 2026 copyright but placeholder date/code fields.
Verified card/routing references: Allegiance; Clearity; 81040; 62308. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Provider Frequently Asked Questions Regarding Cigna Members — pp1–2
Allied Benefit Systems
Licensed associate: Allied’s provider and network resources do not establish current employer-plan payment for an associate therapist. Use the employer’s current SPD and adopted reimbursement terms, not Allied’s own historical employee benefit summary.
Unlicensed graduate: No unlicensed-graduate pathway established. An employer SPD must identify eligible providers and any supervised-service exception.
Student intern: No student-intern eligibility established. A listed PPO network or claim route does not resolve school-placement billing.
Before assigning insured clients: Read the current employer SPD and incorporated behavioral-health reimbursement terms; the recovered Allied employee PPO SBC covers 2021–2022 and is not the assigned current plan. Match Allied versus Allstate identity and the actual member card before checking candidate/supervisor eligibility and enrollment.
Applies to: Allied 37308 and Allstate 75068 are separately identified on the provider page. The Allied–Christian Brothers directory alias does not select Christian Brothers Services 38308 or a trust benefit contract.
Verified card/routing references: Allied Benefit Systems; Allstate; 37308; 75068. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Who We Serve—Providers — Electronic Claims / provider portal plan information
Employer & Broker Portals—Plan Info — Plan Info: current/archived SPD and SBC
Allied Benefit Systems employee PPO SBC — Cover; historical unrelated employer-plan example
Provider Networks — Find Provider Networks (web lines 21–27); network list
Auxiant
Licensed associate: Auxiant’s public materials describe custom administration and sponsor/PPO/PBM relationships; they do not establish payment for an associate under the assigned member plan.
Unlicensed graduate: No unlicensed-graduate coverage established. Sponsor/provider definitions and any supervision exception remain to be identified.
Student intern: No student-placement billing provision established. Negotiated-rate publication does not establish eligible clinician categories.
Before assigning insured clients: Identify the employer or tribal sponsor, current SPD, provider agreement and behavioral-health delegate. Check the candidate’s exact credential, supervisor approval and enrollment with the governing plan; do not treat a PPO rate file as adoption of its supervision policy.
Applies to: Sponsors contract with PPOs/PBMs that produce rate files. That pricing arrangement does not incorporate a carrier’s clinical reimbursement exception.
Verified card/routing references: Auxiant; 10900. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Resource Library — Library: continuity of care, surprise billing and transparency files
What We Do — Who We Serve; For Providers; For Brokers & Consultants (web lines 31–60)
Benefit Health Plan
Licensed associate: Benefit Health Plan’s administrator and authorization materials do not establish supervised associate eligibility. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: No student-specific reimbursement pathway is established by the reviewed Benefit Health Plan materials. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: Benefit Logistics Insurance identifies52682 as MBA TPA, its internal claims administrator. BHP’s own prior-authorization PDF labels52682(MBA). This corroborates routing, not universal underwriting or supervised clinician eligibility.
Verified card/routing references: 52682. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
Submit a Claim FAQ — Medical claim answer:52682 and MBA TPA
Prior Authorization Listing — PDF pp1–2; header EDI PAYER #52682 (MBA); Behavioral Health
CBA Blue
Licensed associate: CBA Blue instructs BCBSVT-contracted providers to follow their contracts and payment-policy requirements, which is a useful adoption lead. The inspected documents do not expressly establish CBA employer-plan adoption of CPP37; do not promise associate reimbursement solely from that comparison policy.
Unlicensed graduate: A post-degree unlicensed candidate needs an expressly applicable covered-provider pathway. CPP37 context and general CBA billing instructions do not establish it.
Student intern: CBA student-placement permission was not established. CPP37’s own defined trainee scope must be checked if actually adopted; the word trainee cannot automatically cover every student intern.
Before assigning insured clients: Identify the employer plan, treatment state and service dates, then obtain the contract provision showing whether CPP37 or another host-plan supervision policy governs. Verify the candidate’s specific credential against that adopted policy and confirm required participation before assigning clients. Confirm rendering and supervising identities independently of the generic box 33 payee direction.
Applies to: Vermont CBA claims go directly to CBA; outside Vermont the manual uses the local host plan. CPP37 remains Blue Cross Vermont policy context until applicable adoption and state/host conditions are established.
Verified card/routing references: CBA Blue; 03036. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
CBA Blue Provider Manual — PDF p1 Claim Submission; p2 Troubleshooting Electronic Claim Submissions
Provider Resources — Claim Filing Information (Vermont Providers); Provider Electronic Submission
Centene Medical
Licensed associate: Identify the Centene subsidiary, product and setting; shared medical routing establishes no corporate-wide associate permission. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Student eligibility requires the actual subsidiary and product policy; the corporate route establishes none. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: MHS Indiana officially directs medical68069 and BH68068 as of its08/28/26 reminder. This proves a concrete Indiana plan use, not exclusive identity of either corporate clearinghouse destination. Stedi aliases span other subsidiaries. Without the member subsidiary/product/state and contracted setting, MHS Medicaid supervision rules cannot govern every68068/68069 claim. No corporate-wide therapist permission, prohibition or field mapping follows from these IDs.
Verified card/routing references: 68069. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
Electronic Payer ID Reminder — 08/28/26 medical68069 / behavioral68068; reminder not change
Christian Brothers Services
Licensed associate: The historical Comprehensive Trust booklet required administrator approval for nonlicensed practitioners. This is a concrete approval lead, but its January 2014 schedule is not current approval for this member, trust or associate.
Unlicensed graduate: The historical booklet makes administrator approval relevant to nonlicensed practitioners, but supplies no current blanket permission for unlicensed graduates.
Student intern: The historical nonlicensed-practitioner approval condition is not a student-intern authorization. Current trust terms and exact-practitioner approval would need to resolve any student placement.
Before assigning insured clients: Identify the member’s actual trust/program and current benefit booklet; do not transfer the historical Comprehensive Trust provision to RMT/EBT generally. Obtain current exact-practitioner approval and supervised-service conditions if the controlling trust retains the nonlicensed-provider pathway. Get professional claim identity instructions; the reimbursement form’s generic NPI/TIN request does not identify the renderer.
Applies to: CBS 38308, Allied aliases, Religious Medical Trust/Employee Benefit Trust resources and the historical Comprehensive Trust are not interchangeable benefit contracts.
Verified card/routing references: Christian Brothers Services; 38308. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Religious Medical Trust Members — Program types and Understanding Your Benefits
Health Benefit Downloadable Forms — RMT/EBT forms and reimbursement resources
Stedi payer directory: AHILO — Primary payer ID / Stedi payer ID / Other names
Health Reimbursement Form — One-page introductory provider/billing instructions
Consociate Health
Licensed associate: Consociate’s custom regional and direct-employer networks do not establish a single associate billing rule. The exact employer SPD and contracted behavioral-health provider policy remain necessary to answer the hiring question.
Unlicensed graduate: No unlicensed-graduate pathway established; flexible network design does not itself expand eligible clinician categories.
Student intern: No student intern provision established. Portal access and benefit-inquiry tools are not a student-service payment policy.
Before assigning insured clients: Select the actual employer/network and relevant provider portal; Consociate, BJC HealthSolutions and EBIX/LIN options are distinct entrypoints. Read the current employer SPD and contracted provider policy for the exact candidate tier, supervisor and participation arrangement.
Applies to: 37135 identifies the Consociate transaction entry, not every custom network or behavioral administrator. FSA expense lists and old portal user guides are not psychotherapy provider definitions.
Verified card/routing references: Consociate Health; 37135. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Custom Networks — Regional networks and direct-to-employer hospital contracts
Providers — Benefits/Claims/Eligibility; EBIX; Online Forms; User Guides
Provider Online Claims Access User Guide — PDF pp1–2 Getting Started; Inquiry; Coverage Verification
Everence
Licensed associate: Everence commercial and Medicare Supplement arrangements differ; no associate pathway is established by portal routing. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Student eligibility is unestablished; choose the actual Everence benefit and administrator first. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: Everence directs Cigna commercial patients and patients outside the US to Allied; Medicare Supplement has a separate portal.35605 catalog identity does not determine member product. Neither portal selection authorizes supervised therapy or establishes original Medicare billing.
Verified card/routing references: 35605. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
Provider portal — Cigna commercial→Allied; separate Supplement/dental
First Choice Health
Licensed associate: For First Choice Health EAP, a clinician who is only associate-licensed does not satisfy the published fully licensed provider application minimum. That is an EAP participation restriction, not a blanket PPO benefit exclusion. PPO associate reimbursement remains unresolved for the actual payor.
Unlicensed graduate: An unlicensed graduate does not meet EAP full licensure, even with a master’s degree. A separate PPO arrangement would need its own express terms.
Student intern: A student intern does not satisfy the EAP full-licensure requirement. No inspected PPO source establishes payment for the student’s services through a supervisor.
Before assigning insured clients: Identify EAP authorization versus medical/PPO coverage before hiring against this caseload; they use different participation and payment arrangements. For EAP participation, use a fully licensed behavioral-health professional with at least a counseling-related master’s degree and malpractice insurance of at least $1 million per claim/$3 million aggregate. For EAP cases, obtain the case number, authorized sessions and required forms before the first visit; do not bill the employer, client or health insurer for contracted EAP services. For PPO associate work, verify the actual payor’s eligibility and any supervisor pathway. The indexed CAQH restriction was not directly accessible and is not treated as a proved benefit exclusion.
Applies to: EAP’s independently licensed provider criteria and authorized-case payment process are separate from First Choice PPO/network access. The 2024.1 PPO manual is on an official UAT host and production-currentness is unconfirmed; the CAQH form remains direct-access 403.
Verified card/routing references: First Choice Health; FCH EAP; 91131. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Become an EAP Provider / EAP Provider Network — Who can apply; application minimums; telehealth
Provider Policies & Procedures v2024.1 — Printed pp1,3–5,14–18
Request to Join Our Network — Provider Form / Helpful Tips
EAP Provider Manual — PDF pp1–2 Receiving a Referral; Essential EAP Forms; EAP Billing Policies
Gravie
Licensed associate: Gravie’s published card and claim directions identify multiple network arrangements but do not establish a single associate-therapy payment rule. Aetna or Cigna branding does not itself adopt those companies’ supervised-service exceptions.
Unlicensed graduate: No unlicensed-graduate permission established. The provider-card guide governs identification and transactions, not clinical qualifications.
Student intern: No student-placement permission established for the inspected Gravie arrangements.
Before assigning insured clients: Match the actual card to Aetna ASA, Cigna or HPS/PayMedix/FirstHealth before requesting the employer’s current provider eligibility terms. Obtain adopted behavioral-health eligibility, participation and supervisor rules for the candidate’s exact credential, rather than applying a logo’s generic policy. Confirm the operative portal/cutover instructions: the published 2026 flier directs Availity while the FAQ retains expected-March-2026 wording.
Applies to: The 2026 flier distinguishes Aetna ASA→GRV01, Cigna→62308 and HPS/PayMedix/FirstHealth→20270. The old URL year is not the document date. Published portal instructions do not independently prove live activation.
Verified card/routing references: Gravie; GRV01; 62308; 20270. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Providers and Provider FAQs — Healthcare providers; Claims & reimbursement; Medical management
Claims — Submitting claims; Aetna card/5-digit group and Cigna card instructions
HealthEZ
Licensed associate: HealthEZ and America’s PPO materials establish general contracting and credentialing, but do not establish acceptance of an associate therapist for the member’s employer plan.
Unlicensed graduate: No unlicensed-graduate pathway established. General credentialing is not proof that a supervised psychotherapy service is covered.
Student intern: No student-intern eligibility established by the network application criteria or card guide.
Before assigning insured clients: Identify the employer plan, network and behavioral-health authority from the card and current plan documents. Verify the candidate-specific eligible provider definition and any supervisor arrangement; general America’s PPO credentialing materials are not an associate approval.
Applies to: HealthEZ’s America’s TPA corporate identity and the directory’s America’s PPO/TPA names do not establish a single employer benefit contract or mental-health reimbursement policy.
Verified card/routing references: HealthEZ; America’s PPO; 41178. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Join Our Network — Credentialing Information and contract-finalization description
Providers — Provider Login; Join provider network; claims/plan information
How to Read Your HealthEZ ID Card — Numbered items 1–6; provider contact/claim routing
HealthLink
Licensed associate: No current member-plan associate permission was established for HealthLink. The FY22 Illinois Local Government SPD is a historical lead that included MSW/LSW subject to legal qualification; it is not a 2026 reimbursement determination.
Unlicensed graduate: No current unlicensed-graduate pathway established. The historical MSW definition requires its actual legal-qualification context; MSW alone does not establish current permission.
Student intern: No student-placement pathway established. A private same-group/TIN/location phone lead concerns an unverified arrangement and does not authorize student billing.
Before assigning insured clients: Obtain the current employer plan and applicable behavioral-health payment policy; HealthLink’s October 2026 manual describes a multi-payor network. For the Illinois phone lead, obtain written applicability and candidate/supervisor conditions for the exact plan instead of transferring same-TIN/location conditions company-wide. Resolve provider-submission instructions separately from the payor-facing 837 guide and its conflicting supervisor loop headings.
Applies to: Open Access/PPO network access, historical Illinois public-plan benefits and a private Illinois lead are distinct. No supplied current employer plan adopts the historical provision. Sources: ADM11-S1, ADM11-S3, ADM11-S7. Internal lead: ADM11-I1.
Verified card/routing references: HealthLink; 90001. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
State of Illinois Local Government Option FY22 SPD — Printed p81, Physician definition
HealthLink Pricing Policies — Behavioral Health listing; introductory scope caveat
Electronic Data Interchange — NEIC Payer ID and claims pathway; Open Access/PPO
Guidelines and Manuals for TPAs — EDI Companion Guide described as instructions for payors
HealthLink (route unresolved)
Licensed associate: HealthLink network participation does not establish the underlying payer’s associate reimbursement permission. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Student eligibility requires the underlying payer’s benefit and agreement, not HealthLink network identity alone. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: HealthLink official EDI page specifies NEIC90001 for OpenAccess/PPO. Public StediQDOJB agrees, but assigned UUID lacks a supplied exact mirror binding; name similarity cannot establish that this UUID equals90001 or whether its historical route retired. October2026 manual separates network services from payor benefit/payment obligations. Outbound companion guide for payors cannot be repurposed as provider trainee permission or an inbound supervisor-loop requirement.
See the “shared routing does not identify the benefit” section above.
Electronic Data Interchange — NEIC Payer ID and claims pathway; Open Access/PPO
HealthSCOPE Benefits
Licensed associate: HealthSCOPE’s link to UHC/UMR medical and drug policies does not establish Optum behavioral-health delegation or adoption of its supervised-therapy payment rules. Associate eligibility remains unresolved for the actual employer plan.
Unlicensed graduate: No unlicensed-graduate pathway established. A TIN registration or valid electronic claim does not prove the service is payable.
Student intern: No student-intern eligibility established by the provider center or electronic-claim instructions.
Before assigning insured clients: Identify the employer, state, current benefit contract and actual behavioral-health administrator. Verify candidate and supervisor eligibility/enrollment under that delegate; do not treat the medical/drug policy link as an Optum supervision exception. Use card-specific submission instructions only after clinical eligibility is established; iEDI registration is a separate administrative step.
Applies to: HealthSCOPE/UMR medical-drug resources and potential Optum behavioral arrangements have separate scope. The public link establishes the former, not the latter.
Verified card/routing references: HealthSCOPE Benefits; 40026. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Provider center—Additional resources — Guidelines and policies link
UnitedHealthcare|UMR Medical & Drug Policies — Landing page policy scope
Claim submissions — Electronic; Online; Mail; PCH submission
HMA
Licensed associate: HMA participation in Priority Health’s Michigan collaboration is not, by itself, adoption of Priority’s limited-license behavioral-health payment exception. No exact HMA employer-plan associate permission was established.
Unlicensed graduate: No unlicensed-graduate pathway established for HMA. Medical-policy hierarchy and HMA payment-integrity rules remain different scopes.
Student intern: No student-placement permission established. The indexed Priority limited-license lead is not a student-intern approval.
Before assigning insured clients: Identify the actual HMA employer product and region; distinguish Michigan Priority collaboration from PNW and other plans. Get written confirmation of whether the specific limited-license payment exception governs the HMA member, plus the candidate’s enrollment and supervision conditions.
Applies to: Healthcare Management Administrators/HMA01 is not Hawaii HMAA/HWMG. Indexed Priority HMA guidance describes a medical-policy hierarchy while reserving HMA payment integrity; direct access was 403 and no supervision adoption is inferred.
Verified card/routing references: Healthcare Management Administrators; HMA; HMA01. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Behavioral health provider billing — Limited license practitioners
For Providers (Michigan) — EDI transactions; coverage; claim submission; onboarding
IBA
Licensed associate: IBA’s public provider resources and employer-specific claim form do not establish associate-therapy eligibility. The employer’s current plan and provider definition remain the missing decision source.
Unlicensed graduate: No degree-only graduate pathway established. The employer-name requirement identifies whose benefits must be checked, not clinician eligibility.
Student intern: No student-placement services pathway established; the member claim form is not a professional supervisory policy.
Before assigning insured clients: Identify the employer and current benefit plan using the card and required employer details; obtain its provider eligibility and supervision terms. Verify the candidate’s specific credential, supervisor and enrollment with that plan before treating the 11329 route as usable for the arrangement.
Applies to: YTGWD/11329 identifies the IBA/International Benefit Administration transaction entry. It does not select an employer contract or establish a clinical supervision exception.
Verified card/routing references: IBA; International Benefit Administration; 11329. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
IBA payer directory — Primary ID 11329; aliases; 837P
Medical Claim Form — Employer required; physician/employee sections
Provider Help Center — Official outbound medical form and provider-portal links
Imagine360
Licensed associate: BrightSpring’s 2026 Imagine360-administered benefit booklets include LPC, LMFT, LCSW and MSW in a Practitioner definition conditioned on applicable state licensure/certification and scope. That is a useful named-plan lead, but does not establish associate-tier psychotherapy reimbursement or supervisor-NPI substitution for every Imagine360 card.
Unlicensed graduate: MSW appears in the named plan definition, but it is a degree and the definition remains conditioned on applicable state licensure/certification and scope. It does not establish automatic payment for an unlicensed MSW.
Student intern: No general student-intern pathway established. The Practitioner definition is not a college-placement benefit exception.
Before assigning insured clients: Identify the employer and actual IH versus Non-IH booklet, state and service date before applying BrightSpring’s provider definition. Read the candidate’s state license/certification and scope together with the plan’s eligible-provider and service terms; obtain a specific associate determination if needed. Confirm enrollment and rendering/supervisor identities separately. The Ardent plan lead returned 403 and is not used as authority.
Applies to: BrightSpring’s January 2026 restatements are named-plan examples only; the Non-IH booklet identifies group H880335. They do not establish every Imagine360 employer plan’s terms or merge IH/Non-IH coverage.
Verified card/routing references: Imagine360; 48143. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Imagine360 2026 benefit resources — Actual IH and non-IH booklet links
BrightSpring Non-IH $3500/$4500 Benefit Booklet — Restated Jan 1 2026; pp.3,52,100
Ardent 2026 Imagine360 plan document lead — Attempted current employer SPD
Independence Administrators
Licensed associate: IA’s behavioral-health offerings and use of IBX resources do not establish member-group adoption of IBX’s psychotherapy associate/AJ pathway. The inspected notices expressly include IA for other services, which cannot be transferred to LSW/LMSW, LAMFT or LAPC psychotherapy.
Unlicensed graduate: No unlicensed-graduate pathway established. Neither IA’s integrated-services brochure nor IBX advanced-practice CRNP/PA rules authorize degree-only therapists.
Student intern: No student-intern psychotherapy eligibility established. IA’s optional EAP is also separate from medical behavioral-health coverage.
Before assigning insured clients: Identify the actual employer behavioral-health benefit and whether the service is optional EAP or medical psychotherapy. Obtain written IA member-group adoption of the specific IBX Section 8 associate pathway, candidate tier and supervisor participation conditions before using AJ.
Applies to: Explicit IA inclusion in ABA management and CRNP/PA notices has service-specific scope. It does not establish incorporation of IBX Section 8 for psychotherapy. The April 2026 IBX manual remains comparison evidence.
Verified card/routing references: Independence Administrators. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Behavioral Health — IA named specifically in April 2026 ABA transition
Advanced Practice Provider credentialing reminder — Explicit IBX and IA scope for CRNP/PA
Keenan and Associates
Licensed associate: Prime Healthcare’s agreement limits payment to covered services within provider qualifications and incorporates plan/manual terms. It does not establish associate-therapy permission for the supplied Keenan destination, nor bind a member to Prime EHP.
Unlicensed graduate: No unlicensed-graduate pathway established. The current SPD and incorporated procedures are needed rather than treating a provider agreement as a degree-only exception.
Student intern: No student-placement permission established. Prime’s provider qualification condition cannot be replaced by a generic supervised-office arrangement.
Before assigning insured clients: Identify whether the card actually belongs to Prime EHP or another Keenan employer plan, and which tier/network is involved. For Prime, obtain the current SPD, provider manual and internal procedures incorporated by agreement §§11–13 through the plan’s documented HR/EHP request route. Resolve candidate license/scope, covered service and any supervisor enrollment/claim instructions before assigning insured clients.
Applies to: FROTU/KEE01 aliases including Prime EHP and 94749 do not prove member identity. The current Prime claims page uses Tier 1 Valenz 94749 versus Tier 2 local BCBS with accurate service location; those are named-plan routes.
Verified card/routing references: Keenan and Associates; Prime Healthcare EHP; KEE01; 94749. A payer ID identifies routing and does not establish clinician eligibility.
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Keenan and Associates directory — KEE01; aliases include 94749 and Prime Healthcare EHP
Claims and Appeals — Tier 1 and Tier 2 claim processing; 360-day rule
Our Journey Forward including Provider Agreement — PDF pp.4–5, agreement §§11–13
Provider Central — Public claims link
Luminare Health
Licensed associate: For confirmed OSU Health Plan coverage, Ohio LPC, LSW and MFT clinicians meeting the policy definitions can deliver covered supervised services billed through an eligible licensed psychologist or independent practitioner when the policy conditions are met. This affirmative pathway does not apply to every Luminare card.
Unlicensed graduate: An unlicensed graduate has no general OSU pathway. A graduate who separately satisfies the expressly allowed psychology-board registration, assigned-title and psychologist-supervision requirements may qualify; degree completion alone is insufficient.
Student intern: OSU excludes CT, SWT, MFTT and other students/trainees not expressly allowed. A specifically qualifying Ohio psychology-board registrant under 4732-13-04, assigned a title under 4732-13-03 and supervised by a licensed psychologist, has a conditional pathway. A generic college-placement intern does not qualify merely by being called an intern.
Before assigning insured clients: Confirm OSUHP coverage and candidate’s actual Ohio license or qualifying psychology registration/title. OSUHP credentials independent practitioners, not supervised practitioners/trainees. Use an eligible policy-defined independent supervisor or licensed psychologist; qualifying psychology trainees specifically require a licensed psychologist. A restricted-network plan requires that supervisor to participate in the OSUHP statewide network. Follow applicable Ohio supervision rules. Supervisor retains records of supervision dates/times, content and goals, signs at least quarterly and supplies records on request. Disclose supervised diagnosis/treatment on all printed and electronic material; identify supervisor names on a client disclosure statement or similar document available to OSUHP on request. Apply the exclusion for services provided by a Licensed Psychologist or Independent Practitioner who is a family covered person of the Supervised Practitioner or Supervised Trainee. Obtain OSUHP clarification of ambiguous relationship terminology rather than treating it as an all-relatives exclusion. Check participation feasibility: the provider page says new network requests are closed; existing groups have a provider update route. Prior authorization is not required when the counseling-supervision criteria are met. Resolve NPI placement, modifier and telehealth implementation separately; missing syntax does not negate the policy’s documented eligibility.
Applies to: All OSUHP benefit plans are within the August 2025 policy. Promise’s July 2026 guide and other Luminare-administered employer plans remain separate. No member was bound to either OSU or Promise by this assignment.
Verified card/routing references: OSU Health Plan; Luminare; Promise Health Plan; 62308; RP128. A payer ID identifies routing and does not establish clinician eligibility.
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Counseling Supervision, revision 8/25 — pp.1–4
For Providers — Claims FAQ and network enrollment
MedCost Benefit Services
Licensed associate: MedCost’s current add-provider form explicitly accepts LCMHC-A, LCSW-A and LMFT-A categories and asks for individual NPI/CAQH information. That gives an associate a real enrollment route to investigate, but is not approval or proof that a particular MBS employer plan reimburses the service or permits supervisor-NPI substitution.
Unlicensed graduate: No unlicensed-graduate pathway established. Associate-license form choices should not be read as a degree-only permission.
Student intern: The listed associate categories do not authorize student intern services. No student-placement reimbursement pathway established in the inspected current materials.
Before assigning insured clients: For a participating practice, submit the candidate’s actual associate category with the requested practice EIN/group NPI and individual NPI/CAQH details; do not represent submission as approval. Obtain credentialing approval before adding the provider to the network; authorize MedCost’s access to current CAQH information as instructed. Identify the exact MBS employer plan/state and verify the approved credential’s covered service and payment identity before assigning insured visits. Do not rely on the historical March 2022 MA LPA/overseeing-MD clause without current confirmation; its absence from October 2025 proves neither permission nor reversal. Reconcile the member-card submission route and actual renderer/supervisor fields; current generic 2310B syntax does not decide substitution.
Applies to: MedCost network onboarding is different from a member’s MedCost Benefit Services employer-plan benefit. North Carolina/South Carolina and Virginia routing and credential labels must remain separate. Current enrollment-form evidence is stronger than the obsolete manual inference but still not a payment determination.
Verified card/routing references: MedCost Benefit Services; MedCost; 56162; 54138; 56205. A payer ID identifies routing and does not establish clinician eligibility.
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Provider Onboarding — Get the MedCost Provider Manual link; Claims Filing Tips
Network Credentialing — Requirements for network participation
Merchants Benefit Administration
Licensed associate: Merchants Benefit Administration’s current provider entrypoint offers benefit and claim inquiries, but no public candidate-tier supervision rule was established. Associate eligibility needs the member’s actual plan terms.
Unlicensed graduate: No unlicensed-graduate reimbursement pathway established. Company identity and portal access do not resolve covered-provider qualifications.
Student intern: No student-intern reimbursement permission established by the current or legacy provider pages.
Before assigning insured clients: Use the current MBA provider entrypoint and identify the actual member employer/product; the site explicitly distinguishes a legacy portal fallback. Obtain the current plan’s covered-provider categories, candidate enrollment result and any supervisory exception before budgeting insured associate visits. Reconcile the actual card’s claim destination; the legacy XXX placeholder is not a payer ID and its old address should not be adopted from company-name similarity.
Applies to: This is Merchants Benefit Administration, not an unrelated MBA-named administrator. Current/legacy portal identity, a directory route and employer benefits have separate scopes.
Verified card/routing references: Merchants Benefit Administration; IHS24. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Merchants Benefit Administration directory — Primary IHS24; AZEBM; 837P
Provider Login — Current provider portal and explicit legacy fallback
Legacy Providers — XXX placeholder and Cheyenne claims address
Merchants Benefit Administration — Current company identity and Scottsdale contact
Meritain Health
Licensed associate: Meritain’s current-linked professional companion guide describes supervising-provider fields, but does not establish which associate therapy services an employer plan pays. A syntactically valid supervisor loop is not an associate billing authorization.
Unlicensed graduate: No unlicensed-graduate pathway established. A technical NPI field does not establish clinical licensure or reimbursement.
Student intern: No student-intern coverage established by the EDI guide or employer benefit summaries.
Before assigning insured clients: Obtain the actual employer SPD and adopted behavioral-health provider/reimbursement policy; the Diocese’s 2026–2027 plan summaries do not bind another group. Confirm the candidate’s covered-provider tier, enrollment and supervision arrangement separately from EDI syntax. Confirm the trading partner’s implemented guide and situational supervisor-loop use; the currently linked PDF is Version 2.0, copyright 2011, not a 2024 edition.
Applies to: Meritain employer plans and Aetna network access do not share a demonstrated supervision exception. Current-public-link identity is established; current implemented EDI version and exact employer adoption remain unresolved.
Verified card/routing references: Meritain Health. A payer ID identifies routing and does not establish clinician eligibility.
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Electronic Transaction Vendors — Vendor table; EDI Companion Guides
North American Administrators
Licensed associate: No current Nashville/North American Administrators member-plan associate permission was established. The recovered Nye County 2026 SPD names Lucent Rancho Cordova and cannot supply clinical permission for this Nashville destination.
Unlicensed graduate: No unlicensed-graduate pathway established. A different branch’s MFCC/LCSW definition is not a Nashville supervisory exception.
Student intern: No student-placement eligibility established for this destination. Nye’s setting-specific home-health/hospice language does not establish outpatient psychotherapy student billing.
Before assigning insured clients: Match the member employer plan and Nashville branch using the actual card; do not use the Nye/Rancho Cordova SPD as governing terms. Obtain the Nashville group’s current covered-provider definitions, associate/student provisions and any supervisor enrollment requirements.
Applies to: WRSMU/65085 is the Nashville transaction entry. Lucent aliases do not merge branch contracts; Nye expressly names Rancho Cordova and master-plan precedence.
Verified card/routing references: North American Administrators Nashville; Lucent Health; 65085. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
North American Administrators Nashville directory — 65085 and aliases; 837P
Providers — Current Availity transition and resources
Providence / Collective Health
Licensed associate: Providence RP5 requires independently qualified commercial clinicians eligible for a plan-recognized NPI to submit under their own NPI, while retaining a conditional auxiliary-personnel route. It does not establish that a psychotherapy associate is auxiliary personnel or that this Collective Health ASO group adopts RP5. Exact-plan associate eligibility remains unresolved.
Unlicensed graduate: No general unlicensed-graduate therapy pathway established for the Collective ASO group. A candidate would need an applicable eligible-provider category and adopted payment rule, not simply supervisor availability.
Student intern: No general psychotherapy student-intern permission established. RP5’s medical auxiliary-personnel pathway cannot automatically be applied to a college counseling placement.
Before assigning insured clients: Identify the exact Collective Health employer/group, coverage agreement and whether RP5 is incorporated; the coverage agreement takes precedence. Determine the candidate’s actual provider category and whether the plan recognizes independent billing or a specific auxiliary route; do not classify all associates as auxiliary. Resolve RP5’s contradictory A/B supervision example before using it to select billing identity. Verify enrollment, actual supervision, claim fields and any telehealth conditions under the applicable product rather than borrowing Medicare Advantage or Medicaid/OHP sections.
Applies to: RP5 separately addresses commercial, Medicare Advantage and Medicaid/OHP arrangements. Collective FAQ establishes administration/network distinctions, not ASO adoption. PEBB Choice group 106528 is a separate named handbook example, not member binding.
Verified card/routing references: Providence Health Plan; Collective Health. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Incident-To Services RP5 — Effective 3/1/2026; pp.1–6,9,11–13
Providence provider FAQ — Network, claims and portal distinctions
Reflect Health
Licensed associate: Reflect Health’s configurable plan administration and legacy S&S identity do not establish a universal supervised-therapy rule. Current member-plan associate eligibility remains unresolved.
Unlicensed graduate: No unlicensed-graduate pathway established. The unavailable Athena RI SPD lead is not inspected clinical authority.
Student intern: No student-intern permission established. A rebrand and administrative-service description do not define eligible therapists.
Before assigning insured clients: Identify the current employer plan, behavioral-health terms and candidate-specific provider eligibility; custom plan administration permits different contracts. Obtain a usable current SPD and adopted supervision policy; the tested Athena RI link returned 404 and an indexed COBRA reference does not establish clinical terms.
Applies to: DCXFI/31441 and legacy S&S aliases identify administrative history. Reflect’s configurable services do not establish adoption of any network carrier’s supervision exception.
Verified card/routing references: Reflect Health; 31441. A payer ID identifies routing and does not establish clinician eligibility.
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Custom Plan Administration — Plan-specific configuration and services
Athena RI SPD with amendments lead — S&S administrative identification in search excerpt
Regence Group Administrators
Licensed associate: RGA explicitly says it is a separate company from Regence BlueShield. Accepting Regence patients or knowing a Regence supervised-practice rule does not establish reimbursement for an associate under an RGA employer plan.
Unlicensed graduate: No RGA unlicensed-graduate pathway established. A third-party Hecla 2025 SPD copy was not controlling matched authority.
Student intern: No RGA student-placement eligibility established. A virtual behavioral-health network extension does not identify supervised student providers.
Before assigning insured clients: Verify the member’s actual RGA employer plan through the card contacts rather than asking Regence BlueShield for RGA coverage. Determine candidate/supervisor eligible-provider status under the RGA group’s current adopted policy; virtual-network descriptions and unbound third-party SPDs do not resolve it. Match actual provider contracting to the submission branch: Regence-contracted uses RGA01, non-Regence uses local BlueCard.
Applies to: RGA is separate from Regence BlueShield. Regence network participation and BlueCard routing do not establish a group’s supervision benefit. Whidbey’s indexed network extension and unbound Hecla text remain limited leads.
Verified card/routing references: Regence Group Administrators; RGA; RGA01. A payer ID identifies routing and does not establish clinician eligibility.
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For Providers — Separate-company warning; Regence-contracted versus non-Regence routing
2026 WhidbeyHealth Benefits Guide — Digital behavioral-health extension table
Hecla Gold 2025 SPD lead — Group 020629; RGA Idaho
U.S. Networks / Administrative Services
Licensed associate: U.S. Networks administrative routing does not establish UHC/Optum supervised-clinician policy adoption. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: No student-specific eligibility follows from the USN administrative route. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: UHC official affiliates/alliances payer list names UnitedHealthcare / U.S. Networks and Administrative Services with USN01, effective3/1/2020, under Commercial. This corroborates exact route but does not make ordinary UHC/Optum clinical policy govern every USN member. Specific international/domestic member benefits, BH administrator and provider agreement remain absent. No supervised clinician approval or field policy established from this administrative code list.
Verified card/routing references: USN01. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
Claims payer list affiliates and strategic alliances — p1 Commercial USN01 row, effective3/1/2020
UMR
Licensed associate: After confirming that this member’s behavioral-health benefit actually adopts the Optum policy, the commercial/Individual Exchange pathway can cover qualified supervised clinicians. July 2026 names CA, CO, HI, IA and MA; other states require qualifying prior Optum approval, not an ordinary new group contract.
Unlicensed graduate: After confirming that this member’s behavioral-health benefit actually adopts the Optum policy, a nonlicensed graduate with at least a master’s degree can fit the pathway when lawful practice, supervision, applicable state/approval and all product conditions are met.
Student intern: A pre-master’s student does not meet the reference guide’s minimum completed master’s degree. A doctoral student who already has the qualifying degree still needs all state/practice/product conditions; student status alone grants nothing.
Before assigning insured clients: Verify actual behavioral-health administration and applicability to this member/product; same-brand routing is insufficient. Confirm master’s-level training, legal practice scope, regular documented one-to-one supervision, and independently licensed credentialed or UBH-written-approved supervisor. Outside CA/CO/HI/IA/MA retain existing executed supervisory agreement on/before September 30, 2024, separate written confirmation or other documented Optum approval; out-of-network supervisory reimbursement is limited to the five states. Prepare claim preview with U5 and DQ supervisor data; separate claims if different supervisors apply.
Applies to: Commercial/Individual Exchange only within actual adoption; ABA, E/M by supervised practitioners, specified nonroutine outpatient/agency arrangements and state-licensed entities excluded. Medicaid/CHIP follows state rules; MA follows federal program requirements. The five-state list is not universal student or every-discipline eligibility.
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UMR Onalaska
Licensed associate: After confirming that this member’s behavioral-health benefit actually adopts the Optum policy, the commercial/Individual Exchange pathway can cover qualified supervised clinicians. July 2026 names CA, CO, HI, IA and MA; other states require qualifying prior Optum approval, not an ordinary new group contract.
Unlicensed graduate: After confirming that this member’s behavioral-health benefit actually adopts the Optum policy, a nonlicensed graduate with at least a master’s degree can fit the pathway when lawful practice, supervision, applicable state/approval and all product conditions are met.
Student intern: A pre-master’s student does not meet the reference guide’s minimum completed master’s degree. A doctoral student who already has the qualifying degree still needs all state/practice/product conditions; student status alone grants nothing.
Before assigning insured clients: Verify actual behavioral-health administration and applicability to this member/product; same-brand routing is insufficient. Confirm master’s-level training, legal practice scope, regular documented one-to-one supervision, and independently licensed credentialed or UBH-written-approved supervisor. Outside CA/CO/HI/IA/MA retain existing executed supervisory agreement on/before September 30, 2024, separate written confirmation or other documented Optum approval; out-of-network supervisory reimbursement is limited to the five states. Prepare claim preview with U5 and DQ supervisor data; separate claims if different supervisors apply.
Applies to: Commercial/Individual Exchange only within actual adoption; ABA, E/M by supervised practitioners, specified nonroutine outpatient/agency arrangements and state-licensed entities excluded. Medicaid/CHIP follows state rules; MA follows federal program requirements. The five-state list is not universal student or every-discipline eligibility.
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WebTPA
Licensed associate: The assignment reports and preserves a newer internally confirmed WebTPA allowance, but its controlling employer/product, credential and filing conditions are not in the public evidence. Do not erase that allowance or publish it as universal permission. LSU First’s public MSW definition does not independently establish Illinois LSW self-rendering or supervisor substitution.
Unlicensed graduate: No public unlicensed-MSW pathway established. MSW is a degree; the controlling plan must resolve actual license qualifications and any supervised exception.
Student intern: No public student-intern pathway established. Neither an MSW reference nor an internally confirmed associate allowance proves college-placement eligibility.
Before assigning insured clients: Recover the controlling written provision behind the August payer discussion and bind it to the actual employer/product, state, license, dates and INN/OON scope; preserve the confirmed allowance as an internal lead. If LSU First is the actual product, review the complete applicable amendments as well as the base SPD; remaining scanned amendments were not fully verified in the prior review. If Prudential is the actual product, use its current SPD/HR plan documents; the provider flyer establishes group 2022PRU administration, not supervisory terms. Resolve whether the approved LSW self-renders or uses a supervisor, and obtain enrollment, modifier, documentation and telehealth instructions for that exact arrangement.
Applies to: LSU First and Prudential are separate named-plan leads, neither bound to a supplied member. The internal payer allowance is preserved as scoped evidence needing written conditions; it is not contradicted by public-document silence. Sources: ADM27-S1, ADM27-S2, ADM27-S4, ADM27-S5. Internal lead: ADM27-I1.
Verified card/routing references: WebTPA; LSU First; Prudential; 75261. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
LSU First current plan resources — 2026 SPD/SMM link and WebTPA administrator identification
Prudential Low HSA SBC lead — SPD availability at MyTotalRewards/HR
For Your Doctor — Prudential — pp.1–2 Claims and Eligibility; Group 2022PRU
WPEE Insurance Trust Fund
Licensed associate: WPEE’s bargaining and non-bargaining SPDs cover outpatient mental-health therapy by an eligible legally licensed practitioner. They do not require LCSW by name for every social worker, but also do not expressly establish supervised LSW/associate billing. Determine whether the candidate meets the actual plan’s legally-licensed-to-treat condition before promising Fund revenue.
Unlicensed graduate: A degree-only, unlicensed graduate does not meet the stated licensed-provider pathway. Supervised clinical experience for Pennsylvania LCSW licensure does not itself establish Fund payment for an LSW or a graduate.
Student intern: A student without the required practitioner license does not meet the stated licensed-provider condition. No express student-service exception was located; this is a limit of the described pathway, not a claim about every possible amendment.
Before assigning insured clients: Match bargaining versus non-bargaining coverage and the current SPD/amendments; the public catalog links 2025 SPDs and a 2026 SBC. Evaluate the candidate’s actual treatment-state license against the Fund’s eligible-practitioner definition; ask the Fund to resolve supervised LSW/associate scope if unclear. Verify provider participation and the Fund’s claim identity instructions for that candidate; Aetna-Meritain network access and Highmark hospital benefits do not establish an outpatient supervision exception.
Applies to: Bargaining and non-bargaining plans have separate SPDs. The 2026 SBC is a cost-sharing summary, not a new supervisory policy. Pennsylvania clinical licensure rules, Fund benefits, hospital coverage and network administration remain separate.
Verified card/routing references: Western Pennsylvania Electrical Employees Insurance Trust Fund. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Bargaining Employees Plan Document and SPD, January 1 2025 — Printed pp.36,38,40–43; sections 9–11
Documents & Forms — 2025 bargaining/non-bargaining SPD links and 2026 SBC link
2026 Summary of Benefits and Coverage — Coverage period 1/1–12/31/2026; mental-health row
49 Pa. Code §47.12c — LSW prerequisite and supervised clinical experience
Behavioral health administrators
Carelon Behavioral Health
Licensed associate: The Massachusetts addendum permits license-eligible clinicians in in-network Fallon behavioral-health facilities after educational requirements are complete, with hours accruing and regular supervision by an independently licensed Carelon-credentialed/contracted clinician.
Unlicensed graduate: A graduate may qualify as license-eligible while accruing independent-license hours if all education, supervision, facility and service conditions are met; graduation alone is insufficient.
Student intern: The documented Fallon pathway requires completed education. It does not establish coverage for a student still completing the qualifying degree.
Before assigning insured clients: Confirm an in-network Fallon facility contract and covered/authorized service; do not broaden facilities to every private group. Document completed education, licensure hours and regular qualified supervision. Use the supervised-clinician roster process, not ordinary group roster automation; submission is not approval. For WellSense patients, use current WellSense administration rather than the stale retained Carelon section.
Applies to: Fallon Massachusetts facility permission is affirmative. Carelon corporate identity and BHOVO do not extend it to other contracts; WellSense transitioned administration.
Verified card/routing references: BHOVO. A payer ID identifies routing and does not establish clinician eligibility.
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National Provider Handbook — Form 102_0426; printed pp.12–14 section 2.06 roster management
Documentation Standards and Requirements — pp.3–5 clinical record requirements; pp.5–6 Incident to
BH Insourcing Reference Guide — pp2–3 transition and Massachusetts payer13337
Centene Behavioral Health
Licensed associate: Identify the Centene subsidiary, product and setting; shared behavioral-health routing establishes no corporate-wide associate permission. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Student eligibility requires the actual subsidiary and product policy; the corporate route establishes none. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: MHS Indiana officially directs medical68069 and BH68068 as of its08/28/26 reminder. This proves a concrete Indiana plan use, not exclusive identity of either corporate clearinghouse destination. Stedi aliases span other subsidiaries. Without the member subsidiary/product/state and contracted setting, MHS Medicaid supervision rules cannot govern every68068/68069 claim. No corporate-wide therapist permission, prohibition or field mapping follows from these IDs.
Verified card/routing references: 68068. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
Electronic Payer ID Reminder — 08/28/26 medical68069 / behavioral68068; reminder not change
Guidehealth Behavioral Health
Licensed associate: Guidehealth’s public delegation resources do not establish associate eligibility for the exact payer agreement. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: No student-specific reimbursement pathway is established for the exact Guidehealth agreement. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy.
Applies to: Guidehealth official contact page directs benefits, claims, credentialing and contracting inquiries through its provider resources for services performed on behalf of payors. Exact Stedi36363 identifies the BH network, but public contact/portal material does not bind it to a specific delegated IPA/site or supervised-therapist agreement.
Verified card/routing references: 36363. A payer ID identifies routing and does not establish clinician eligibility.
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Contact — Provider benefits, claims, credentialing/contracting instructions
Magellan Health
Licensed associate: Magellan’s California supplement reimburses eligible associates/interns in its defined California regulated-plan scope, with qualified network supervision, documented review, co-signatures, verification of training and written member consent. Idaho has a separate supervisory arrangement with unresolved public claim conflicts.
Unlicensed graduate: A graduate fitting the California eligible associate/intern category can use the documented pathway after qualification and supervision requirements are met. Graduation alone does not establish eligibility.
Student intern: California’s phrase associates/interns is not a complete definition of pre-degree student eligibility. Verify the candidate’s lawful credential/program and contract scope rather than labeling all students eligible. Idaho likewise needs its own qualification rules.
Before assigning insured clients: Verify California regulated-plan/contract scope and candidate education, eligibility, work history and training. Arrange regular individual supervision, chart documentation, co-signed plans/notes and written member consent. For California claims use primary HL and applicable modality second; obtain unresolved NPI mapping. For Idaho resolve conflicting billing-organization identity and master’s modifier pair before configuring claims.
Applies to: California Knox-Keene plans/EAP scope stated in supplement; not every Magellan product. Idaho IBHP is separate despite shared 01260 routing.
Verified card/routing references: 01260. A payer ID identifies routing and does not establish clinician eligibility.
Read this insurer’s hiring requirements
Billing Instructions for Magellan Telehealth Providers—California — p.4 notes1,3–5,9–10
California Provider Handbook Supplement — printed pp.22–23 Use of Associates and Interns (SB855)
Optum
Licensed associate: the commercial/Individual Exchange pathway can cover qualified supervised clinicians. July 2026 names CA, CO, HI, IA and MA; other states require qualifying prior Optum approval, not an ordinary new group contract.
Unlicensed graduate: a nonlicensed graduate with at least a master’s degree can fit the pathway when lawful practice, supervision, applicable state/approval and all product conditions are met.
Student intern: A pre-master’s student does not meet the reference guide’s minimum completed master’s degree. A doctoral student who already has the qualifying degree still needs all state/practice/product conditions; student status alone grants nothing.
Before assigning insured clients: Verify actual behavioral-health administration and applicability to this member/product; same-brand routing is insufficient. Confirm master’s-level training, legal practice scope, regular documented one-to-one supervision, and independently licensed credentialed or UBH-written-approved supervisor. Outside CA/CO/HI/IA/MA retain existing executed supervisory agreement on/before September 30, 2024, separate written confirmation or other documented Optum approval; out-of-network supervisory reimbursement is limited to the five states. Prepare claim preview with U5 and DQ supervisor data; separate claims if different supervisors apply.
Applies to: Commercial/Individual Exchange only within actual adoption; ABA, E/M by supervised practitioners, specified nonroutine outpatient/agency arrangements and state-licensed entities excluded. Medicaid/CHIP follows state rules; MA follows federal program requirements. The five-state list is not universal student or every-discipline eligibility.
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Quest Behavioral Health
Licensed associate: Quest stopped provider credentialing effective September 2026 and provider contracts terminate December 31, 2026. Previously accepted licensed associates may meet the remaining applicable benefit conditions, but a new hire cannot be budgeted on an ordinary new Quest enrollment. Any transition SCA requires its own documented eligibility.
Unlicensed graduate: An unlicensed graduate cannot use supervisor-substitution billing under the standard outpatient rule; licensed associates are a different category.
Student intern: The standard outpatient pathway requires a valid license. An unlicensed student cannot use a supervisor’s license/NPI to satisfy it.
Before assigning insured clients: Do not count on a new ordinary Quest credentialing application: credentialing stopped in September 2026. Confirm existing clinician acceptance or actual eligibility for the short-term transition SCA, available for current treating providers participating in or pursuing the member’s successor network; it is not automatic new-hire approval. Verify individual credentialing/acceptance and the exact employer benefit and service date. Confirm the program is still administered by Quest: UPHS/UPENN ended June 30, 2026; WellSpan BH/EAP continues through December 31, 2026; other employer dates differ. Use treating clinician NPI in 24J, required signature/name in 31 and applicable authorization in 23.
Applies to: Quest BH/EAP employer benefit and service date must be confirmed. UPHS/UPENN transitioned July 1, 2026; WellSpan transitions January 1, 2027. Quest contracts end December 31, 2026, and credentialing ceased in September 2026. Do not infer successor-network permission.
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Medicaid products
Aetna Better Health Virginia
Licensed associate: Virginia’s resident/supervisee category supplies positive state eligibility context, but the current Aetna Better Health manual does not establish contractual acceptance of the exact resident, roster or supervised billing arrangement. This is an unresolved plan acceptance question, not a documented prohibition.
Unlicensed graduate: A qualifying board-approved resident/supervisee differs from a bare unlicensed graduate. Aetna’s specific acceptance of either arrangement is not established by the reviewed manual.
Student intern: No Aetna Better Health Virginia pre-degree student-intern therapy pathway was established. Generic supervisor fields do not supply eligibility.
Before assigning insured clients: For a proposed resident/supervisee, first verify board-approved credential/site/duties and state supervision requirements. Obtain Aetna acceptance of that clinician/relationship, enrollment or roster handling, rendering identity and any telehealth terms before assigning Aetna-covered clients. Preserve the current manual’s literal generic supervisor and renderer locations without treating those fields as trainee permission.
Applies to: Aetna Better Health of Virginia Medicaid, current August 2026 manual for July 2026–June 2027. Do not import Aetna commercial or DMAS FFS claim arrangements.
Verified card/routing references: Aetna Better Health Virginia; 128VA. A payer ID identifies routing and does not establish clinician eligibility.
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Approved Virginia SPA24-0005 — Attachment3.1-A&B Supplement1 p10.0, Non-Licensed Practitioners
Aetna Medicaid Illinois
Licensed associate: A qualified post-degree clinician can fit an Illinois FQHC/RHC subclinical pathway, or the distinct approved-agency staffing pathway. This does not establish ordinary private-practice LPC/LSW billing for this destination. Fully licensed LCPC/LMFT coverage must not be denied using the superseded June 2021 handbook exclusion.
Unlicensed graduate: A graduate without independent clinical licensure may qualify in the covered encounter-clinic or approved-agency setting if the actual degree, MHP/QMHP role and supervision requirements are met. Graduation alone does not create private-practice reimbursement.
Student intern: A student placement alone does not satisfy the completed-degree FQHC/RHC pathway. An agency must assess any independently held MHP qualification and its program rules; no general student-intern private-practice payment permission is established.
Before assigning insured clients: Classify the employer as ordinary practitioner/group, enrolled FQHC/RHC, or approved CMHC/BHC before budgeting supervised visits. For an FQHC/RHC hire, verify the qualifying completed degree, clinic-site IMPACT enrollment, and supervision by one of the professionals named in the HFS notice. For CBS services, verify CMHC/BHC employment and the exact MHP/QMHP qualification; a license title or college placement alone is insufficient. Implement the corrected education-based T1040 modifiers for encounters, and obtain the specific plan subclinical rendering/supervisor instructions separately.
Applies to: Illinois HFS fee-for-service and separately identified HealthChoice Illinois products. LPC/LSW or other preclinical status is distinct from independent LCPC/LMFT licensure. FQHC/RHC subclinical coverage requires an applicable completed graduate degree; CBS MHP/QMHP status requires the actual qualifications and approved agency setting. No universal private-practice MCO trainee permission is established.
Verified card/routing references: Aetna Better Health of Illinois. A payer ID identifies routing and does not establish clinician eligibility.
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Encounter clinic handbook — D200(1), D201(1), D202, D205
89 IAC140.400 Payment to Practitioners — (a)(2)
89 IAC140.453 — (b)(2)-(5); actual full HTML recoveredHTTP200 via no-www host
Coverage of LCPC and LMFT services — Coverage; provider qualifications; managed care billing
Blue Cross Community Health Plans
Licensed associate: A qualified post-degree clinician can fit an Illinois FQHC/RHC subclinical pathway, or the distinct approved-agency staffing pathway. This does not establish ordinary private-practice LPC/LSW billing for this destination. Fully licensed LCPC/LMFT coverage must not be denied using the superseded June 2021 handbook exclusion.
Unlicensed graduate: A graduate without independent clinical licensure may qualify in the covered encounter-clinic or approved-agency setting if the actual degree, MHP/QMHP role and supervision requirements are met. Graduation alone does not create private-practice reimbursement.
Student intern: A student placement alone does not satisfy the completed-degree FQHC/RHC pathway. An agency must assess any independently held MHP qualification and its program rules; no general student-intern private-practice payment permission is established.
Before assigning insured clients: Classify the employer as ordinary practitioner/group, enrolled FQHC/RHC, or approved CMHC/BHC before budgeting supervised visits. For an FQHC/RHC hire, verify the qualifying completed degree, clinic-site IMPACT enrollment, and supervision by one of the professionals named in the HFS notice. For CBS services, verify CMHC/BHC employment and the exact MHP/QMHP qualification; a license title or college placement alone is insufficient. Implement the corrected education-based T1040 modifiers for encounters, and obtain the specific plan subclinical rendering/supervisor instructions separately. Do not apply the BCBSIL prelicensed-trainee brand alert to BCCHP without explicit Medicaid product applicability.
Applies to: Illinois HFS fee-for-service and separately identified HealthChoice Illinois products. LPC/LSW or other preclinical status is distinct from independent LCPC/LMFT licensure. FQHC/RHC subclinical coverage requires an applicable completed graduate degree; CBS MHP/QMHP status requires the actual qualifications and approved agency setting. No universal private-practice MCO trainee permission is established.
Verified card/routing references: Blue Cross Community Health Plans. A payer ID identifies routing and does not establish clinician eligibility.
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Reminder on coverage for prelicensed interns and fellows — Billing and supervision reminders
Encounter clinic handbook — D200(1), D201(1), D202, D205
89 IAC140.400 Payment to Practitioners — (a)(2)
89 IAC140.453 — (b)(2)-(5); actual full HTML recoveredHTTP200 via no-www host
Coverage of LCPC and LMFT services — Coverage; provider qualifications; managed care billing
BlueCare / TennCare Select
Licensed associate: BlueCare’s manual supports non-independently licensed master’s-level clinicians who are employees of a licensed Mental Health Outpatient Facility whose BlueCare contract expressly permits this service and supervisor-NPI billing. This does not authorize an ordinary solo/group practice to hire any associate and bill under its owner.
Unlicensed graduate: A nonlicensed master’s-level facility employee may fit BlueCare’s express facility exception with appropriate qualification, regular supervision, roster inclusion and contract permission. This eligibility does not depend on pretending the graduate remains a student. The separate candidate-for-licensure policy was inaccessible.
Student intern: TennCare expressly permits qualified graduate students: accredited eligible graduate program, school-required placement and letter, formal school-agency agreement, licensed outpatient facility with MCO permission and an onsite qualified network supervisor. BlueCare’s manual repeats the student facility/supervisor condition.
Before assigning insured clients: Confirm the facility holds TDMHSAS Mental Health Outpatient Facility licensure and its BlueCare contract expressly permits the relevant student or nonlicensed master’s services. For the master’s employee exception, employ the clinician, maintain appropriate education/training and regular individual supervision, and update the prescribed nonlicensed roster at least quarterly. For a student, obtain school good-standing/required-placement letter and formal school-agency agreement; use a network-enrolled licensed supervisor under that facility. Maintain onsite coverage, no more than four qualified graduate students per supervisor per academic year, at least one individual face-to-face supervision hour weekly, and placement/supervision records. Confirm student-specific modifiers and telehealth implementation; the manual’s conflicting telehealth statements and policy date-history inconsistency remain unresolved.
Applies to: BlueCare/TennCareSelect Medicaid facility services; exclude commercial BCBST, CoverKids and BlueCare Plus adoption. Actual graduate students and post-degree non-independently licensed master’s employees use different qualification tests.
Verified card/routing references: Medicaid Tennessee BlueCare TennCare Select; MC390. A payer ID identifies routing and does not establish clinician eligibility.
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ANSI837 Professional Edits — pp6–12 edits630025,630027,630126/226 and630826/631926
CareSource Indiana
Licensed associate: CareSource members have a distinct CCBHC service pathway that CareSource expressly routes to Gainwell. That supported program route is useful, but ordinary CareSource private-practice associate/nonenrolled-practitioner approval is not established by the FFS module or generic plan claim fields.
Unlicensed graduate: The state qualified completed-degree FFS pathway and CCBHC clinical-hours provisions are documented; CareSource ordinary outpatient acceptance of the exact graduate remains contract-specific. A CCBHC billing its designated encounter route is a separate decision.
Student intern: For covered CCBHC services, current state policy expressly addresses supervised interns and documents the actual clinician while omitting HL/HE. The ordinary CMHC FFS school-placement permission cannot automatically be applied to every CareSource outpatient contract.
Before assigning insured clients: Verify whether the person is individually enrollable or meets the completed master’s/doctoral-degree category in social work, mental health counseling, or marital and family therapy; an associate title alone does not decide the category. Enroll/link the billing entity and qualified supervisor; where applicable complete the group/clinic nonenrolled-staff addendum for the covered clinic specialties. Arrange written review within seven days of intake and thereafter no more than 90 days apart, emergency availability and diagnosis/treatment-plan certification; a cosignature alone is insufficient. For a real student placement, confirm qualifying graduate/postgraduate enrollment, school approval, CMHC specialty 111 and the hospital-affiliation restriction. Apply current state modifiers and the separate CCBHC exception; check statutory practitioner category and allowable service before scheduling telehealth. For a CCBHC service, verify specialty 623 and use Gainwell claims/Acentra authorization rather than the ordinary CareSource route. For ordinary managed-care therapy, secure CareSource acceptance of the exact credential, supervising relationship, roster and rendering identity before assigning the caseload.
Applies to: Indiana IHCP outpatient FFS; independently enrolled clinical professionals, qualified nonenrollable completed-degree practitioners, CMHC student interns and CCBHC encounters are separate paths. Express FFS/MCE modifier bulletins do not make every ordinary FFS enrollment or intern rule a CareSource contract rule.
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CCBHC policy and billing clarifications — p.2: Modifiers HL and HE not used on CCBHC claims
CCBHC services billing reminder — pp1-2; effectiveJan1 2025; NPI623,T1040,Q2/V2,Gainwell,Acentra
CCBHC policy and billing clarifications — p.2: Modifiers HL and HE not used on CCBHC claims
Cenpatico Indiana
Licensed associate: General Cenpatico/MHS associate eligibility remains unresolved; Indiana’s limited CMHC student pathway cannot establish every associate’s permission. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: IHCP recognizes actual graduate/postgraduate students in accredited programs with school approval for a CMHC internship/practicum, supervised by an enrolled practitioner employed/contracted by the billing CMHC. This is a bounded state CMHC pathway; applicability to the exact Cenpatico/MHS member contract remains unresolved.
Before assigning insured clients: Establish CMHC enrollment (type 11, specialty 111), school approval and an eligible enrolled supervisor; hospital-affiliated CMHCs cannot separately bill this intern pathway. Resolve exact MHS/Cenpatico product applicability and the assigned 10570 versus official BH 68068 route; no migration crosswalk established. Separate FFS-only detailed instructions from the bulletin’s FFS/managed-care modifier scope.
Applies to: Indiana CMHC intern pathway; no general commercial or private-group trainee permission. State FFS details do not automatically bind MHS managed care.
Verified card/routing references: 10570. A payer ID identifies routing and does not establish clinician eligibility.
See the “shared routing does not identify the benefit” section above.
Electronic Payer ID Reminder — 08/28/26 medical68069 / behavioral68068; reminder not change
Colorado Access
Licensed associate: Colorado’s oversight framework contemplates prelicensed services and imposes attestation/U9 obligations. A proposed clinician must fit the actual current state category and this RAE’s contracted arrangement. The accessible sources do not establish a universal eligible-license list or current supervisor/rendering requirements.
Unlicensed graduate: A post-degree unlicensed practitioner may fall within the supervised workforce framework, subject to actual qualification and contracted RAE approval. Degree alone and the presence of U9 do not establish payment.
Student intern: The unlicensed/prelicensed workforce framework does not by itself establish that every pre-degree student placement is reimbursable. Confirm student education, placement, service and current RAE eligibility separately; do not rename all unlicensed staff student interns.
Before assigning insured clients: Verify the exact workforce category, qualifying current supervisor and covered service under the contracted RAE’s current oversight policy. Submit the required annual January 1 oversight attestation to each contracted RAE and confirm the current accepted form and recipient. Use U9 on applicable supervised lines; do not resurrect the withdrawn state Box 19 requirement or assume a surviving separate January 2027 NPI mandate. Obtain current RAE-specific renderer, supervision, roster and telehealth instructions; do not use a search-only prelicensed ratio as policy.
Applies to: Health First Colorado behavioral-health oversight for Colorado Access. Licensed associates/prelicensed clinicians, post-degree unlicensed practitioners and pre-degree students are distinct. Colorado Access evidence is not CCHA implementation evidence.
Verified card/routing references: Colorado Access; COACC. A payer ID identifies routing and does not establish clinician eligibility.
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Health First Colorado Provider Bulletin B2600533 January2026 — p10 Final RPO Policy/Attestation
Colorado Community Health Alliance
Licensed associate: Colorado’s oversight framework contemplates prelicensed services and imposes attestation/U9 obligations. A proposed clinician must fit the actual current state category and this RAE’s contracted arrangement. The accessible sources do not establish a universal eligible-license list or current supervisor/rendering requirements.
Unlicensed graduate: A post-degree unlicensed practitioner may fall within the supervised workforce framework, subject to actual qualification and contracted RAE approval. Degree alone and the presence of U9 do not establish payment.
Student intern: The unlicensed/prelicensed workforce framework does not by itself establish that every pre-degree student placement is reimbursable. Confirm student education, placement, service and current RAE eligibility separately; do not rename all unlicensed staff student interns.
Before assigning insured clients: Verify the exact workforce category, qualifying current supervisor and covered service under the contracted RAE’s current oversight policy. Submit the required annual January 1 oversight attestation to each contracted RAE and confirm the current accepted form and recipient. Use U9 on applicable supervised lines; do not resurrect the withdrawn state Box 19 requirement or assume a surviving separate January 2027 NPI mandate. Obtain current RAE-specific renderer, supervision, roster and telehealth instructions; do not use a search-only prelicensed ratio as policy.
Applies to: Health First Colorado behavioral-health oversight for Colorado Community Health Alliance. Licensed associates/prelicensed clinicians, post-degree unlicensed practitioners and pre-degree students are distinct. Colorado Access evidence is not CCHA implementation evidence.
Verified card/routing references: Colorado Community Health Alliance; COCHA. A payer ID identifies routing and does not establish clinician eligibility.
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Colorado Medicaid Standards for Unlicensed Practitioners FAQ — Questions4–9, pp.1–2
Health First Colorado Provider Bulletin B2600533 January2026 — p10 Final RPO Policy/Attestation
Provider Resources and Training — Public provider resources
Community Care Pennsylvania
Licensed associate: Master’s-level contracted clinicians may bill only their own services; supervision does not authorize psychotherapy by another licensed clinician. A psychology exception permits only psychological services outside another license’s own scope and within Chapter 41 conditions.
Unlicensed graduate: The alert describes master’s-level clinicians without another BPOA-governed license providing therapy/testing under a contracted psychologist, but also requires Chapter 41 graduate psychology training. A master’s degree alone does not establish that doctoral-training condition.
Student intern: A qualifying doctoral psychology intern/trainee can fit the psychologist pathway when Chapter 41 is met. Graduate training means at least 15 graduate semester hours in the defined doctoral psychology program; a generic master’s counseling placement is not established by the word intern.
Before assigning insured clients: Choose the actual supervisor category: master’s-level provider prohibition versus contracted psychologist exception. Verify Chapter 41 graduate psychology training, competence, emergency availability, required face-to-face consultation, records and disclosure of supervised status. Respect the stated three-full-time-equivalent employee supervision limit and obtain required delegation/subcontract approvals.
Applies to: All Community Care HealthChoices contracts for individually credentialed/group practitioners; excludes licensed outpatient psychiatric clinics under Chapter 5200. This is separate from UPMC commercial credentialing.
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Florida Medicaid
Licensed associate: The Medicaid therapy policy permits defined master’s-level practitioners in a community behavioral health agency, but the reviewed evidence does not establish that a registered mental-health counselor intern automatically meets that category or can bill independently. Registered intern is a post-degree registration, not a licensed-independent-clinician or pre-degree student label.
Unlicensed graduate: A graduate who actually meets Medicaid’s applicable master’s-level practitioner definition and agency requirements can fit the documented individual/group therapy provider category. The current controlling definition and its application to a particular registered intern remain unresolved.
Student intern: No general pre-degree student individual-therapy reimbursement pathway was established. The agency policy’s master’s-level and group-only bachelor’s categories require their own actual qualifications; school enrollment alone supplies neither.
Before assigning insured clients: Use a community behavioral health agency employment/contract arrangement for this benefit and establish the precise Medicaid practitioner category and permissible service. For an RMHCI hire, verify issued registration and the board-approved qualified supervisor before supervised practice; retain the required shared supervision logs and cadence. Verify member coverage, agency participation, clinician enrollment/roster rules and actual renderer with AHCA or the identified managed-care plan. Confirm the current master’s-level definition, code/fee-schedule eligibility, Medicaid documentation and telehealth requirements; do not infer claim rules from board supervision logs.
Applies to: Florida AHCA behavioral-health therapy agency benefit; member FFS versus named SMMC plan must be verified. Board-authorized RMHCI supervision is clinical authority and is not Medicaid enrollment or payment approval.
Verified card/routing references: Medicaid Florida; 77027. A payer ID identifies routing and does not establish clinician eligibility.
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Behavioral Health Therapy Services Coverage Policy — §§1.2,3.2,6.2,7.2,8.2–8.3, pp.1–5
2026 Florida Statutes491.0045 — §491.0045(1)–(3) intern registration/supervision
Medicaid Florida — ZDEIS primary77027; FloridaAHCA; Medicaid
Healthy Blue Kansas
Licensed associate: Kansas’s approved 2023 amendment recognizes licensed clinicians practicing under qualified supervision. That is positive licensed-associate context, but the reviewed sources do not establish this MCO’s acceptance of the exact license/setting or authorize independent practice billing.
Unlicensed graduate: A degree without a license must not be treated as the licensed-under-supervision category. FFS excludes nonlicensed psychotherapy; this plan’s exact program/contract acceptance remains unresolved.
Student intern: No plan-specific permission for actual student-intern psychotherapy was established. Traditional FFS excludes therapy by nonlicensed persons; that scoped restriction is not evidence of a universal KanCare MCO ban.
Before assigning insured clients: Verify the exact active Kansas license and whether the clinician is licensed under supervision versus wholly nonlicensed. Complete KMAP enrollment and separately obtain the selected MCO network/contract decision for the credential, setting, service and date. Document the qualified clinical-level/physician supervisor and obtain plan-specific rendering, roster, telehealth and claim instructions before treating insured clients.
Applies to: Kansas KanCare Healthy Blue Kansas; dated SPA evidence recognizes supervised licensees. The June 2026 KMAP psychotherapy exclusion is traditional FFS only. Neither MCO adoption nor a private-practice supervisee contract is established.
Verified card/routing references: 00047. A payer ID identifies routing and does not establish clinician eligibility.
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KanCare provider enrollment — KMAP enrollment FAQ; MCO selection and contracting
Highmark Delaware Health Options
Licensed associate: The independent licensed-behavioral-health-practitioner benefit does not create general associate billing permission; its express psychologist-supervised assistant/postdoctoral exclusion must be respected. Separately licensed SUD/OTP and other identified program benefits have different staffing rules, not a general private-practice workaround.
Unlicensed graduate: A qualified graduate may fit a defined unlicensed counselor/technician role in a properly licensed/enrolled SUD/OTP program. The program, role, benefit owner and HHO contract must actually support the service; this is not independent LBHP eligibility.
Student intern: No general Health Options student-intern private-practice therapy route was established. A program must establish the actual trainee qualification and covered program benefit; an unlicensed staff category is not automatically an academic placement.
Before assigning insured clients: Identify the precise covered benefit and payer/program owner before hiring for insured visits. If using a program pathway, verify program licensure, DMAP enrollment, permitted staff credentials and HHO contract acceptance. For the applicable unlicensed program staffing rule, arrange QHP availability and observe the manual’s maximum of ten unlicensed staff; do not carry that ratio into every benefit. Obtain service-specific rendering identity, documentation, modifiers and telehealth instructions for the approved benefit.
Applies to: Highmark Health Options Delaware Medicaid. Distinguish independent LBHP services from EPSDT, rehabilitation, HCBS and licensed SUD/OTP program benefits. New York Highmark rules are unrelated.
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2026 Provider Manual — pp.44,67,107,131–133: benefits/auth/FWA/CMS1500/payerID
DSAMH Provider Enrollment Questions & Answers — pp.1–3; program intake questionnaire
Highmark NY Medicaid and CHP
Licensed associate: New York Medicaid expressly supports the specified limited-permit and LMSW supervised routes, and designated CFTSS agencies have separate limited-permit provisions. Highmark’s exact private-practice contract acceptance is not established; Child Health Plus CFTSS benefit coverage does not automatically adopt Medicaid trainee claim identity.
Unlicensed graduate: A graduate must hold the applicable limited permit or other actual qualifying credential/program role. The same-profession permit route differs from a pre-degree student placement. A bare degree does not establish Highmark payment.
Student intern: The ordinary Medicaid therapy manual permits student-involved sessions only with the licensed clinician continuously present and actively guiding care, with no simultaneous other work. Separately designated CFTSS/HCBS agencies have their own same-profession student guidance; apply that program and contract boundary. Highmark/CHP-specific trainee acceptance remains to be confirmed.
Before assigning insured clients: Verify exact permit/license, scope and matching qualified supervisor; limited-permit holders cannot independently enroll in Medicaid. For ordinary student-involved therapy, budget continuous licensed-clinician attendance and clinician-authored/signed documentation; a student-only caseload is not the documented ordinary route. For CFTSS, verify agency designation/Medicaid enrollment, eligible practitioner OPRA enrollment and the service-specific network contract or approved single-case arrangement. For Highmark/CHP, confirm the actual benefit, clinician acceptance and applicable claims identity; obtain program telehealth approval and preserve supervision qualifications.
Applies to: Highmark New York Medicaid managed care and separately Child Health Plus. Distinguish private practitioner FFS eligibility, Highmark contracted professional services, and designated CFTSS/HCBS agencies. CFTSS benefit coverage includes CHP, but Medicaid-only attending guidance is not automatically CHP filing guidance.
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LCSW, LMHC and LMFT Policy Manual — pp.7–11; Limited Permit Holders; Student Interns; Article28
Humana Healthy Horizons Louisiana
Licensed associate: Humana Healthy Horizons Louisiana lists PLPC, PLMFT, LMSW and CSW within service-specific qualifications. Other CPST components may use these categories, but CPST/PSR assessment and treatment planning require fully licensed professionals. This is not blanket outpatient psychotherapy permission.
Unlicensed graduate: For the documented CPST components, the candidate must hold a named provisional/master’s credential or qualify as an APA-program psychology intern. The adjacent PSR rule separately permits some bachelor’s-qualified personnel for eligible non-assessment work; do not turn the CPST restriction into a ban on all unlicensed graduates. Assessment/treatment planning still requires a fully licensed professional.
Student intern: The cited category is an intern in an APA-approved psychology internship program, not a generic counseling or social-work student placement. Eligibility remains service/component-specific.
Before assigning insured clients: Bind the patient to Louisiana Healthy Horizons and the intended service/component and setting. Confirm the service is delivered through the required licensed and accredited provider agency; the CPST component rule is not a freestanding private-office psychotherapy permission. Reserve CPST/PSR assessment and treatment planning for fully licensed staff; match other CPST tasks to permitted personnel. Confirm enrollment, supervision, authorization and claim mapping for the exact service instead of importing commercial supervisory modifiers.
Applies to: 2026 Louisiana Healthy Horizons Medicaid only. No inference to Humana commercial, Medicare Advantage, other states or every service.
Verified card/routing references: Humana Healthy Horizons in Louisiana; 61101. A payer ID identifies routing and does not establish clinician eligibility.
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Illinois Medicaid
Licensed associate: A qualified post-degree clinician can fit an Illinois FQHC/RHC subclinical pathway, or the distinct approved-agency staffing pathway. This does not establish ordinary private-practice LPC/LSW billing for this destination. Fully licensed LCPC/LMFT coverage must not be denied using the superseded June 2021 handbook exclusion.
Unlicensed graduate: A graduate without independent clinical licensure may qualify in the covered encounter-clinic or approved-agency setting if the actual degree, MHP/QMHP role and supervision requirements are met. Graduation alone does not create private-practice reimbursement.
Student intern: A student placement alone does not satisfy the completed-degree FQHC/RHC pathway. An agency must assess any independently held MHP qualification and its program rules; no general student-intern private-practice payment permission is established.
Before assigning insured clients: Classify the employer as ordinary practitioner/group, enrolled FQHC/RHC, or approved CMHC/BHC before budgeting supervised visits. For an FQHC/RHC hire, verify the qualifying completed degree, clinic-site IMPACT enrollment, and supervision by one of the professionals named in the HFS notice. For CBS services, verify CMHC/BHC employment and the exact MHP/QMHP qualification; a license title or college placement alone is insufficient. Implement the corrected education-based T1040 modifiers for encounters, and obtain the specific plan subclinical rendering/supervisor instructions separately.
Applies to: Illinois HFS fee-for-service and separately identified HealthChoice Illinois products. LPC/LSW or other preclinical status is distinct from independent LCPC/LMFT licensure. FQHC/RHC subclinical coverage requires an applicable completed graduate degree; CBS MHP/QMHP status requires the actual qualifications and approved agency setting. No universal private-practice MCO trainee permission is established.
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Encounter clinic handbook — D200(1), D201(1), D202, D205
89 IAC140.400 Payment to Practitioners — (a)(2)
89 IAC140.453 — (b)(2)-(5); actual full HTML recoveredHTTP200 via no-www host
Coverage of LCPC and LMFT services — Coverage; provider qualifications; managed care billing
Indiana Medicaid
Licensed associate: Eligible enrolled clinicians have an own-NPI route; qualified nonenrollable completed-degree practitioners have a documented supervised outpatient FFS route. Confirm the exact degree and enrollment category rather than using associate as a universal billing credential.
Unlicensed graduate: A completed qualifying master’s or doctoral degree can support the specified nonenrolled-practitioner FFS route with an enrolled supervisor and billing entity. Student status is a separate CMHC category.
Student intern: A qualifying currently enrolled graduate/postgraduate student approved for placement at an IHCP CMHC can fit the FFS CMHC intern pathway. Hospital-owned/affiliated CMHCs cannot separately bill these intern services. This is not a general private-group student pathway.
Before assigning insured clients: Verify whether the person is individually enrollable or meets the completed master’s/doctoral-degree category in social work, mental health counseling, or marital and family therapy; an associate title alone does not decide the category. Enroll/link the billing entity and qualified supervisor; where applicable complete the group/clinic nonenrolled-staff addendum for the covered clinic specialties. Arrange written review within seven days of intake and thereafter no more than 90 days apart, emergency availability and diagnosis/treatment-plan certification; a cosignature alone is insufficient. For a real student placement, confirm qualifying graduate/postgraduate enrollment, school approval, CMHC specialty 111 and the hospital-affiliation restriction. Apply current state modifiers and the separate CCBHC exception; check statutory practitioner category and allowable service before scheduling telehealth.
Applies to: Indiana IHCP outpatient FFS; independently enrolled clinical professionals, qualified nonenrollable completed-degree practitioners, CMHC student interns and CCBHC encounters are separate paths. Express FFS/MCE modifier bulletins do not make every ordinary FFS enrollment or intern rule a CareSource contract rule.
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CCBHC policy and billing clarifications — p.2: Modifiers HL and HE not used on CCBHC claims
Medi-Cal
Licensed associate: Medi-Cal NSMHS permits AMFTs, APCCs, ASWs and registered psychological associates to render under a qualified supervising clinician within the stated scope.
Unlicensed graduate: Graduation alone does not substitute for the named associate/registration status and lawful supervision.
Student intern: The cited NSMHS associate categories do not establish a general student practicum payment pathway.
Before assigning insured clients: Verify board associate registration and qualified supervision within the NSMHS scope. Establish the enrolled supervising provider and correct manual/plan billing instructions before the first insured visit. Distinguish FFS NSMHS from county specialty mental health and managed-care administration.
Applies to: Medi-Cal non-specialty mental health, not an automatic county SMHS or every managed-care contract permission.
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Meridian Illinois
Licensed associate: A qualified post-degree clinician can fit an Illinois FQHC/RHC subclinical pathway, or the distinct approved-agency staffing pathway. This does not establish ordinary private-practice LPC/LSW billing for this destination. Fully licensed LCPC/LMFT coverage must not be denied using the superseded June 2021 handbook exclusion.
Unlicensed graduate: A graduate without independent clinical licensure may qualify in the covered encounter-clinic or approved-agency setting if the actual degree, MHP/QMHP role and supervision requirements are met. Graduation alone does not create private-practice reimbursement.
Student intern: A student placement alone does not satisfy the completed-degree FQHC/RHC pathway. An agency must assess any independently held MHP qualification and its program rules; no general student-intern private-practice payment permission is established.
Before assigning insured clients: Classify the employer as ordinary practitioner/group, enrolled FQHC/RHC, or approved CMHC/BHC before budgeting supervised visits. For an FQHC/RHC hire, verify the qualifying completed degree, clinic-site IMPACT enrollment, and supervision by one of the professionals named in the HFS notice. For CBS services, verify CMHC/BHC employment and the exact MHP/QMHP qualification; a license title or college placement alone is insufficient. Implement the corrected education-based T1040 modifiers for encounters, and obtain the specific plan subclinical rendering/supervisor instructions separately. Use Meridian’s encounter table for that product only; resolve its inconsistent February effective-year statements before relying on a denial date.
Applies to: Illinois HFS fee-for-service and separately identified HealthChoice Illinois products. LPC/LSW or other preclinical status is distinct from independent LCPC/LMFT licensure. FQHC/RHC subclinical coverage requires an applicable completed graduate degree; CBS MHP/QMHP status requires the actual qualifications and approved agency setting. No universal private-practice MCO trainee permission is established.
Verified card/routing references: Meridian. A payer ID identifies routing and does not establish clinician eligibility.
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Encounter clinic handbook — D200(1), D201(1), D202, D205
89 IAC140.400 Payment to Practitioners — (a)(2)
89 IAC140.453 — (b)(2)-(5); actual full HTML recoveredHTTP200 via no-www host
Coverage of LCPC and LMFT services — Coverage; provider qualifications; managed care billing
Molina Illinois
Licensed associate: A qualified post-degree clinician can fit an Illinois FQHC/RHC subclinical pathway, or the distinct approved-agency staffing pathway. This does not establish ordinary private-practice LPC/LSW billing for this destination. Fully licensed LCPC/LMFT coverage must not be denied using the superseded June 2021 handbook exclusion.
Unlicensed graduate: A graduate without independent clinical licensure may qualify in the covered encounter-clinic or approved-agency setting if the actual degree, MHP/QMHP role and supervision requirements are met. Graduation alone does not create private-practice reimbursement.
Student intern: A student placement alone does not satisfy the completed-degree FQHC/RHC pathway. An agency must assess any independently held MHP qualification and its program rules; no general student-intern private-practice payment permission is established.
Before assigning insured clients: Classify the employer as ordinary practitioner/group, enrolled FQHC/RHC, or approved CMHC/BHC before budgeting supervised visits. For an FQHC/RHC hire, verify the qualifying completed degree, clinic-site IMPACT enrollment, and supervision by one of the professionals named in the HFS notice. For CBS services, verify CMHC/BHC employment and the exact MHP/QMHP qualification; a license title or college placement alone is insufficient. Implement the corrected education-based T1040 modifiers for encounters, and obtain the specific plan subclinical rendering/supervisor instructions separately. Obtain current Molina Illinois Medicaid implementation instructions; the assigned 2026 manual URL was inaccessible, which does not establish exclusion.
Applies to: Illinois HFS fee-for-service and separately identified HealthChoice Illinois products. LPC/LSW or other preclinical status is distinct from independent LCPC/LMFT licensure. FQHC/RHC subclinical coverage requires an applicable completed graduate degree; CBS MHP/QMHP status requires the actual qualifications and approved agency setting. No universal private-practice MCO trainee permission is established.
Verified card/routing references: Molina Healthcare of Illinois. A payer ID identifies routing and does not establish clinician eligibility.
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Encounter clinic handbook — D200(1), D201(1), D202, D205
89 IAC140.400 Payment to Practitioners — (a)(2)
89 IAC140.453 — (b)(2)-(5); actual full HTML recoveredHTTP200 via no-www host
Coverage of LCPC and LMFT services — Coverage; provider qualifications; managed care billing
Molina Washington
Licensed associate: Washington Apple Health Part I expressly permits licensed mental-health associates affiliated under a facility/clinic, using their own servicing NPI. That supports the state associate pathway; Molina’s exact product contract/roster approval remains unverified. It does not establish solo independent associate billing or Part II individual servicing identity.
Unlicensed graduate: A degree without the applicable licensed-associate credential does not meet the documented Part I associate route. A different program staff category would need separate evidence.
Student intern: The cited licensed-associate pathway does not establish student-intern eligibility. A pre-degree student cannot use an associate credential or own servicing identity merely by joining a clinic.
Before assigning insured clients: Verify active licensed-associate credential and actual Apple Health benefit/product; the payer destination alone spans multiple products. For Part I, register the clinician’s own servicing NPI in ProviderOne under the enrolled facility/clinic and obtain Molina contract/roster acceptance. Use current October 2026 taxonomy rules, including the Medicaid-only versus dual-claim distinction, rather than only a historical transition notice. Determine Part I versus Part II before claims setup: the latter uses the clinic identity and prohibits an individual servicing NPI. Confirm plan-specific supervision, documentation and telehealth rules before assigning that work.
Applies to: Molina Washington Apple Health Medicaid only after product confirmation. The assigned payer destination also covers commercial and Medicare. Part I facility-affiliated associate services and Part II specialized agency services are distinct lanes.
Verified card/routing references: Molina HealthCare Washington; 38336. A payer ID identifies routing and does not establish clinician eligibility.
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Mental Health Services Billing Guide — pp.35–36,42–43; PartII pp.84–85
Molina HealthCare Washington — Primary38336; aliases; Programs Commercial,Medicare,Medicaid
Oregon Medicaid
Licensed associate: OHA’s board-registered associates may currently serve/bill OHP under applicable rules, but the July 1, 2027 change generally requires full licensure or employment in a COA-holding agency, subject to listed setting exemptions.
Unlicensed graduate: A graduate must obtain the relevant board associate registration and meet current practice/enrollment conditions; the degree alone is insufficient.
Student intern: OHA’s board-registered-associate transition page is not student-practicum reimbursement authority.
Before assigning insured clients: Verify board registration, current OHP enrollment and CCO contracting separately. Map likely full licensure against July 1, 2027 and determine COA employment or a documented setting exemption if needed. Check whether the specific CCO adopts requirements earlier and recheck OHA’s current effective date before staffing commitments.
Applies to: OHP across CCO and Open Card; state baseline and CCO participation are distinct. Do not use Moda commercial rules.
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UHC Kansas KanCare
Licensed associate: Kansas’s approved 2023 amendment recognizes licensed clinicians practicing under qualified supervision. That is positive licensed-associate context, but the reviewed sources do not establish this MCO’s acceptance of the exact license/setting or authorize independent practice billing.
Unlicensed graduate: A degree without a license must not be treated as the licensed-under-supervision category. FFS excludes nonlicensed psychotherapy; this plan’s exact program/contract acceptance remains unresolved.
Student intern: No plan-specific permission for actual student-intern psychotherapy was established. Traditional FFS excludes therapy by nonlicensed persons; that scoped restriction is not evidence of a universal KanCare MCO ban.
Before assigning insured clients: Verify the exact active Kansas license and whether the clinician is licensed under supervision versus wholly nonlicensed. Complete KMAP enrollment and separately obtain the selected MCO network/contract decision for the credential, setting, service and date. Document the qualified clinical-level/physician supervisor and obtain plan-specific rendering, roster, telehealth and claim instructions before treating insured clients.
Applies to: Kansas KanCare UnitedHealthcare Community Plan - KS (KanCare); dated SPA evidence recognizes supervised licensees. The June 2026 KMAP psychotherapy exclusion is traditional FFS only. Neither MCO adoption nor a private-practice supervisee contract is established.
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KanCare provider enrollment — KMAP enrollment FAQ; MCO selection and contracting
Virginia Medicaid
Licensed associate: Virginia Medicaid expressly recognizes LMHP-R, LMHP-RP and LMHP-S outpatient services with board-preapproved duties/site and direct personal supervision by a qualified Medicaid-enrolled licensed professional. These defined resident/supervisee credentials are the relevant associate-type category; an undefined associate title is insufficient.
Unlicensed graduate: A graduate who actually qualifies and obtains the required board preapproval as a resident/supervisee may use the documented supervised pathway. An unregistered graduate’s degree alone does not establish eligibility.
Student intern: The cited resident/supervisee permission does not establish a general pre-degree student-intern outpatient therapy pathway. Student status must not be relabeled LMHP-R, LMHP-RP or LMHP-S.
Before assigning insured clients: Verify the exact LMHP-R/RP/S category and written board preapproval for duties, site and supervision before clinical assignment. Use a qualified licensed Medicaid-enrolled supervisor and arrange direct personal supervision. Have both clinicians date/sign therapy documentation and the supervisor cosign within one business day of the service. Confirm enrollment, billing entity and resident/supervisor claim identity with DMAS; separately verify telehealth and any MCO acceptance.
Applies to: Virginia DMAS outpatient psychiatric-services rules and the approved state-plan resident/supervisee category. Managed-care contract acceptance and claim identity remain separate; this is not automatic Aetna Better Health approval.
Verified card/routing references: Medicaid Virginia; 10198. A payer ID identifies routing and does not establish clinician eligibility.
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Approved Virginia SPA24-0005 — Attachment3.1-A&B Supplement1 p10.0, Non-Licensed Practitioners
Telehealth Services Supplement — pp2,6,9–10 Provider definition, POS/modifiers, requirements/consent
Wisconsin Medicaid
Licensed associate: Wisconsin reimburses enrolled QTTs: LPC-IT, LMFT-IT, APSW/ISW accumulating clinical licensure hours, and unlicensed doctoral psychologists working toward full licensure, under Medicaid-enrolled licensed supervision.
Unlicensed graduate: An unlicensed doctoral psychologist can fit the enrolled QTT pathway. A master’s graduate generally needs the specified DSPS training license/certification; degree-only graduate status is not enough.
Student intern: A graduate student in a supervised practicum can have services reimbursed through the distinct student pathway, not individual QTT enrollment. Follow DHS 107.01(2) service conditions, direct immediate on-premises enrolled supervision, written supervisor documentation and applicable clinic/biller requirements.
Before assigning insured clients: Complete the correct individual QTT enrollment and licensed supervisor/billing-provider enrollment; report group affiliations. For student practicum establish the school/clinic arrangement, allowable billing setting, required direct on-premises supervision and written documentation instead of applying ordinary enrolled-QTT assumptions. Preview QTT rendering NPI with U6 for master’s-level or HP doctoral-level; student pathway uses supervisor rendering NPI plus U7 and applicable professional modifier. Verify current service, setting, telehealth and managed-care implementation; Medicaid payment does not guarantee board credit for supervised hours.
Applies to: ForwardHealth BadgerCare Plus/Medicaid; QTT settings expanded beyond DHS35/75 clinics in 2024, including practitioner offices subject to benefit/POS policy. Do not extend that expansion indiscriminately to student practicum rules or assume every HMO’s participation is automatic.
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Wyoming Medicaid
Licensed associate: Wyoming Medicaid expressly covers the listed provisionally licensed mental-health professionals: PPC, PLAT, PCSW and PMFT. They must satisfy the enrollment/supervision arrangement; ordinary in-person claims identify the actual provisional clinician. This is stronger than a generic trainee exception.
Unlicensed graduate: A degree without provisional licensure or a qualifying sponsored resident/student category is not established as eligible. Do not turn the student/resident provision into general permission for every graduate.
Student intern: The manual expressly permits covered services by sponsored residents and student interns per Medicaid policy, billed with the clinical supervisor NPI and HL. Sponsor/placement qualification still needs confirmation; this is a real student category, not a synonym for provisional licensure.
Before assigning insured clients: Obtain the actual qualifying provisional license and enroll through the permitted professional/group affiliation before treating covered clients. Before the listed provisional clinician begins clinical practice, provide DQCS documentation to the Board and obtain approval. Arrange an approved DQCS’s clinical supervision and the employer’s administrative supervision; the listed certified/provisional providers may not supervise other clinical staff. For students/residents, verify the Medicaid-compliant sponsorship and supervise within the sponsor’s approved practice; retain the actual provider identity. Ensure ready supervisor availability, including suitable telecommunications, and final responsibility for care. Resolve the distinct telehealth supervising-provider instruction before assigning remote visits; separately screen Medicare-primary eligibility and the explicit PMFT Medicare exception.
Applies to: Wyoming state Medicaid; separate in-person provisional, sponsored resident/student, telehealth and Medicare-primary requirements. Shared taxonomy does not establish Medicare enrollment.
Verified card/routing references: Medicaid Wyoming; 77046. A payer ID identifies routing and does not establish clinician eligibility.
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Traditional Medicare routes
Medicare Florida Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Illinois Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Indiana Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Northern California Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Ohio Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Pennsylvania Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Railroad
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Southern California Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Tennessee Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Texas Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Washington Part B
Licensed associate: No direct payment merely for associate status. A qualified auxiliary-personnel arrangement may be reimbursable through an eligible incident-to billing practitioner, such as a physician or clinical psychologist, if all service, setting and state-law requirements fit. An LCSW, MFT or MHC supervisor does not acquire the same incident-to benefit simply by supervising.
Unlicensed graduate: A graduate may fit qualified auxiliary personnel only where state law permits the work and the eligible practitioner/service arrangement meets the incident-to benefit; a degree and supervisor signature alone are insufficient.
Student intern: Student placement alone establishes no payment pathway. Assess actual auxiliary qualifications and state-law authority under the eligible practitioner benefit; neither a universal student ban nor universal permission follows.
Before assigning insured clients: Identify an eligible billing practitioner and the applicable statutory benefit before hiring against Medicare revenue. Verify auxiliary personnel qualifications, state-law authority and employment/contract relationship; establish the required initial professional service, plan and continuing involvement. Arrange applicable supervision; qualifying behavioral health services may use general supervision, without eliminating the other conditions.
Applies to: Original Medicare Part B; regional and Railroad routes do not create separate state benefits. Medicare Advantage and supplements require separate analysis.
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Medicare Advantage products
Blue Cross Medicare Advantage
Licensed associate: The assigned sources do not establish this Advantage product’s associate eligibility or enrollment pathway. Original Medicare incident-to conditions are background, not approval for this plan.
Unlicensed graduate: No plan-specific unlicensed-graduate payment authority is established.
Student intern: No plan-specific student-intern payment authority is established.
Before assigning insured clients: Identify the exact Medicare Advantage contract/product and behavioral-health administrator, then obtain its provider-category and participation requirements. Resolve how the proposed practitioner and auxiliary arrangement meets the applicable benefit before assuming supervisor billing.
Applies to: Medicare Advantage product-specific determination required; do not import commercial or regional Original Medicare enrollment.
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Devoted Health
Licensed associate: The assigned sources do not establish this Advantage product’s associate eligibility or enrollment pathway. Original Medicare incident-to conditions are background, not approval for this plan.
Unlicensed graduate: No plan-specific unlicensed-graduate payment authority is established.
Student intern: No plan-specific student-intern payment authority is established.
Before assigning insured clients: Identify the exact Medicare Advantage contract/product and behavioral-health administrator, then obtain its provider-category and participation requirements. Resolve how the proposed practitioner and auxiliary arrangement meets the applicable benefit before assuming supervisor billing.
Applies to: Medicare Advantage product-specific determination required; do not import commercial or regional Original Medicare enrollment.
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Medicare supplements
AARP Medicare Supplement
Licensed associate: A Medigap destination does not independently authorize an associate service. Resolve Original Medicare provider and service eligibility, then secondary coverage.
Unlicensed graduate: No independent unlicensed-graduate pathway arises from supplemental coverage.
Student intern: No independent student permission arises from Medigap; primary Medicare benefit analysis controls.
Before assigning insured clients: Confirm the actual policy is Medigap and establish primary Medicare benefit/provider eligibility. Resolve primary adjudication and the supplement’s coordination provisions before projecting secondary collections.
Applies to: This assessment is limited to the named Medicare supplement; it does not cover same-brand commercial or Advantage products.
See the “medicare supplements resolve the primary service first” section above.
Cigna Medicare Supplement
Licensed associate: A Medigap destination does not independently authorize an associate service. Resolve Original Medicare provider and service eligibility, then secondary coverage.
Unlicensed graduate: No independent unlicensed-graduate pathway arises from supplemental coverage.
Student intern: No independent student permission arises from Medigap; primary Medicare benefit analysis controls.
Before assigning insured clients: Confirm the actual policy is Medigap and establish primary Medicare benefit/provider eligibility. Resolve primary adjudication and the supplement’s coordination provisions before projecting secondary collections.
Applies to: This assessment is limited to the named Medicare supplement; it does not cover same-brand commercial or Advantage products.
See the “medicare supplements resolve the primary service first” section above.
Medico / Wellabe
Licensed associate: A Medigap destination does not independently authorize an associate service. Resolve Original Medicare provider and service eligibility, then secondary coverage.
Unlicensed graduate: No independent unlicensed-graduate pathway arises from supplemental coverage.
Student intern: No independent student permission arises from Medigap; primary Medicare benefit analysis controls.
Before assigning insured clients: Confirm the actual policy is Medigap and establish primary Medicare benefit/provider eligibility. Resolve primary adjudication and the supplement’s coordination provisions before projecting secondary collections.
Applies to: This assessment is limited to the named Medicare supplement; it does not cover same-brand commercial or Advantage products.
See the “medicare supplements resolve the primary service first” section above.
Mutual of Omaha
Licensed associate: A Medigap destination does not independently authorize an associate service. Resolve Original Medicare provider and service eligibility, then secondary coverage.
Unlicensed graduate: No independent unlicensed-graduate pathway arises from supplemental coverage.
Student intern: No independent student permission arises from Medigap; primary Medicare benefit analysis controls.
Before assigning insured clients: Confirm the actual policy is Medigap and establish primary Medicare benefit/provider eligibility. Resolve primary adjudication and the supplement’s coordination provisions before projecting secondary collections.
Applies to: This assessment is limited to the named Medicare supplement; it does not cover same-brand commercial or Advantage products.
See the “medicare supplements resolve the primary service first” section above.
Employee assistance programs
Aetna EAP
Licensed associate: Aetna EAP associate eligibility is unestablished; commercial supervisory permission and provider-specific authorization do not establish an EAP exception. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: Aetna EAP student eligibility is unestablished; authorization cannot be transferred from another provider. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Obtain the provider-specific EAP authorization and establish the actual treating clinician’s eligibility; the authorization cannot be transferred from another provider.
Applies to: March 2026 EAP manual p.9 requires Aetna network application, initial credentialing and three-year recredentialing, with CAQH authorization. This generic admission process does not establish an associate exception. Provider-specific, nontransferable authorization and EAP20/REF G1 are documented p.11. Neither authorization nor commercial Aetna supervisory permission establishes EAP trainee eligibility or rendering/supervisor fields.
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ComPsych
Licensed associate: ComPsych’s public individual network criteria require the highest state license/certification, a master’s degree and three postgraduate years (doctorate for psychologists). A nonindependent associate does not satisfy this published individual pathway. A facility/group exception is not established.
Unlicensed graduate: An unlicensed graduate does not satisfy the published individual admission criteria. This is not proof of a universal prohibition under every facility contract.
Student intern: An ordinary student placement does not satisfy the published individual admission criteria. No group/facility exception is established in the reviewed public sources.
Before assigning insured clients: Evaluate candidate against highest-license, degree and experience criteria before planning individual panel admission. Identify EAP versus managed-care agreement and obtain any claimed facility/group exception in writing.
Applies to: Public individual ComPsych network admission, not every organizational arrangement or product.
Verified card/routing references: 37363. A payer ID identifies routing and does not establish clinician eligibility.
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Provider ResourceCenter — Public login/navigation
Provider ResourceCenter Credentialing — Credentialing requirements bullets; administration help
Quest EAP
Licensed associate: Quest stopped provider credentialing effective September 2026 and provider contracts terminate December 31, 2026. Previously accepted licensed associates may meet the remaining applicable benefit conditions, but a new hire cannot be budgeted on an ordinary new Quest enrollment. Any transition SCA requires its own documented eligibility.
Unlicensed graduate: An unlicensed graduate cannot use supervisor-substitution billing under the standard outpatient rule; licensed associates are a different category.
Student intern: The standard outpatient pathway requires a valid license. An unlicensed student cannot use a supervisor’s license/NPI to satisfy it.
Before assigning insured clients: Do not count on a new ordinary Quest credentialing application: credentialing stopped in September 2026. Confirm existing clinician acceptance or actual eligibility for the short-term transition SCA, available for current treating providers participating in or pursuing the member’s successor network; it is not automatic new-hire approval. Verify individual credentialing/acceptance and the exact employer benefit and service date. Confirm the program is still administered by Quest: UPHS/UPENN ended June 30, 2026; WellSpan BH/EAP continues through December 31, 2026; other employer dates differ. Use treating clinician NPI in 24J, required signature/name in 31 and applicable authorization in 23.
Applies to: Quest BH/EAP employer benefit and service date must be confirmed. UPHS/UPENN transitioned July 1, 2026; WellSpan transitions January 1, 2027. Quest contracts end December 31, 2026, and credentialing ceased in September 2026. Do not infer successor-network permission.
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Federal programs
CHAMPVA
Licensed associate: CHAMPVA’s authorized-provider definition does not settle particular associate eligibility or permit supervisor-NPI substitution. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: CHAMPVA student eligibility and supervisor substitution are not established by the reviewed provider definition. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Resolve the conflicting public authorization descriptions for the exact mental-health service and confirm the candidate meets CHAMPVA authorized-provider requirements.
Applies to: 38 CFR17.270(b) requires state licensure/certification for the service, or appropriate national/professional certification where a state offers neither. It does not specify whether a particular associate license qualifies or authorize substitution of a supervisor NPI. Current provider page directs paper medical claims to CHAMPVA PO Box30750, Tampa FL33630-3750; medical EDI84146 and dental84147 via Optum Insight. This closes provider address/routing separately from clinician permission. Current provider page says most mental-health/SUD services require preauthorization; accepted current beneficiary care page identifies inpatient mental-health/SUD. Conflicting breadth remains; verify authorization for exact service instead of treating all outpatient services alike. Neither the regulatory definition nor provider claim checklist establishes associate psychotherapy eligibility, rendering/supervising NPI, DQ/837 supervision loops, modifiers or supervised telehealth.
Read this insurer’s hiring requirements
38 CFR17.270 — (b), Authorized non-VA provider
CHAMPVA provider information — Claims submission; preauthorization; provider mailing address
CHAMPVA Guidebook — printed pp.55–59 Filing a Claim; pp.12–13 behavioral health
CHAMPVA Policy Manual portal — VA publications page linked Policy Manuals; current manual app
TRICARE East
Licensed associate: TRICARE’s supervised mental health counselor is a separately qualifying provider category, not a generic associate accumulating first clinical hours: it requires the relevant license/certification, a master’s degree and completed two-year/3,000 clinical/100 face-to-face supervision experience. Physician referral and ongoing physician oversight are required.
Unlicensed graduate: A newly unlicensed graduate does not meet SMHC state license/certification and completed experience requirements merely by being supervised.
Student intern: An ordinary student intern does not meet SMHC degree, experience and state credential requirements; a supervisor’s TRICARE certification does not cover any student therapist.
Before assigning insured clients: Determine SMHC versus independent TCMHC eligibility and complete actual provider certification/participation for the relevant contractor. For SMHC establish physician referral, ongoing physician oversight and claim certification of communication to the referring physician about treatment results. Retain degree, state credential and completed experience evidence; a therapist supervisor alone is insufficient. Use the actual East certification pathway; the assigned Humana form is virtual-health-specific and cannot establish certification for every practice setting.
Applies to: East and West administer the same federal counselor categories, with separate contractor certification procedures. Non-network certification is not network participation. CHAMPVA and VA Community Care are different programs.
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TRICARE For Life
Licensed associate: TRICARE’s supervised mental health counselor is a separately qualifying provider category, not a generic associate accumulating first clinical hours: it requires the relevant license/certification, a master’s degree and completed two-year/3,000 clinical/100 face-to-face supervision experience. Physician referral and ongoing physician oversight are required.
Unlicensed graduate: A newly unlicensed graduate does not meet SMHC state license/certification and completed experience requirements merely by being supervised.
Student intern: An ordinary student intern does not meet SMHC degree, experience and state credential requirements; a supervisor’s TRICARE certification does not cover any student therapist.
Before assigning insured clients: Determine SMHC versus independent TCMHC eligibility and complete actual provider certification/participation for the relevant contractor. For SMHC establish physician referral, ongoing physician oversight and claim certification of communication to the referring physician about treatment results. Retain degree, state credential and completed experience evidence; a therapist supervisor alone is insufficient. Resolve Medicare primary eligibility/adjudication and TRICARE-only versus jointly covered services before secondary billing.
Applies to: East and West administer the same federal counselor categories, with separate contractor certification procedures. For Life is Medicare-wraparound: TRICARE eligibility does not create a Medicare primary benefit, and TRICARE-only services need their own coverage analysis.
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TRICARE West
Licensed associate: TRICARE’s supervised mental health counselor is a separately qualifying provider category, not a generic associate accumulating first clinical hours: it requires the relevant license/certification, a master’s degree and completed two-year/3,000 clinical/100 face-to-face supervision experience. Physician referral and ongoing physician oversight are required.
Unlicensed graduate: A newly unlicensed graduate does not meet SMHC state license/certification and completed experience requirements merely by being supervised.
Student intern: An ordinary student intern does not meet SMHC degree, experience and state credential requirements; a supervisor’s TRICARE certification does not cover any student therapist.
Before assigning insured clients: Determine SMHC versus independent TCMHC eligibility and complete actual provider certification/participation for the relevant contractor. For SMHC establish physician referral, ongoing physician oversight and claim certification of communication to the referring physician about treatment results. Retain degree, state credential and completed experience evidence; a therapist supervisor alone is insufficient.
Applies to: East and West administer the same federal counselor categories, with separate contractor certification procedures. Non-network certification is not network participation. CHAMPVA and VA Community Care are different programs.
Read this insurer’s hiring requirements
VA Community Care / Optum Serve
Licensed associate: VA CCN associate eligibility requires the exact agreement and referral; a direct-supervision credentialing exemption is insufficient. This is an evidence gap, not a prohibition. Obtain a credential-specific decision under the actual member benefit and provider agreement before budgeting insured visits.
Unlicensed graduate: The reviewed sources do not establish a reimbursable pathway for this credential. This is an evidence gap, not a prohibition; obtain the exact product and provider agreement before including these visits in insured revenue projections.
Student intern: No student psychotherapy pathway is established for the exact CCN agreement/referral. Do not assume a policy for licensed associates also permits an unlicensed student placement.
Before assigning insured clients: Identify the member product, behavioral-health administrator, state, date of service and governing group agreement before applying a supervisory policy. Match the approved referral and SEOC to the clinician, setting and bill-to instructions; a credentialing exemption alone does not establish payment eligibility.
Applies to: ZYFDR maps toVACCN; assigned Optum Serve route is distinct from commercial Optum87726 and CHAMPVA84146. Approved referral/region-specific bill-to controls. Current manualp43 requires review of approved SEOC and applicable CMS coding unless agreement overrides; p44 referral/UCERN in23. Neither general CMS reference nor p23 direct-supervision credentialing exemption establishes exact associate psychotherapy eligibility. No public exact license/setting/referral authorization and rendering/supervisor NPI/DQ/modifier/telehealth protocol found through distinct SEOC/referral and qualification paths. VA employee hiring/credentialing or disability examination rules do not govern these CCN claims.
Verified card/routing references: VACCN. A payer ID identifies routing and does not establish clinician eligibility.
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Identity and source holds
Bishop
Licensed associate: The inventory name is not a resolved benefit/insurer identity. No associate reimbursement determination is supported.
Unlicensed graduate: Graduate eligibility cannot be established from this routing label.
Student intern: Student eligibility cannot be established from this routing label.
Before assigning insured clients: Obtain a redacted card or plan/administrator identity, product, service jurisdiction and governing provider agreement before assigning insured clients; claim-form instructions alone do not answer eligibility.
Applies to: Identity hold: neither a public company of a similar name nor a claim destination is evidence of the controlling benefit.
Identity and controlling policy remain unresolved; no insurer-specific filing page is linked.
Endeavor Health
Licensed associate: The inventory name is not a resolved benefit/insurer identity. No associate reimbursement determination is supported.
Unlicensed graduate: Graduate eligibility cannot be established from this routing label.
Student intern: Student eligibility cannot be established from this routing label.
Before assigning insured clients: Obtain a redacted card or plan/administrator identity, product, service jurisdiction and governing provider agreement before assigning insured clients; claim-form instructions alone do not answer eligibility.
Applies to: Identity hold: neither a public company of a similar name nor a claim destination is evidence of the controlling benefit.
Identity and controlling policy remain unresolved; no insurer-specific filing page is linked.
Regency Employee Benefits
Licensed associate: The inventory name is not a resolved benefit/insurer identity. No associate reimbursement determination is supported.
Unlicensed graduate: Graduate eligibility cannot be established from this routing label.
Student intern: Student eligibility cannot be established from this routing label.
Before assigning insured clients: Obtain a redacted card or plan/administrator identity, product, service jurisdiction and governing provider agreement before assigning insured clients; claim-form instructions alone do not answer eligibility.
Applies to: Identity hold: neither a public company of a similar name nor a claim destination is evidence of the controlling benefit.
Identity and controlling policy remain unresolved; no insurer-specific filing page is linked.
Salvation Army / Campion Barrow
Licensed associate: The inventory name is not a resolved benefit/insurer identity. No associate reimbursement determination is supported.
Unlicensed graduate: Graduate eligibility cannot be established from this routing label.
Student intern: Student eligibility cannot be established from this routing label.
Before assigning insured clients: Obtain a redacted card or plan/administrator identity, product, service jurisdiction and governing provider agreement before assigning insured clients; claim-form instructions alone do not answer eligibility.
Applies to: Identity hold: neither a public company of a similar name nor a claim destination is evidence of the controlling benefit.
Identity and controlling policy remain unresolved; no insurer-specific filing page is linked.
Before sending the first supervised-service claim
Keep the actual treating clinician, clinical supervisor, payer participation, and claim rendering identity separate in the record. Resolve the product and provider-category rule, any required program approval, the date-of-service version, and the electronic claim fields. Previously paid claims, accepted transmissions, co-signatures, and a group NPI do not establish all of those conditions.
Who can I bill under as my supervisor?
California AMFT, ASW and APCC payer comparison
New York limited-permit billing guide
Frequently Asked Questions
Can my associate or student intern bill every insurer I accept?
Your participation alone does not establish that. Compare the new hire’s actual credential, education and student status with each insurer’s product, supervision and enrollment conditions before assigning insured clients.
Does a published associate pathway also cover a student intern?
Only where the applicable source supports that actual training category. A completed-degree or licensed-associate pathway should not be applied to a student still earning the required degree merely because both roles involve supervision.
Does an unresolved destination mean supervised services are prohibited?
No. Not established means the cited evidence does not settle the proposed arrangement. Conditional means a scoped pathway exists with requirements to meet; a restriction applies to its named category or program.
Can I search by the insurer or payer ID on the card?
The directory includes recognizable payer names and verified card or routing references where available. Match the actual member product, administrator and state; the payer ID alone does not determine clinician eligibility.
What if eligibility is documented but the claim fields are still unclear?
Keep the documented eligibility distinction, then resolve enrollment, approval and claim configuration before billing. Missing field instructions do not turn an established pathway into a prohibition or authorize an unverified claim setup.
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About Bomi
Founded by George Ruan, Dax Earl, and Andrey Goder, Bomi helps independent therapists and group practices with insurance billing, credentialing, and payer follow-up. Bomi grew out of Dax’s experience helping his mother with her therapy practice, with a clear purpose: reduce the administrative burden of insurance while keeping practice owners in control.
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