Billing

Does NH Medicaid Cover Supervised Therapists and Interns in CMHPs?

By Bomi Health • October 30, 2026

Yes, in the covered community mental-health program pathway. New Hampshire’s He-M 426.08 permits psychotherapy by specified supervised professionals and formal interns, and makes documented supervision a condition of reimbursement. This is a CMHP and approved community-provider rule, not blanket permission for any unlicensed therapist in private practice. Sources reviewed October 30, 2026.

Sections

Who can provide psychotherapy under supervision?

He-M 426.08(h) lists the independently qualified professions. For people who do not meet those standards, subsection (i) describes a supervised pathway requiring the stated prior supervised mental-health experience and relevant master’s-level education; it also identifies a registered-nurse pathway with a mental-health nursing certificate. The experience requirement is at least one year of psychiatric or mental-health work under an eligible psychiatrist, doctoral psychologist, licensed mental-health professional or the specified statutory authority.

The listed master’s fields include marriage and family therapy, psychology, social work, rehabilitation counseling and education/counseling from an appropriately accredited institution. Being a recent graduate or holding a generic associate credential is not, alone, enough to show that all these requirements are met. The CMHP must verify the person’s actual qualifications.

How much supervision is required?

For staff qualifying under subsection (i), subsection (j) requires at least two hours of ongoing supervision each month. At least one hour must be direct individual or group supervision by a licensed practitioner of the healing arts; the second may be peer or case review. Direct supervision here means meeting with the clinician to review clinical practice and evaluate performance. This does not establish a rule that the supervisor must attend every therapy session.

Are student interns treated differently?

Yes. Subsections (k) and (l) separately address a formal internship. They specify enrollment in at least a master’s program in psychology, social work, rehabilitation counseling, education/counseling or nursing, or an accredited psychology doctoral or postdoctoral program. They do not authorize every student, volunteer or bachelor’s-level placement.

An eligible intern must receive at least one hour of direct supervision per week from a licensed practitioner appropriate to the field of study. The supervisor must write and sign a weekly supervisory-record note describing observations and recommendations, plus a monthly evaluation summary. Medicaid reimbursement to the CMHP or community provider depends on supervision occurring and being documented.

Which provider can bill?

The August 2025 NH Medicaid Community Mental Health manual requires CMHP approval under He-M 403 and Medicaid enrollment. CMHPs or their authorized subcontractors provide the covered program services; staff qualifications remain governed by He-M 426. Services must meet the program’s eligibility, treatment-plan and documentation requirements. The manual also conditions reimbursement on documented supervision.

The manual requires CMS-1500 or electronic 837P claims and appropriate service codes. Its HE/HW and U-series modifiers describe program eligibility and other service circumstances. They are not a blanket intern modifier. The reviewed provisions do not supply a universal rule for substituting the supervisor’s NPI for the clinician’s in every psychotherapy claim, so that field remains subject to the actual enrolled program’s claim instructions.

What this does not authorize

The CMHP pathway does not establish independent private-practice enrollment for an unlicensed graduate, nor prove a particular Medicaid managed-care contract accepts the arrangement. A separate substance-use program’s rendering-provider rule also cannot be transferred automatically to CMHP psychotherapy. Use the specific service, program and member coverage to select the applicable requirements.

New Hampshire administrative rules — He-M 426.08(h)–(m)

NH Medicaid Community Mental Health provider manual — August 2025

Frequently Asked Questions

Can an NH psychotherapy intern be reimbursed by Medicaid?

The CMHP rule provides a formal-internship pathway for specified graduate programs with at least weekly direct supervision and signed weekly and monthly supervisory documentation. It is not a rule for every student or practice.

Can a private group use these CMHP rules without program approval?

The reviewed sources do not authorize that. CMHP approval, enrollment and the actual program/service requirements are part of this pathway.

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