Can Associates or Student Interns Bill OSU Health Plan?
By Bomi Health • October 9, 2026
Sections
Can an associate or student intern see these clients?
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.
Counseling Supervision, revision 8/25
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.
Scope: 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.
Policy research reviewed October 17, 2026. Apply the policy version and participation terms governing the date of service.
Start with the patient's plan
Confirm OSU Health Plan coverage before applying this guide. Luminare processes OSUHP claims, but its name also appears on other clients' cards. Promise has its own provider documents and routes.
Source: For Providers; Provider Resource Guide July 2026 v3.
Separate licensed practitioners from trainees
The August 2025 OSUHP policy covers supervised Ohio LPCs, LSWs and MFTs through a supervising licensed psychologist or policy-defined independent practitioner: a licensed professional clinical counselor (LPCC), licensed independent social worker (LISW), or licensed independent marriage and family therapist. These categories require valid licenses under the cited Ohio provisions. Registered CTs, SWTs and MFTTs are excluded. Certain Ohio-board-registered psychology trainees qualify through a licensed psychologist when their registration and assigned title satisfy the policy’s cited rules.
Source: Counseling Supervision, revision 8/25.
Check the supervisor, network and records
Supervising licensed psychologists and independent practitioners must follow the applicable Ohio supervision provisions in Administrative Code 4732-13 or 4757-17. If the covered person’s plan has network restrictions, the supervisor must participate in the OSUHP statewide network. The supervisor maintains training-supervision records showing dates, times, content and goals, signs them at least quarterly, and makes them available to OSUHP on request. Covered supervised practitioners and qualifying psychology registrants must disclose to clients on all printed and electronic material that they diagnose and treat mental and emotional disorders under the supervision of an appropriately licensed mental health professional. They must also name the supervising professional(s) on the client disclosure statement or a similar document, available to OSUHP on request. The policy excludes services provided by a Licensed Psychologist or Independent Practitioner who is a “family covered person” of the Supervised Practitioner or Supervised Trainee. Where that relationship terminology is ambiguous, obtain plan clarification; do not broaden it to every relative or decide its meaning by inference. OSUHP may audit claims and supporting records. Prior authorization is unnecessary when the policy’s criteria are satisfied.
Source: Counseling Supervision, revision 8/25.
Resolve claim fields separately
The policy identifies who bills, but does not map rendering NPIs, CMS-1500 boxes, 837 loops or supervisory modifiers. Obtain those implementation instructions for the approved arrangement. The current provider page lists Luminare's OSU claim address; that administrative route does not fill the missing identity instructions.
Source: Counseling Supervision, revision 8/25; For Providers.
Example: an LPC and a counselor trainee
Hypothetical example: An OSUHP practice assigns one patient to an Ohio LPC and another to a registered counselor trainee. Both have the same supervisor.
The LPC can meet the policy's pathway if its conditions are satisfied; the CT is excluded. A qualifying registered psychology trainee instead requires the policy's psychologist-led pathway.
Source: Counseling Supervision, revision 8/25.
Primary sources
Counseling Supervision, revision 8/25
Provider Resource Guide July 2026 v3
Compare other payer and state supervisory billing rules
Frequently Asked Questions
Does this cover every Luminare member?
No. Apply it only after confirming OSUHP coverage.
Are all trainees excluded?
No. The policy distinguishes excluded counseling/social-work/MFT trainees from specifically qualifying psychology trainees.
Must the supervised clinician be independently credentialed with OSUHP?
OSUHP credentials independent practitioners; the supervised-service pathway has separate conditions.
Does meeting eligibility determine the rendering NPI?
No. The public policy does not supply that claim-field mapping.
What is the family-related exclusion?
The policy excludes services provided by a Licensed Psychologist or Independent Practitioner who is a “family covered person” of the Supervised Practitioner or Supervised Trainee. Ask OSUHP to clarify ambiguous application of that exact terminology; it is not a basis to exclude every relative.
Where must supervision be disclosed?
Disclose the supervised diagnosis and treatment of mental and emotional disorders to clients on all printed and electronic material. Also identify the supervising professional(s) on the disclosure statement or similar document and make that document available to OSUHP on request.
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