Can Psychology Trainees Bill Community Care HealthChoices?
By Bomi Health • August 25, 2026
Policy research reviewed October 17, 2026. This hiring guide separates a documented pathway from the conditions still to confirm for your clinician and member benefit.
Sections
Identify Community Care’s benefit and the supervisor category
Community Care’s July 18, 2024 Provider Alert #15 applies to its HealthChoices contracts for individually credentialed practitioners and group practices. It excludes licensed outpatient psychiatric clinics under Pennsylvania Chapter 5200. This is a Medicaid provider rule, distinct from UPMC Health Plan’s commercial credentialing requirements, even when the organizations’ names appear together.
For contracted master’s-level clinicians, the alert permits billing only for services they personally rendered. It prohibits billing another clinician’s or student’s work under their credential simply because supervision occurred. An LCSW or LPC practice owner therefore cannot use this policy as a general supervised-psychotherapy hiring route.
Community Care Provider Alert #15, July 18, 2024
The psychologist pathway has real training conditions
The alert separately permits qualifying psychology interns, residents, trainees and employees to work under a contracted licensed psychologist. It requires Chapter 41 graduate training in psychology and full compliance with that chapter. The state definition includes completion of 15 graduate semester hours in the specified doctoral psychology program. A psychology intern is a student in a doctoral internship, not every person called a counseling intern.
The alert also discusses master’s-level clinicians who hold no license governed by another BPOA board. They may provide psychological services, including therapy and testing, under direct psychologist supervision, but that description must be read together with the alert’s Chapter 41 training condition. A master’s degree alone should not be treated as permission for any graduate hire.
Community Care Provider Alert #15, July 18, 2024
A license in another discipline changes the analysis
When the supervised person already holds another professional license, the alert limits psychologist-supervised work to psychological services outside that license’s scope. Its example distinguishes an LCSW’s own-scope psychotherapy from psychological testing. The LCSW cannot move their psychotherapy under the psychologist’s credential merely to avoid direct participation requirements.
This distinction should shape the job before patients are assigned. Record the actual license, graduate training and intended services, then match them to the applicable route. The same group may have a qualifying psychology trainee and a licensed therapist who needs their own credentialing; one billing template cannot decide both cases.
Community Care Provider Alert #15, July 18, 2024
Arrange supervision and records before the first visit
The psychologist must plan appropriate work, maintain regular supervisory contact, remain available for emergencies and keep records of the employee’s activities and competence. The alert reproduces requirements for signatures, disclosure of supervised status and a maximum of three full-time-equivalent employees under simultaneous supervision. These duties require actual staffing capacity, not only a co-signature field.
For an eligible trainee arrangement, Community Care permits billing through the contracted psychologist’s credential. Preserve the actual treating person in the record and confirm applicable product and transaction instructions. For other arrangements, resolve the clinician’s own credentialing or the separate clinic rules rather than stretching this exception. The hiring decision depends on the supervisor’s category, the trainee’s defined preparation and the services assigned.
Community Care Provider Alert #15, July 18, 2024
Frequently Asked Questions
Can an LCSW bill every intern’s psychotherapy under supervision?
No. The master’s-level practitioner section permits billing only personally rendered services. The psychologist exception has different qualifications. Source S1.
Does the word intern include every master’s student?
No. Chapter 41 defines psychology training and doctoral internships; verify the individual’s actual qualifications. Sources S1 and S2.
Sources and scope
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