Healthy U Medicaid: Unlicensed Behavioral Health, Supervisor NPI and HL

Does Healthy U allow supervised unlicensed therapy billing?

Healthy U has an explicit supervisor-billing rule for eligible services performed by unlicensed behavioral health staff: use the supervising clinician’s NPI with modifier HL. That does not establish blanket permission for an unlicensed graduate or student to provide psychotherapy. Utah’s September 2026 Behavioral Health Services manual separately requires a licensed mental health therapist for psychotherapy in section 7-5.2.

First establish that Healthy U is responsible for the member’s behavioral health benefit. Its current provider manual covers behavioral health under Healthy U Behavioral or Healthy U Integrated. For Healthy U medical-only members, behavioral health is handled by Medicaid fee-for-service or the local Prepaid Mental Health Plan (PMHP).

What changed for unlicensed providers and HL?

The payer’s November 2025 Provider Connection notice says ordinary unlicensed providers could continue billing through November 30, 2025, then would be terminated in PRISM and Healthy U and could not re-enroll. It describes billing their services under the supervising clinician with HL, available from September 1, 2025 and required from December 1, 2025. The earlier transition allowance for claims without HL has ended.

The September 2026 state manual retains the supervisor-NPI and HL requirement in section 3-4. It also requires the supervisor to comply with federal, state and Medicaid rules and document monthly LEIE and SAM exclusion checks. Moving the claim under a supervisor does not remove staff qualifications, covered-service limits or documentation requirements.

Which staff and services are actually supported?

The state manual uses service-specific qualification lists. Section 7-3.2 permits a qualifying bachelor’s-degree holder working toward Social Service Worker (SSW) licensure to assist with a mental health assessment under a licensed mental health therapist as part of a multidisciplinary team. It also names certain license-exempt students in qualified substance use disorder education programs, with required supervision. This is an assessment-support service, not independent diagnosis or psychotherapy.

Section 7-9.2 includes qualifying SSW-track bachelor’s graduates and certain exempt substance use disorder counselor students for therapeutic behavioral services under the stated supervision conditions. These behavioral interventions require referral through assessment and treatment planning and continuing individual mental health treatment. They are a distinct service, not a substitute label for an ordinary psychotherapy session.

Section 3-3 separately permits other trained individuals to provide psychosocial rehabilitation and supportive living under its training requirements. A generic unlicensed status or any graduate degree does not, by itself, satisfy these categories. The payer notice does not name a blanket associate-counselor, associate-MFT or social-work-graduate psychotherapy pathway.

Can a student provide psychotherapy and simply add HL?

Not on the strength of the HL notice alone. The reviewed current psychotherapy participation provision requires a licensed mental health therapist, while the expressly described unlicensed pathways have their own service and training limits. These sources do not establish a general student psychotherapy claim pathway. A proposed placement needs authority for the actual service and clinician category, not just a supervisor willing to lend an NPI.

What about peer support, case managers and technicians?

The payer notice treats peer support specialists, case managers and registered behavioral health technicians as certification exceptions to the ordinary unlicensed-enrollment termination. It requires proof of certification and allows re-enrollment after proper documentation where termination occurred for missing certification. Those exceptions do not turn these roles into psychotherapy-qualified clinicians.

Which Healthy U plan and network must cover the service?

The current payer manual identifies Healthy U Behavioral as serving eligible Summit County Medicaid members. Except for emergencies or a Single-Case Agreement, its members must use contracted Healthy U Behavioral providers. Healthy U Integrated is a separate medical-and-behavioral benefit. Confirm the member’s exact benefit and network before applying the payer’s unlicensed-provider notice.

This answer does not extend the Medicaid notice to University of Utah Health Plans commercial products, Individual and Family plans, or CHIP. It also does not replace the applicable authorization, contract, covered-service or state scope-of-practice requirements.

Frequently Asked Questions

Does Healthy U require HL for unlicensed behavioral health services?

Its notice requires HL from December 1, 2025 for the described supervisor-billed services. The current state manual also requires the supervisor’s NPI with HL. The clinician must still qualify for the actual covered service.

Does HL let any unlicensed graduate provide psychotherapy?

No blanket permission is established. The current psychotherapy provision requires a licensed mental health therapist; the manual separately identifies limited unlicensed assessment-support, therapeutic-behavioral and rehabilitation pathways.

Does every Healthy U member have behavioral health through Healthy U?

No. The payer manual distinguishes Healthy U Behavioral and Integrated from medical-only Healthy U, whose behavioral health benefit is through Medicaid fee-for-service or a local PMHP.

Can peer support specialists use the ordinary unlicensed enrollment rule?

The notice places peer support specialists, case managers and registered behavioral health technicians in separate certification exceptions. That is not psychotherapy eligibility.

Sources and scope

Reviewed October 30, 2026. The payer’s dated notice establishes its unlicensed-provider transition; the current online provider manual establishes product and network boundaries; the September 2026 Utah manual supplies the current HL and service-participation distinctions. No broader psychotherapy permission or claim-routing recipe is inferred.

Healthy U November 2025 Provider Connection

University of Utah Health Plans current provider manual

Utah Behavioral Health Services manual, September 2026