Can Students and Unlicensed Graduates Bill Vermont Medicaid?

Yes, through Vermont Medicaid’s specific supervised billing program when enrollment, education, licensure-progress and supervision requirements are met. The January 1, 2026 manual explicitly includes both students in relevant master’s or doctoral programs and graduates accumulating required licensure hours. The supervisor is the billing provider and the supervisee is the rendering provider. This is distinct from a general permission to use another clinician’s NPI.

Which trainees and supervisors are eligible?

The student must be enrolled in a master’s or doctoral program and accruing hours toward Vermont licensure, including hours required for graduation. A graduate must have the relevant degree and be accruing licensure hours. The manual also accepts enrollment evidence that the hours are complete and the required examination is scheduled.

Qualifying Vermont-licensed supervisors include a psychiatry-board-certified physician, psychiatric nurse practitioner, clinical psychologist, marriage and family therapist, clinical mental health counselor, clinical social worker or alcohol and drug counselor. The supervisor must be enrolled with Medicaid and meet the applicable professional supervision requirements. Services must remain within the supervisor’s scope; naming a profession here does not authorize every cross-profession pairing.

Students and graduates need their own enrollment

The supervisee enrolls under the appropriate provider type and specialty: S56 for student trainees, S57 for graduate trainees. Enrollment requires proof of education or current program enrollment, licensure-hour progress with signed attestations, malpractice coverage and the required OPR roster documentation. The manual anticipates updates if OPR replaces rostering with a trainee credential. Do not substitute the supervisor’s enrollment for the supervisee’s enrollment.

Whose NPI and which modifiers belong on the claim?

For the standard DVHA claim described on page 8, list the supervisor as billing provider and the supervisee as rendering provider. Do not append pricing modifiers such as AH, AJ, HO, HN or HM—even when the supervisor normally uses one. Continue using applicable informational modifiers, including telehealth modifiers. Designated Agencies may bill differently.

The supervisor identified on the claim must actually provide supervision for the hours billed. Keep documentation of the supervisee’s degree, discipline, license eligibility, start date, supervisor and prior supervisors. Payment and any recoupment go to the supervising provider.

Which psychotherapy services are supported?

Page 9 lists psychotherapy codes including 90832, 90834, 90837, 90846, 90847 and 90853 among potentially reimbursable services, when within the supervisor’s scope and the hours count toward licensure. The list is not a promise of coverage for every patient or setting.

The manual also lists diagnostic and crisis codes on page 9 while page 11 broadly excludes assessment and emergency-care services. Those passages need service-specific clarification before relying on those categories. This article does not resolve that tension by treating every listed code as universally payable. Psychological and neuropsychological testing, evaluation and scoring use other policy avenues; case management and specialized rehabilitation are also excluded from this supervised billing route.

When does supervised billing stop?

A licensed provider who is not enrolled cannot use this program as an enrollment workaround. A supervisee who has completed all minimum licensure requirements cannot continue merely because the license application is pending; the manual instructs providers to hold claims until licensure is approved. That differs from its enrollment provision for someone still scheduled to take a required examination.

Indefinite unlicensed practice is not the ordinary pathway. The manual preserves a narrow grandfathered waiver exception for previously approved providers who maintain employment with the original agency or employer and meet continuing-education requirements. This is not a new waiver opportunity or general student exemption.

Frequently Asked Questions

Does Vermont Medicaid allow student therapists before graduation?

Yes, eligible master’s or doctoral students accruing required licensure or graduation hours can use the program after completing the required enrollment and supervision steps.

Does the supervisor appear as rendering provider?

For the standard DVHA claim described in the 2026 manual, the supervisor is billing provider and the supervisee is rendering provider. Designated Agencies may have different billing instructions.

Should supervised claims include HO?

Not as a pricing modifier under this program. The manual says to omit pricing modifiers including HO while retaining applicable informational modifiers.

Sources and review date

Reviewed October 30, 2026. Policy dates below identify the source versions; member benefits, provider contracts and applicable state requirements remain controlling.

Vermont Medicaid Supervised Billing Manual for Behavioral Health, January 1, 2026