The answer is sometimes—but it is important to understand what “under supervision” actually means.

One of the questions we hear most often from group practices is whether they can bill an insurance company for services provided by a therapist who is either provisionally licensed or not credentialed with the insurance plan. Those are two very different situations, and the answer can depend on the therapist’s license, state law, the insurance company, and the practice’s contract with that payer.

Clinical Supervision and Insurance Billing Are Not the Same Thing

Many therapists are required to work under clinical supervision while they are completing the requirements for independent licensure. Depending on the state, these clinicians may hold titles such as associate, intern, limited licensee, or another type of provisional credential.

State law may allow that therapist to provide psychotherapy under the supervision of a fully licensed clinician. That does not, however, automatically mean an insurance company will pay for the service.

Each payer has its own rules about whether it recognizes provisionally licensed clinicians, how they must be reported on a claim, whether the supervising clinician must be credentialed, and how the service will be reimbursed.

In other words, being legally allowed to provide therapy is only one part of the equation.

Billing for Provisionally Licensed Therapists

Some insurance companies do allow practices to bill for services provided by certain provisionally licensed therapists. When they do, the payer may have very specific requirements.

For example, the payer may specify:

• The type of provisional license the therapist must hold
• Who may provide supervision
• Whether the supervisor must be credentialed with the plan
• How the therapist and supervisor should be reported on the claim
• Whether a modifier is required
• Whether the service is reimbursed at the in-network or out-of-network rate

Some plans will reimburse these services. Others will not.

The fact that a therapist is receiving supervision does not, by itself, establish that the service is covered. Before billing, the practice should confirm that the particular payer recognizes that type of provisional license and allows the service to be billed under its supervision rules.

What About a Fully Licensed Therapist Who Isn’t Credentialed?

This is where practices can run into trouble.

A fully licensed therapist who can practice independently but is not credentialed with a particular insurance company is not in the same position as a provisionally licensed therapist who is legally required to receive supervision.

The issue isn’t clinical supervision. The issue is network participation.

You generally cannot take a fully licensed, non-credentialed therapist and bill the services under another provider’s credentials simply because that provider is credentialed with the insurance company. If the therapist actually performed the service, the claim must be submitted in accordance with the payer’s rules regarding the provider who rendered that service.

Having a clinical supervisor does not automatically give an independently licensed therapist access to that supervisor’s insurance contracts or in-network status.

Why This Matters

Using one provider’s credentials to obtain reimbursement for services performed by someone else can create problems with the insurance company.

Depending on the circumstances, the payer may deny or reprocess the claim, request records, audit the practice, or seek repayment of claims that were paid incorrectly.

For that reason, practices should be careful about using the phrase “billing under supervision.” It is not a universal billing method that can be used whenever a therapist is not credentialed with an insurance company.

Don’t Assume a Payer Allows Supervised Billing

Before submitting claims for a provisionally licensed therapist, we recommend contacting the payer and asking some very specific questions:

1. Does the plan reimburse services provided by this type of provisionally licensed therapist?
2. Does the plan allow those services to be billed under a supervising provider?
3. How should the rendering provider and supervising provider be reported on the claim?
4. Does the supervising provider need to be credentialed with the plan?
5. Is there a modifier or other billing requirement?
6. Will the claim be paid at the in-network or out-of-network rate?

Whenever possible, get the answer in writing and keep it with your payer documentation.

UnitedHealthcare/Optum is one example of why practices should not make assumptions. Its rules regarding billing for services performed under supervision are limited and may vary by state and by the terms of the provider’s contract. Simply having a credentialed supervisor does not necessarily mean that services provided by another therapist can be billed under that provider’s name or network participation.

The Bottom Line

There are really three separate questions:

Is the therapist legally allowed to provide the service?

Does the insurance company reimburse services provided by that type of clinician?

Does the claim accurately reflect the provider who performed the service and meet the payer’s billing requirements?

A “yes” to the first question does not automatically mean the answer to the other two is also yes.

For practices employing provisionally licensed therapists, understanding the rules before claims are submitted can help prevent denials, recoupments, and more significant billing problems later.

How Psychiatric Billing Associates Can Help

Psychiatric Billing Associates works with behavioral health group practices to help identify payer requirements affecting the billing of services provided by provisionally licensed therapists and other clinicians.

Because the rules can vary by state, license type, insurance plan, and provider contract, it is important to verify the requirements that apply to your specific practice before assuming that a service can be billed “under supervision.”