When legal scope, clinical supervision, and reimbursement don’t align.

In the world of behavioral health, we’ve got rules.
State licensure laws. Scope of practice guidelines. Supervision requirements. Medicaid regulations.

You’d think that if your clinicians are working within those rules, providing care legally and ethically, you’d be safe to bill.

But then commercial payers enter the chat…
And suddenly? All bets are off.

The Great Commercial Coverage Mystery

One of the most common questions I get from mental health organizations is:
“Can our LPC or LSW bill under supervision to [insert major payer]?”

And the honest answer?

👉 Maybe.
👉 Sometimes.
👉 Depends on the rep you talked to…and how their system is set up.

Unlike Medicare or state Medicaid plans (which at least publish guidelines), many commercial carriers are eerily silent on:

• Which licensure types are recognized
• Whether supervision is allowed for dependently licensed providers
• What documentation is required to prove supervision occurred
• Whether claims billed under a supervising NPI will be paid, or flagged

So what happens?

Organizations:

• Interpret based on state rules alone (which is a compliance risk)
• Assume if it paid once, it must be OK (also risky)
• Wait for denials and then investigate (too late)

But Here’s the Real Kicker…

Your provider could be:

• Fully licensed or dependently licensed
• Supervised according to board rules
• Practicing 100% within legal scope

…and still be unbillable to a commercial plan.

That’s not a clinical issue. That’s a reimbursement policy issue.

What Can You Do?

✅ Know your state scope of practice laws. They matter but they don’t guarantee coverage.
✅ Dig into each payer’s provider manual (if they even have one) and get answers in writing.
✅ Track paid claims by licensure level. Patterns matter when your documentation is thin.
✅ Push for contracts or letters of agreement that specify covered provider types.

And for the love of clean claims don’t take verbal OKs from call center reps as gospel.
Get. It. In. Writing.

Final Thoughts

This isn’t just frustrating; it’s a barrier to care.
We have licensed, supervised, qualified mental health professionals ready to do the work and payers refusing to acknowledge them until claims hit a denial queue.

If we want real parity in mental health care, we need clear and public standards on who can bill and under what conditions.

Until then, behavioral health leaders need to be part legal analyst, part policy nerd, and part mind-reader.

And if you’re tired of guessing?
That’s where I come in.