Supervisory Billing – And Why I Avoid This Topic 

If you’ve been following my newsletter for any of the 16 years I’ve been writing, you might have noticed I have completely avoided one hot topic: supervisory billing. And yet, I am constantly asked about whether a pre-licensed person can bill insurance under the license of their supervisor.

I have avoided this topic because I am not an expert in supervisory billing, and because the answer to whether it is covered is an unsatisfying “it depends.” It depends on the health plan. If the plan covers it, it may depend on whether you have followed their supervisory billing policies. It may depend on the state where you are practicing. It may depend on the pre-licensed status of the treating clinician (i.e. a trainee might not be covered while an Associate might be).

But since I’m getting so many questions about supervisory billing, I’ve decided to stop being such a chicken, and to wade into the waters to at least address this topic.   Even if I only cover it in a general manner, I hope I can help you ask better questions, and to help you steer clear of some common mistakes.

The internet is full of advice about supervisory billing, and therapists reporting they are getting paid for supervisory billing.  But I wonder — does the health plan know who is performing the service? And would they have paid for it if they did?

Of course, you CAN bill for a pre-licensed therapist’s sessions. This isn’t the right question. Anything CAN be billed, and may even be paid.  But the real question is, SHOULD you bill for it, is it covered, under what circumstances, and in an audit, could you or your client be asked to give money back to a health plan? (Hint: the answer to that last one is “yes.”)

So, it is important to do this right.

If you are considering — or currently doing — supervisory billing, here are some thoughts:

1. First off, supervisory billing is often confused with incident-to billing. Because of this, you might be led astray if you check the health plan’s incident-to billing rules.  According to an expert on Medicare and billing, Susan Frager, (psychbillingcoach), supervisory billing is not the same as incident-to billing, and would not meet Medicare’s incident-to billing criteria. “If you are billing Medicare for supervisees, and calling it incident-to, then STOP. RIGHT. NOW,” she writes.  See her article on the difference here: click here

2. I can’t give you a list of plans that cover supervisory billing – as I said, it varies across the country. But Aetna and CIGNA seem to be most open to it, and I have heard some United Health Care/OPTUM plans do.  Regence and Premera both have it on their websites/manuals that they do pay for it, but as always, verify.  It is my sense most Blue Cross plans do not cover supervisory billing, but again, I’ve heard some therapists tell me they are being covered.

3. I would get the plan’s supervisory billing policy IN WRITING before billing for it. You need solid confirmation that the plan will cover it and under what circumstances.  And don’t make assumptions — Coverage will vary depending on insurance plan, and possibly even in different parts of the country with the same insurance plan.  You may need to research the coverage with THAT specific client’s account within the plan.

4. Find out what rules need to be followed when doing this type of billing. For example, must the supervisor be in-network (this is typical)? Must the supervisor do all intakes?  What pre-license-level clinicians are covered (trainees? Associates? Provisionally licensed?)  Can the hours be billed under someone who isn’t their direct supervisor?  Are there any documentation requirements? Must you have a group contract with them to be covered?

5. If the supervisor is in-network, how does the plan want the claim to be filled out? For example, whose NPI goes under the “rendering provider NPI” in Box 24J?  Typically, private (commercial) health plans want the SUPERVISOR’S NPI.  They also want the supervisor’s tax ID in Box 25, signature in Box 31, address in box 33, and NPI in 33a.  This may seem odd, as it will appear that the supervisor provided the session.  The supervisee’s name won’t even appear on the claim.

5. What If you are out of network with the plan, and give the client a superbill? I suggest that you put ALL the info about both the clinician and supervisor on the superbill – see below example:
   • “Rendering Provider: Joe Jones, Associate MFT #02345 [NPI, tax ID, signature]”
   • “Supervising Provider: Jane Smith, LCSW, #22567 [NPI, tax ID, signature]”
   • If billing under a group tax ID, the group’s name, address, Tax ID, and NPI should also be added.

7. Can you do supervisory billing for a licensed therapist? Usually no.  If a fully therapist in your group is out of network with a health plan, they typically can’t bill under the license of an in-network therapist.  Health plans typically won’t pay supervisory billing services for any provider who are eligible to credential.

8. It is important to consider that supervisory billing is more likely to be audited, and records are more likely to be requested.  Why?  Suppose a supervisor is seeing 5 clients a day and has 2 associates who are each billing 5 clients a day. Since all sessions are being billed under the supervisor’s NPI, the health plan doesn’t know there are three clinicians involved.  The health plan just sees 15 sessions coming in under one therapist’s name for that day, which may cause them to investigate.  In an audit, they could ask that you supply all the notes for the sessions that were billed.

9. Because supervisory billing means an increased audit risk, supervisees need to have GREAT notes, that are completed and reviewed by supervisors in a timely manner. This is another great reason both your pre-licensed folks and supervisors should take my pre-recorded webinar “What’s Missing From Your Charts: Writing Great Notes.”   Find out more at theinsurancemaze.com/store.   Let me know if you want to discuss a discount group rate for the training.