CurrentBlue Cross Blue Shield - Rhode IslandPolicy N/A

Behavioral Health Supervisory Protocol for LCSWs, Postdoctoral Clinicians, MHC-As, MFT-As, and PAs

Defines BCBSRI requirements for supervisory protocols allowing non-credentialed supervisees (LCSWs, postdoctoral clinicians, Mental Health Counselor Associates, Marriage and Family Therapist Associates, and Physician Assistants) to render outpatient behavioral health services under a BCBSRI-credentialed supervising clinician and the documentation, billing, and oversight expectations that apply.

Policy Summary

PayerBlue Cross Blue Shield - Rhode Island

PolicyBehavioral Health Supervisory Protocol for LCSWs, Postdoctoral Clinicians, MHC-As, MFT-As, and PAs

Policy CodePolicy N/A

Change TypeNo material change

Effective DateNov 1, 2024

Next Review DateN/A

Key ActionClaims must be submitted by the independently licensed BCBSRI-credentialed clinician and include the appropriate HO/HP/HN modifier.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

30 daystimeframe to produce requested documentation to avoid denial/retraction of payment

HO, HP, HNrequired claim modifiers

Commercial & Medicaremember types covered

BCBSRI requiredsupervisor credentialing

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Supervisory Protocol Coverage and Administrative Criteria

Supervisory protocol coverage and administrative criteria

Covered when ALL of the following administrative and documentation requirements are met:

Services may be rendered to Commercial and Medicare members; benefits, deductibles and copayments are determined by the member's Evidence of Coverage or Subscriber Agreement.

The supervising clinician must be an independently‑licensed behavioral health clinician who is credentialed with BCBSRI.

ALL of the following

A clear process for informing the patient when a clinician who is not credentialed with BCBSRI is providing the service and documentation of the patient's awareness.
Documentation that the supervising clinician is credentialed with BCBSRI.
A process by which the supervising BCBSRI‑credentialed provider reviews documentation of the patient's overall treatment (assessment, treatment plan, and any changes to the diagnosis).
A process supporting regular supervisor–supervisee meetings in accordance with Rhode Island Department of Health guidelines.

Member medical records must document medical necessity and comply with BCBSRI rules, regulations, policies, and procedures; records must be available to BCBSRI upon request.

BCBSRI may audit services provided to members regardless of provider participation status; failure to produce requested documentation within 30 days may result in denial or retraction of payment.

For Medicare members, direct supervision follows CMS Medicare Benefit Policy Manual (Chapter 15): the supervisor must be present in the office suite and immediately available to provide assistance and direction while the supervisee is performing services (presence in the same room is not required).

Claims for services rendered under this supervisory protocol must be submitted by the independently‑licensed BCBSRI‑credentialed clinician and include the appropriate modifier indicating supervisee type (see coding requirements).

Claim Modifiers & Submission Responsibilities

Required claim modifiersModifierCovered

HO	Modifier indicating services rendered by an LCSW, MHC-A, or MFT-A
HP	Modifier indicating services rendered by a Postdoctoral clinician
HN	Modifier indicating services rendered by a Physician Assistant

Claim submission responsibility

Who must submit claimsClaims must be submitted by the independently licensed BCBSRI‑credentialed clinician

Required claim modifiersInclude HO for LCSW/MHC‑A/MFT‑A, HP for Postdoctoral clinician, or HN for Physician Assistant

Reference for CPT codesRefer to the Behavioral Health Outpatient Professional Services payment policy for applicable CPT codes

Supervision, Service Provision, and Documentation Obligations

Documentation Required

Supervised Service Provision

Services provided by non-credentialed supervisees (LCSWs, Postdoctoral clinicians, MHC-As, MFT-As, and PAs) must be delivered under the supervision of an independently licensed, BCBSRI‑credentialed behavioral health clinician. The supervising clinician must review and document the member's overall treatment (assessment, treatment plan, diagnosis changes) and meet with the supervisee regularly per Rhode Island Department of Health guidelines.

The supervising clinician must be credentialed with BCBSRI and this must be documented.
Patients must be informed when a non‑credentialed clinician provides services and documentation of the patient’s awareness must be maintained in the record.
All supervising protocols and written policies must outline the processes for review of documentation, regular supervisory meetings, and patient notification.

Billing Rule

Claim Submission and Audit Requirements

Claims for services rendered by supervisees must be submitted by the independently licensed, BCBSRI‑credentialed supervising clinician. Claims must include the appropriate modifier to indicate the service was performed by a supervised provider: use HO for LCSW/MHC‑A/MFT‑A; HP for Postdoctoral clinicians; HN for Physician Assistants. Failure to provide requested documentation within 30 days may result in denial or retraction of payment.

Claims submitted under the supervisor’s NPI.
Include the correct modifier on claims (HO, HP, or HN) as applicable to the supervisee.
Maintain and produce all documentation for BCBSRI audits or documentation requests within 30 days to avoid payment denial or retraction.

Provider Type Definitions

LCSW

TermLicensed Clinical Social Worker (LCSW)

Supervisor requiredSupervisor = Licensed Independent Clinical Social Worker (LICSW)

Billing/licensure noteLicensure that bills = Licensed Independent Clinical Social Worker (LICSW)

LICSW

TermLicensed Independent Clinical Social Worker (LICSW)

RoleActs as supervisor for LCSWs per the supervisory protocol

BillingLICSW is the licensure that may bill when required

MHC-A

TermMental Health Counselor Associate (MHC‑A)

SupervisorsSupervised by LMHC, licensed psychiatrist, licensed psychologist, LMFT, or LICSW

ScopeAssociate‑level counselor permitted to deliver supervised outpatient behavioral health services

MFT-A

TermMarriage and Family Therapist Associate (MFT‑A)

SupervisorSupervised by a Licensed Marriage and Family Therapist (LMFT)

ScopeAssociate‑level MFT permitted to provide supervised outpatient services under LMFT oversight

Postdoctoral clinician

TermPostdoctoral clinician

SupervisorSupervisor = Licensed Psychologist

Billing/licensure notePostdoctoral clinician's licensure that bills = Licensed Psychologist

PA (behavioral health)

TermPhysician Assistant (behavioral health) — PA‑BH

SupervisorSupervised by a licensed psychiatrist within a behavioral health setting

PurposePA working toward behavioral health specialization may render supervised outpatient services