CurrentBlue Cross Blue Shield - Rhode IslandPolicy N/A

Behavioral Health Supervisory Protocol for Licensed Clinical Social Workers, Postdoctoral Clinicians, Mental Health Counselor Associates, and Marriage and Family Therapist Associates

Governs supervisory protocol requirements for LCSWs, Postdoctoral clinicians, Mental Health Counselor Associates (MHC-As), and Marriage and Family Therapist Associates (MFT-As) delivering outpatient services under supervision of a BCBSRI-credentialed independent behavioral health clinician in Rhode Island.

Policy Summary

PayerBlue Cross Blue Shield - Rhode Island

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

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateJan 2, 2023

Next Review DateN/A

Key ActionCredentialed outpatient providers must submit and receive BCBSRI approval of a supervisory protocol prior to supervisees rendering reimbursable services; send protocols to Behavioralhealth@bcbsri.org with required documentation.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

HO, HPrequired claim modifiers for supervisee services

Behavioralhealth@bcbsri.orgsubmit protocols to

6 itemsrequired protocol elements

800-274-2958admission notification contact

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Supervisory Protocol Coverage Requirements

Supervisory protocol coverage requirements

Requirements for supervisee services to be eligible for reimbursement under BCBSRI:

Supervisee services must be provided under an approved supervisory protocol submitted by a BCBSRI‑credentialed professional outpatient provider.

Supervisory protocol must be submitted to Behavioralhealth@bcbsri.org and receive BCBSRI approval prior to supervisees rendering reimbursable services.

ALL of the following

Documentation of the supervising clinician being credentialed with BCBSRI.
A written policy addressing the supervisory protocol utilized at the clinic.
The process by which documentation of the patient’s overall treatment (assessment, treatment plan, and any changes to the diagnosis) is reviewed by the supervising BCBSRI‑credentialed provider(s).
A clear process for informing the patient that a clinician who is not credentialed with BCBSRI is providing the service and documentation of the patient’s awareness of same.
A process that supports the supervisor(s) and the supervisee meeting on a regular basis, in accordance with Rhode Island Department of Health guidelines.
The supervising clinician’s Tax ID and National Provider Identifier (NPI).

Claims for supervisee services must be submitted by the independently licensed BCBSRI‑credentialed clinician; include the appropriate modifier (HO for LCSW/MHC‑A/MFT‑A or HP for Postdoctoral clinician) per coding guidance.

Benefits and coverage may vary by contract; refer to the member’s Evidence of Coverage or Subscriber Agreement. Services may be rendered to Commercial and Medicare members; CMS Chapter 15 guidance on direct supervision applies (supervisor must be present in the office suite and immediately available).

Claim Modifiers and Coding for Supervisee Services

Claim modifiers for supervisee servicesModifier

HO	Modifier to indicate services rendered by an LCSW, MHC-A, or MFT-A
HP	Modifier to indicate services rendered by a Post Doctorate Clinician

Submission, Approval, and Notification Requirements

Prior Authorization

Submit supervisory protocol and obtain BCBSRI approval before supervisee provides reimbursable services

Credentialed outpatient providers must submit a supervisory protocol and receive BCBSRI approval before an LCSW, Postdoctoral clinician, MHC-A, or MFT-A may render reimbursable services. Send the supervisory protocol to Behavioralhealth@bcbsri.org and include the required documentation elements listed by BCBSRI.

Documentation that the supervising clinician is credentialed with BCBSRI
A written clinic supervisory policy describing the supervisory protocol
Process for supervisory review of patient treatment documentation (assessment, treatment plan, and diagnosis changes)
Process for informing the patient that a non‑credentialed clinician is providing services and documentation of the patient’s awareness
Process supporting regular supervisor–supervisee meetings consistent with Rhode Island Department of Health guidelines
Supervising clinician Tax ID and NPI

Key Role Definitions

Mental Health Counselor Associate — definition entry

TermMental Health Counselor Associate (MHC-A)

Supervision allowed underLicensed Mental Health Counselor (LMHC), licensed psychiatrist, licensed psychologist, Licensed Marriage and Family Therapist (LMFT), or Licensed Independent Clinical Social Worker (LICSW)

Credentialing by BCBSRIBCBSRI does not credential MHC-As; services permitted only when supervised by a BCBSRI‑credentialed independent behavioral health clinician

Submission requirementSupervisory protocol must be submitted to and approved by BCBSRI prior to MHC-A rendering reimbursable services

Marriage and Family Therapist Associate — definition entry

TermMarriage and Family Therapist Associate (MFT-A)

Policy Summary

PayerBlue Cross Blue Shield - Rhode Island

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

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateJan 2, 2023

Next Review DateN/A

SourceLink

On This Page

Documentation Required

Notify Behavioral Health Utilization Management of admissions when required

Notification of admission is required for some behavioral health outpatient professional services; providers must contact BCBSRI's Behavioral Health Utilization Management to notify admissions.

Contact Behavioral Health Utilization Management at 800-274-2958 for required admission notifications

Supervision allowed underLicensed Marriage and Family Therapist (LMFT)

Credentialing by BCBSRIBCBSRI does not credential MFT-As; services permitted only when supervised by a BCBSRI‑credentialed independent behavioral health clinician

Submission requirementSupervisory protocol must be submitted to and approved by BCBSRI prior to MFT-A rendering reimbursable services

Licensed Clinical Social Worker — definition entry

TermLicensed Clinical Social Worker (LCSW)

Supervision relationshipBCBSRI allows an LCSW to practice under supervision of a Licensed Independent Clinical Social Worker (LICSW)

Credentialing by BCBSRIBCBSRI does not credential LCSWs for independent practice in this supervisory context; supervisee services require a BCBSRI‑credentialed supervising clinician

Submission requirementSupervisory protocol must be submitted to and approved by BCBSRI prior to LCSW rendering reimbursable services

Licensed Independent Clinical Social Worker — definition entry

TermLicensed Independent Clinical Social Worker (LICSW)

RoleMay supervise LCSWs and Mental Health Counselor Associates (MHC-As) to render outpatient services under BCBSRI policy

Credentialing requirementSupervising LICSW must be credentialed with BCBSRI to submit an approvable supervisory protocol

Submission requirementSupervisory protocols (including supervising clinician documentation) must be sent to Behavioralhealth@bcbsri.org and approved prior to supervisee services for reimbursement