Blue Review
A Provider Publication

January 2023

Expanding Access to Behavioral Health Care Services: Coverage for Services Provided by Pre-licensed Behavioral Health Interns and Postdoctoral Fellows

This is the first article in a series that’s committed to increasing awareness of ways we’re partnering with health care providers and other community organizations to expand access to behavioral health services for our members, their families and the community.

Blue Cross and Blue Shield of Illinois (BCBSIL) reimburses for covered services provided by masters and doctoral interns, in addition to postdoctoral fellows (e.g., psychology, social work and counseling trainees). These unlicensed behavioral health trainees must be working toward clinical state licensure, under the clinical supervision of a fully licensed BCBSIL contracted provider. The intern or fellow isn’t added to a group, doesn’t contract with BCBSIL and is excluded from BCBSIL’s online Provider Finder® directory.

The behavioral health trainee, as defined above, may only bill under the supervising clinician’s rendering National Provider Identifier (NPI) and must abide by the same contractual obligations as the contracting provider. The behavioral health trainee’s supervising contracted provider must maintain adequate medical and administrative records consistent with the standards of major organizations conducting accreditation and must permit BCBSIL or its agent or representative to review such medical records and administrative records regarding BCBSIL members.

All covered services provided to and billed for BCBSIL members by the contracting provider must either be performed by the contracting provider or under that provider’s direct and personal supervision, except as otherwise authorized and communicated by BCBSIL. Direct personal supervision requires that a contracting provider be in the immediate vicinity to perform or to manage the procedure personally, if necessary, but doesn’t require the contracting provider to be present in the actual therapy session.

Licensing and supervision requirements are directed by the corresponding licensing bodies and/or professional organizations corresponding to the clinician’s license.

Non-credentialed provider types – Licensed Social Workers (LSWs) and Licensed Professional Counselors (LPCs) – may be added to a group but will remain excluded from BCBSIL’s Provider Finder. These providers can and should bill under their own rendering NPIs. Once they’re fully licensed, and upon completion of the credentialing process through the Council for Affordable Quality Healthcare (CAQH®), Licensed Clinical Social Workers (LCSWs) and Licensed Clinical Professional Counselors (LCPCs) must be added to the group again. At this point, these fully licensed clinicians will be reflected as such in BCBSIL’s Provider Finder.

In summary:

  • Covered services rendered by the behavioral health trainee as described above must be billed under a supervising licensed clinician’s NPI, in accordance with all other standard billing requirements.
  • Direct, personal supervision is required, which means the supervising contracted provider must be available 100% of the time the behavioral health trainee is providing services, enabling the supervisor to provide direction and intervene in the event of an emergency.
  • Supervising providers may supervise a maximum of four behavioral health trainees at a time.1
  • Behavioral health trainees must receive the required minimum individual face-to-face supervision in compliance with Illinois’ state licensure requirements, specific to the trainee’s level of licensure.
  • Supervisors and any behavioral health trainee should work within the same organization/system. (BCBSIL may waive this element where necessary for programs reaching underserved populations.)
  • Under no circumstances can the behavioral health trainee make direct payment to the supervisor for supervision while pursuing clinical hours for state licensure.

If you have questions or need more information, contact your assigned BCBSIL Provider Network Consultant.

CAQH is an independent third party not-for-profit collaborative alliance of the nation’s leading health plans and networks. The mission of CAQH is to improve health care access and quality for patients and reduce administrative requirements for physicians and other health care providers and their office staffs. CAQH is solely responsible for its products and services.

1This information is consistent with the Centers for Medicare & Medicaid Services (CMS) Medicare teaching rules prohibiting supervision of more than four residents at any given time, as referenced on page 10 of the CMS Guidelines for Teaching Physicians, Interns, and Residents: MLN Booklet, March 2017, ICN 006347 (updated May 2022).