Medicaid narrows where trainee therapists can bill

Unlicensed master's-level clinicians can bill Alaska Medicaid for psychotherapy only if they are affiliated with a qualifying community behavioral health clinic, under guidance the Division of Behavioral Health issued Monday.

The division calls it a clarification. The clinic-affiliation requirement does not appear in its June 2 guidance, which laid out who may provide and bill for psychotherapy but said nothing about where clinicians pursuing licensure may affiliate. The new document supersedes all previous guidance and sets no effective or phase-in date.

The effect falls on therapists still working toward licensure under supervision. Medicaid will reimburse their psychotherapy inside a qualifying clinic. Outside one, it will not.

Alaska News previously covered the June guidance, which limited psychotherapy billing to licensed providers or supervised clinicians actively pursuing licensure: psychiatrists, counselors, marriage and family therapists, and clinical social workers, along with physicians, physician assistants and nurses working within their scope. Both the supervising and the rendering provider carry responsibility for compliance.

The update also loosens paperwork. Naming the supervising clinician in the progress note is now optional. Agencies can instead keep the clinician's clinical placement approval on file, or verify the supervisory relationship another way. Identifying the supervisor on the claim itself is recommended, not required.