Supervisory billing

Supervisory billing enables a fully licensed clinician to bill insurance for services provided by a pre-licensed mental health clinician (such as an intern, associate, or trainee). Headway is introducing functionality to allow supervisors to review supervisee notes and bill these services through our insurance partners.

Note: Supervisory billing is specific to provisionally licensed clinicians billing under a supervisor's contract and NPI. It is not the same as "incident-to" billing, which is defined by CMS (Centers for Medicare and Medicaid Services) as services provided under the direct supervision of a physician, such as a psychiatrist.
 

Eligibility and licensing 

We currently support LMSWs, LPCs, LMHCs (MHC-LPs), and Clinical Psychologists (CP-LPs) in New York, including support cross-license supervision arrangements (e.g., a fully licensed psychologist supervising an LMSW) in accordance with state regulations.
 

Caseload limits

To remain compliant with New York State licensing board requirements, Headway currently limits each supervisor to a maximum of five (5) provisionally licensed clinicians. 

This limit does not account for any supervisees you may be working with outside of Headway. It is your responsibility as a licensed supervisor to ensure your total supervisee caseload remains compliant with New York State licensing board requirements.
 

Scope of support

Headway's supervisory billing program is designed to streamline the insurance billing process for supervisory relationships, ensuring compliant and efficient reimbursement for your practice. 

For guidance on licensure requirements or the application process for full licensure, we encourage clinicians to consult their state licensing board or a qualified supervisor.

Getting started

For step-by-step guides on how to get started, select a link below:

• How it works: Getting started as a supervisee on Headway
• How it works: Getting started as a supervisor on Headway
• How it works: Getting started as an admin on Headway

To onboard a supervisee:

1. Log into Sigmund as an admin
2. Click Manage team on the left panel
3. Send invites to the supervisor and supervisee
   • Note: Both supervisors and supervisees are required to have Sigmund Lite access to participate in supervisory billing on Headway
      

Once invited, supervisees will receive an email to confirm enrollment and start the intake process (if they do not already have a Headway account).

Required sign-offs

• Both the supervisor and supervisee must sign the Terms & Conditions of the program.
• All clients working with a supervisee are required to review and sign a disclosure form confirming they understand they are receiving care from a provisionally licensed provider.

Client visibility and referrals

During this initial phase, supervisees will not be listed in Headway’s public search, and may only treat existing clients or referrals sourced directly by your practice who have been clinically assessed and determined to be appropriate for care with a provisionally licensed provider. 

Headway is exploring expanding visibility for pre-licensed clinicians in the public search and will share updates as this becomes available.

Clinical workflow

To ensure clinical and legal compliance, create a secure audit trail, and facilitate the co-signature functionality required by payers and state boards, all supervisees are required to use Headway for notes and treatment plans. 

Documentation requirements

Supervisees and supervisors must use Headway’s note templates. These are the same templates used by fully licensed providers, specifically designed to meet payer standards and protect your practice from clawback risks.

• Progress notes: A progress note is required for every session and should be completed by the supervisee, and reviewed/approved by their supervisor.
• Treatment plans: Must be associated with every client’s care. These can be written by the supervisee in Headway or uploaded by the supervisor. A plan is required after the client has had two sessions.

Confirming sessions

Group admins cannot confirm supervisory billing sessions, to maintain the clinical integrity and legal validity of the supervisory relationship.

Sessions must be confirmed by the clinician who delivered care, and then approved by their designated supervisor. This workflow ensures that the supervisor has reviewed any clinical notes and provided the necessary sign-off required for billing.

Billing and payment

Rates 

Headway is committed to securing competitive reimbursement rates for supervisory billing. For Aetna, supervisee sessions will be reimbursed at rates consistent with fully licensed providers. We are actively negotiating rates with additional payers and will communicate updates as they become available.
 

Provider payments

Payment for all sessions conducted by clinicians within your practice will be made directly to the group.

Headway does not determine or regulate compensation arrangements between supervisors and supervisees, as those terms are established within your practice.
 

Compliance

While supervisory billing can naturally invite more oversight from payers and state boards, Headway’s mandated note templates and co-signature workflows are designed to ensure you meet payer standards and minimize clawback risks.