This program is currently in a pilot phase specifically for group practices in New York seeing Aetna clients. While we are prioritizing group practices initially, we’re actively working to expand to additional major payers (such as Cigna) and new states in the coming months.
Supervisory billing enables a fully licensed clinician to bill insurance for services provided by a pre-licensed 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. It is not the same as "incident-to" billing (which typically refers to services provided on behalf of a physician).
Eligibility and licensing
We are currently supporting LMSWs, LPCs, LMHCs (MHC-LPs), and Clinical Psychologists (CP-LPs) in New York, including support cross-license supervision (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.
Scope of support
Headway focuses specifically on the insurance billing aspect of supervision. We do not assist with the licensure process itself or the submission of applications to become fully licensed.
Getting started
For supervisors
Supervisors are licensed therapists who manage the caseload of provisionally licensed therapists. To onboard a supervisee:
- Log into Sigmund as an admin
- Click Manage team on the left panel
- Send invites to the supervisor and supervisee
For supervisees
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 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. We plan to integrate pre-licensed clinicians into the public search in the near future.
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: Must be written for every session.
- 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.
To maintain the clinical integrity and legal validity of the supervisory relationship, sessions must be confirmed by the clinician who delivered care and approved by their designated supervisor. This ensures that the supervisor has reviewed the clinical notes and provided the necessary sign-off required for billing.
Billing and payment
Rates
While payer rates may vary, Headway always aim to match fully licensed reimbursement rates for supervisees whenever possible. For Aetna, rates will match fully licensed therapists. We are currently negotiating rates for other payers and will update when we have more information.
Provider payments
Headway does not set a "price of supervision." We will pay the group directly for all sessions held by the group’s clinicians.
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.