This program is currently in a pilot phase specifically for group practices in New York seeing Aetna and Cigna clients and group practices in Texas seeing Aetna, Cigna, and BCBS TX clients. While we are prioritizing group practices initially, we’re actively working to expand to additional major payers, new states, and solo providers over the next year.
Not in your state yet? Fill out this form and we'll let you know when supervisory billing becomes available.
Supervisory billing enables a fully licensed clinician to bill insurance for services provided by a provisionally licensed mental health clinician (such as an 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
Take a look at the table below to understand the supervisee and supervisor license types we accept. Please note that New York and Texas require the supervisor name and practice to be on the supervisee’s license.
Caseload limits
States have different limits for how many supervisees a supervisor can oversee. Headway currently limits supervision based on the appropriate state’s licensing board requirements, but 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 your state’s 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.
| Current Supervisee Licenses Accepted | Supervisor Types Allowed | Maximum # of Supervisees per Supervisor |
| New York | ||
| NY Licensed Master of Social Work (LMSW) | LCSW, Psychologist | 5 |
| NY - Marriage and Family Therapist - Limited Permit (MFT-LP) |
LCSW, LMFT, Psychologist Supervisor name and practice must be on supervisee’s license |
5 |
| NY - Mental Health Counselor - Limited Permit (MHC-LP) |
LCSW, LMHC, Psychologist Supervisor name and practice must be on supervisee’s license |
5 |
| NY - Psychologist - Limited Permit (Psychologist-LP) |
Psychologist Supervisor name and practice must be on supervisee’s license |
5 |
| Texas | ||
| TX - Licensed Master Social Worker (LMSW) |
LCSW-S Supervisor name must be on supervisee's license |
No max |
| TX - Licensed Professional Counselor Associate (LPC-A) |
LPC-S Supervisor name must be on supervisee's license |
No max |
| TX - Licensed Marriage and Family Therapist Associate (LMFT-A) |
LMFT (supervisor approved certification) Supervisor name must be on supervisee's license |
No max |
| TX - Licensed Psychologist with Provisional Status |
Psychologist Supervisor name must be on supervisee's license |
No max |
| TX - LPA |
Psychologist Supervisor name must be on supervisee's license |
No max |
| Florida | ||
| Registered Clinical Social Work Intern |
LCSW Supervisor name must be on supervisee's license |
25 |
| Registered Marriage and Family Therapy Intern |
LMFT Supervisor name must be on supervisee's license |
25 |
| Registered Mental Health Counseling Intern |
LMHC Supervisor name must be on supervisee's license |
25 |
| Psychology Resident or Post-doctoral fellow | Psychologist | 25 |
Getting started
For step-by-step guides on how to get started, select a link below:
To onboard a supervisor (if they do not have a Headway account), or a supervisee:
- Log into Sigmund as an admin
- Click Manage team on the left panel
- Send invites to the supervisor and supervisee.
Note: both supervisors and supervisees are required to have Sigmund Lite access to partake in supervisory billing on Headway.
Once invited, providers will receive an email to confirm enrollment and start the intake process.
Required sign-offs
- Both the supervisor and supervisee must review and 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
Supervisees are not 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 provisionally-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, Cigna, and Blue Cross and Blue Shield, 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.