Re: Open Letter to Community Behavioral Health (CBH) Regarding Supervisory Billing in Private Practice Settings

We, the undersigned mental health clinicians, insured community members, and other interested stakeholders, write to request that Community Behavioral Health, the Behavioral Health Managed Care Organization (BH-MCO) for Philadelphia County, revise their provider policies to allow supervisory billing for pre-licensed clinicians (i.e. unlicensed Masters-level clinicians and Licensed Associate Professional Counselors (LAPCs), Licensed Social Workers (LSWs), Marriage and Family Therapists (MFTs), etc) under licensed clinicians (e.g. professional counselors, clinical social workers, marriage and family therapists, etc) in private practice settings. 

The Context:
The infrastructure of Philadelphia’s mental health care landscape relies heavily on the care provided by pre-licensed Masters-level clinicians. Pre-licensed Masters-level clinicians make up a significant portion of the provider population in Philadelphia, working in outpatient agencies, hospitals, clinics, and group private practice settings. With the devastating and sudden closure of large mental healthcare systems within the city of Philadelphia, such as the Wedge Medical Center, identifying a solution to the mental health provider shortage has taken on an even greater urgency. The loss of the Wedge’s several locations throughout the city heralds the potential loss of hundreds of providers from the CBH network, especially pre-licensed clinicians who were able to serve CBH members only under the supervision of licensed clinicians at these locations. This loss is a pivotal opportunity for CBH to update its policies regarding supervisory billing for private practice settings. 

At present, private practice settings are excluded from supervisory billing under current CBH guidelines. This restriction poses a significant barrier to private practices choosing to join CBH's provider network; the financial barrier posed by this restriction disincentivized currently CBH-credentialed practices, as well as practices which participate in other insurance plans, from employing pre-licensed clinicians and/or from joining CBH’s network. This disincentive further contributes to the shortage of providers available to service Medicaid-eligible individuals, which we the undersigned anticipate will be exacerbated by the recent agency closures.

A change to CBH’s policies regarding supervisory billing in private practice settings would be a significant benefit to the CBH provider and member network as many practices host and train clinicians from the graduate intern level with the goal of seeing them to graduation and then through their post-graduate associate practice to licensure. These new clinicians often desire to remain with their private practice internship sites as employees to continue to serve low-income clients.

The Issue:
Unfortunately, these new providers fall into a 'no license' gap and may be forced to leave their private practice settings post-graduation due to the current CBH restrictions on private practice supervisory billing. This significant barrier drives these new clinicians to seek employment at practices which are in-network with commercial insurance plans that do allow supervisory billing and, in the experience of many undersigned, they do not return to ever become Medicaid providers; they simply transition from being private pay or commercial insurance associates to becoming private pay and commercial insurance licensed clinicians. The opportunity to train and retain these pre-licensed clinicians as new Medicaid providers is lost. 

The Solution:
The hope of the undersigned is that CBH will update their guidelines to allow private practices to bill for pre-licensed Master's level clinicians (e.g. LAPCs, LSWs, MFTs, etc) in the manner in which mental health agencies are presently allowed–under the plenary license of CBH credentialed supervisors. CBH updating their guidelines to allow supervisory billing for pre-licensed clinicians would represent a commitment to accessible mental health care for CBH members by creating a pathway for pre-licensed clinicians to become and grow as CBH providers early in their professional careers, ensuring long-term care access for CBH members and continued growth of the CBH provider network.

CBH revising their policies to allow supervisory billing for pre-licensed clinicians in private practice settings would:

 • Expand access to individual, group, relationship, and family therapy for Medicaid recipients in Philadelphia County

 • Help address the shortage of competent providers available to serve Medicaid recipients in Philadelphia County

 • Increase bilingual and culturally responsive care options for Philadelphia's diverse population

--

Letter Drafted: June 23rd, 2025 

Addressed To: Donna E.M. Bailey, MBA, MSEd, Chief Executive Officer; Steve Branigan, Chief Information Officer; Andrew Devos, MEd, Chief Operations Officer; Katie Dunphy, LSW, MPH, PMP, Chief of Staff; Alex Gauthier, Chief Financial Officer; Linda Trinh, Deputy Chief Financial Officer; Dr. Samuel L. Williams, III, MD, MBA, Deputy Chief Medical Officer; the CBH Board of Directors; and DBHIDS.