Billing and coding
How to bill insurance under a supervisor's credentials
Learn about supervisory billing with Headway’s in-depth guide and FAQs.
March 13, 2025
7 min read
Whether you’re relatively new to the world of billing insurance or have been filling out claim forms for years, you know that healthcare billing can be complicated. And supervisory billing—which occurs when a provisionally licensed therapist or a trainee bills for services using a supervisor’s credentials—is no exception.
From understanding eligibility requirements to making sense of the various rules imposed by individual insurance providers and state licensing boards, professionals who utilize it encounter their fair share of challenges. Yet this kind of billing, which has become increasingly common in mental healthcare settings, can have real benefits for therapists and their clients alike.
Interested in implementing supervisory billing in your own practice? Here are a few things you ought to know.
Who can use supervisory billing?
When permitted by the client’s insurance company and the state in which the services are performed (more on that later), supervisory billing can be used by provisionally licensed therapists who are supervised by a fully licensed mental health professional. The supervising clinician—who must be credentialed with the client’s insurance company—is ultimately responsible for the services their trainee provides to the client and uses their own NPI number to bill for those services. Additionally, through a review process, supervisors typically are required to offer feedback on the trainee’s performance and make sure the trainee upholds all care standards mandated by law.
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How does supervisory billing help therapists and their clients?
Supervisory billing can offer significant advantages for both therapists and their patients. For starters, enabling provisionally licensed therapists to treat clients means an increase in the number of mental health professionals—and a greater ability for therapists as a whole to meet the high demand for services. Supervisory billing also allows opportunities for up-and-coming therapists to get the training and experience they need to thrive, while potentially providing individual therapy practices a chance to grow their businesses by taking on new clients they might not have been able to accommodate otherwise.
What are the regulations for supervisory billing?
Currently, supervisory billing is only available through select insurers (and only in certain states). Insurers that allow supervisory billing include Cigna and Aetna, which currently permit the practice in all states. Optum and United Healthcare also authorize supervisory billing, but only in California, Colorado, Iowa, and Massachusetts; the providers subject other states to additional eligibility criteria and restrictions. Your best bet? Check an insurer’s written policies (which are subject to change) and any billing code information you might need before submitting a claim using supervisory billing to avoid denial.
Is there a difference between incident-to and supervisory billing?
Yes. The two billing types are sometimes referred to interchangeably, but they are indeed different. One major distinction? While supervisory billing is used by a provisionally licensed therapist who forms a treatment plan on their own, incident-to billing is typically reserved for non-physician practitioners (NPPs) who offer their services in coordination with a treatment plan that has been established by a physician. Plus, incident-to billing also usually calls for the physician to be onsite while the NPP works with the patient. Supervisory billing, on the other hand, generally does not (though, as mentioned earlier, a certain degree of monitoring is expected).
Does Headway allow supervisory billing?
No, currently, Headway does not support supervisory billing, but we hope to accommodate it in the future. Would utilizing supervisory billing through Headway benefit your practice? Tell us about it here.
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Billing insurance under a supervisor’s credentials can increase the availability of mental healthcare and help therapists in training to get hands-on experience. Still, you should always check an insurer’s written policies before submitting a supervisory billing claim to avoid denial. For more information on Headway’s billing and state-specific regulations, here’s what Headway-initiated billing and documentation reviews look for.
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Simplify insurance and save time on your entire workflow — from compliance and billing to credentialing and admin.
This content is for general informational and educational purposes only and does not constitute clinical, legal, financial, or professional advice. All decisions should be made at the discretion of the individual or organization, in consultation with qualified clinical, legal, or other appropriate professionals.
© 2025 Therapymatch, Inc. dba Headway. All rights reserved. No part of this publication may be reproduced without permission.
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