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Supervised Billing

Supervised billing for behavioral health services means that a qualified licensed provider can bill for covered clinical services within their scope of practice provided by a qualified non-licensed provider when the qualified non-licensed provider is under their direct supervision. A qualified non-licensed provider is defined in HCAR 9.103, the Medicaid Supervised Billing rule, which governs Supervised Billing under Vermont Medicaid. Only clinical services are billable under Supervised Billing - case management, specialized rehabilitation or emergency care, and assessment services, may not be provided by non-licensed providers under Supervised Billing. 

The Department of Vermont Health Access (DVHA) is currently revising the Medicaid Supervised Billing Rule (HCAR 9.103).  In order for DVHA to conduct the necessary outreach and stakeholder engagement required to revise the rule, the Department has issued a retroactive extension for qualified non-licensed providers who are providing clinical services adherent to HCAR 9.103 eligible for Medicaid reimbursement until 12/31/25, regardless of whether or not the provider had met their five-year billing restriction outlined in HCAR 9.103.3(c).    

All Supervised Billing claims must follow all other requirements in HCAR 9.103 and must follow correct coding guidelines. This includes the use of the HO, HN, and HM modifiers which are REQUIRED on all supervised billing claims. All claims without modifiers are subject to audit and recoupment. Additionally, claims for services provided by a non-licensed and non-certified (NLNC) provider and billed under a supervisor without the appropriate modifier may be denied due to recent Medicare changes that affect Third Party Liability.  

Details About the Extension 

The Department of Vermont Health Access (DVHA) has heard from providers that the Supervised Billing Rule (HCAR 9.103) and the included five-year Medicaid billing provision are no longer appropriately serving Vermont Medicaid providers and members. It has become clear that HCAR 9.103 is not achieving the goal of supporting a strong behavioral health workforce and providing high-quality care to Vermonters. To best support the workforce while DVHA revises HCAR 9.103, this extension will be made retroactive from 7/1/22 until 12/31/25. The retroactive extension will apply to NLNC providers and their supervisors in the following ways: 

  • NLNC providers who complied with the five-year Medicaid billing provision and who stopped seeing Vermont Medicaid members, are eligible for the extension and may begin submitting claims for clinical services provided under Supervised Billing. All claims submitted must comply with timely filing requirements and remain subject to all other requirements as outlined in HCAR 9.103.  

  • NLNC providers who complied with the five-year Medicaid billing provision and who continued to see Medicaid patient’s pro-bono, may now submit claims for services provided to Medicaid members under Supervised Billing in accordance with timely filing requirements and all other requirements as outlined in HCAR 9.103. Please reach out to your Gainwell provider representative for their assistance submitting these claims.  

  • Providers who were eligible to be refunded for monies recouped due to a violation of HCAR 9.103.3(c), have been contacted by the DVHA Special Investigations Unit (SIU) and refund arrangements have been made. Each case is unique, and if you are eligible to be refunded monies paid to Vermont Medicaid because of an audit, SIU will be in touch with further instruction.  

  • NLNC providers who billed Vermont Medicaid for services provided under Supervised Billing, in violation of the five- year billing provision, but have not yet been subject to an SIU audit, Vermont Medicaid will not recoup any monies related exclusively to the violation HCAR 9.103.3(c). You may still be subject to an SIU audit for all other violations of HCAR 9.103 and violation of any other Medicaid requirements. 

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