I am currently volunteering in private practice because insurance companies will not allow sub-contracting of my supervisor (psychologist) to me, an APCC. So my question is, can we sub-contract via a group NPI? I hear other places are doing this? If you do not have the answer for this, please refer me to someone who does.



Greetings Jamie,

That’s a really good question! Many (it seems every) post-degree, pre-licensed associate-level clinician, across the USA, is asking this very question–as well as every practice administrator wanting to hire interns/residents/associates, and is trying to answer themselves the question “what can they bill?”

The answer, in most private practice settings, is usually not much. Typically, rarely do any private insurance plans allow for this, like Blue cross, Aetna, Cigna, etc. Regarding Medicaid products, the answer is “it depends” (sorry). It depends on the MCO that manages medicaid, the certification level of the practice, and Medicaid policies in your specific area.

Basically, none of these are legal issues, so the answers can change (technically, but rarely). The issue is what the practice’s specific contract with the insurer/payer says. Some clinics, non-profits, or hospitals might have special contracts that allow associates / residents to bill. Some longstanding practices might have contracts that allow for associates for bill. This is all very rare, perhaps because there are a lot of fully-licensed therapy providers, and insurance companies don’t see a need to allow associates to bill for services.

It’s a tough part on one’s career, to be sure, post degree and pre-license, and I admit the system isn’t very well designed to help associates like you gain the hours you need to obtain your full licensure.

I hope this helps, even if it’s not great news.