Latest / The Mental Health Evolution / Ep 58: Two States, Two Directions: What's Happening to the Future of Our Workforce

Transcript

Ep 58: Two States, Two Directions: What's Happening to the Future of Our Workforce · The Mental Health Evolution

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  (Transcribed by TurboScribe. Go Unlimited to remove this message.) This podcast is part of the Frederick podcast
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  network.
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  Learn more at listenfrederick.com.
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  Welcome to Mental Health Evolution, a podcast about
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  what's changing in mental health and why it
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  matters.
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  I'm your host, Rachel Harrison, inviting you into
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  honest conversations with people from all perspectives in
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  the field, clinicians, tech founders, investors, insurance companies,
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  and all the folks in between.
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  Let's explore what's working, what's not, and what's
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  next.
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  Welcome back, everyone, to the Mental Health Evolution
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  podcast, where we talk about how the landscape
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  is rapidly evolving in the mental health industry.
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  This is a solo episode, and I want
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  to talk about something that's happening right now
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  in insurance and workforce policy that I don't
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  think is getting nearly enough attention.
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  As you may know, I own a multi
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  -state practice and run a training institute.
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  I employ clinicians at every stage of licensure,
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  including interns, pre-licensed, and limited license clinicians
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  who are doing excellent clinical work under supervision
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  while they complete the hours to get their
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  full license.
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  And I am watching two states make completely
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  different policy directions at the exact same moment
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  in time in ways that will directly affect
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  clinicians, practices, folks that I train, and probably
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  your clinical world too.
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  So it's important to define that in this
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  episode, we are talking about three different levels
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  of clinicians.
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  The first level is a clinical intern who
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  is at the very end of their graduate
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  coursework and getting real-life clinical experience while
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  under the supervision of an advanced, fully licensed
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  clinician, as well as the supervision of their
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  degree program.
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  The next level, or level two, is a
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  provisionally licensed clinician.
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  These are graduates who must work anywhere from
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  two to four years under the supervision of
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  a clinical supervisor, who is normally someone who
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  has a minimum level of experience along with
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  training and certification to be a supervisor.
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  This clinician takes legal responsibility for the clients
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  the provisionally licensed clinician sees for psychotherapy.
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  Both level one and level two clinicians introduce
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  a high cost to a practice or organization
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  because of the hours and cost of both
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  clinical and administrative supervision.
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  Historically, interns are the highest cost and risk
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  and normally do not get paid for their
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  training and experience because of that.
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  Provisionally licensed clinicians are normally paid a lower
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  wage than a fully licensed clinician because of
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  the high cost and liability of their license
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  requirements.
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  Insurance companies have not historically covered interns at
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  all with the exception of Medicaid.
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  Some carriers do cover provisionally licensed clinicians and
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  others allow billing under the supervisor's credentials and
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  paneling.
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  Lastly, or the fully licensed level, level three,
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  is clinicians that have an independent license to
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  practice.
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  They can practice anywhere in a state where
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  they're licensed and insurance has always covered this
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  level of licensure with clinicians who are paneled.
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  So let's get to what is happening currently.
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  First of all, I want to talk about
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  Blue Cross Blue Shield of Michigan.
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  So this is the largest commercial insurer in
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  the state of Michigan and they hold nearly
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  70 percent of Michigan's commercial market.
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  Earlier this year, they announced that starting March
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  1st, 2027, they will no longer reimburse for
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  services provided by limited licensed clinicians in private
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  practice settings.
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  So let me explain what this means in
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  plain terms.
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  Right now, when a newly graduated clinician joins
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  a practice, there are two options for billing
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  insurance.
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  Sometimes insurance companies actually cover their work and
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  they can bill directly under their name and
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  they can be credentialed with the insurance company.
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  Sometimes what's allowed is to be billed under
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  their clinical supervisor.
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  So they can still see clients, they can
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  provide insurance-based care, but those billings are
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  all going under their supervised or their clinical
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  supervisor.
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  The way practices have made this work is
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  through this type of billing if an insurance
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  company does not recognize the provisional or limited
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  license.
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  So this means that the practice can afford
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  to employ, develop a pre-licensed clinician while
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  they complete that supervised training.
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  Blue Cross Blue Shield of Michigan says they
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  are ending this in private practice setting and
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  framing it as a quality of care decision.
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  They say that if limited licensed clinicians want
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  to train toward full licensure, they should do
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  so in hospitals, outpatient psychiatric centers, or community
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  health agencies where there is built-in oversight.
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  Practice owners in Michigan are not buying the
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  quality of care framing.
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  One practice owner told Bridge Michigan that the
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  move will simply sink some practices.
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  Another estimates she will lose coverage for 250
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  clients.
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  The president of Michigan Mental Health Counselors Association
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  said it plainly, you are cutting off a
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  pipeline for these practitioners to become fully licensed.
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  And this quality of care piece is very
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  interesting because in private practice settings, the same
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  level of supervision, sometimes higher levels of supervision
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  are required for provisionally licensed clinicians.
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  But the key question that no one can
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  answer right now is whether this stays in
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  Michigan.
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  Blue Cross Blue Shield Michigan has nearly 70%,
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  as we mentioned earlier, of the state's commercial
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  market and is the dominant payer for this
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  workforce.
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  If other insurers in Michigan or other states
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  follow the economics of training the next generation
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  of therapists, collapse in the private practice setting.
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  So here's what I want you to think
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  about.
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  Every fully licensed therapist was once a provisionally
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  licensed therapist.
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  There is no other path.
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  And if private practices can no longer afford
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  to employ pre-licensed clinicians because insurance will
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  not reimburse them for their work, that training
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  ground disappears.
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  The pipeline shrinks.
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  And three to five years from now, the
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  workforce shortage we are already living with gets
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  meaningfully worse.
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  At the same time that this is happening
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  in Michigan, Maryland passed HB 1094 and SB
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  910 in the 2026 legislative session, and the
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  governor signed both into law in April.
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  These bills go in the exact opposite direction.
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  One state is mandating reimbursement for supervised interns.
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  Another state's largest insurer is eliminating coverage for
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  a level up from intern, which is the
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  provisionally licensed clinician.
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  NESW Maryland testified in support of this bill
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  by saying that supervised interns are providing real
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  services to real clients and that the inability
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  to bill for those services limits placement opportunities
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  and shrinks the capacity to deliver care.
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  Maryland also passed a behavioral health workforce investment
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  fund back in 2023 and cited reduction in
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  mental health workforce shortage areas from 22 to
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  10 jurisdictions as evidence that investing in this
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  pipeline works.
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  Maryland made a deliberate policy choice.
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  If you want to operate in this state
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  as an insurance company, you have to pay
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  for supervised interns.
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  You have to support the training environment.
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  This is a legislative answer to the same
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  question.
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  Michigan's largest insurance just answered very differently.
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  So let's zoom out.
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  What is the bigger picture here?
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  There is no national standard.
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  There is no federal policy that says how
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  this should work.
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  Every fully licensed therapist and clinician in this
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  country got there through supervised practice, and right
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  now whether that pipeline is financially viable depends
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  largely on what state you are in and
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  which insurer covers your clients.
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  When insurance stops reimbursing for pre-licensed work
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  in private practice settings, the cost of developing
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  new clinicians doesn't just disappear, it just gets
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  shifted.
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  It gets shifted onto the practices that still
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  believe in training and onto the pre-licensed
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  themselves, some of whom are already working for
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  very little pay while they pay for their
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  own supervision out of pocket depending on their
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  place of work.
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  The clinicians who complete that gauntlet who survive
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  the years of low pay and out-of
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  -pocket supervision costs are then free to practice
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  independently.
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  The clinics and practices that invest their time
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  and resources in training both interns and provisionally
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  licensed clinicians often do so because they believe
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  in quality training for future therapists.
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  The costs and liabilities can be prohibitive.
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  Many groups don't allow interns nor provisionally licensed
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  clinicians for this reason, and this limits the
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  amount of training opportunities that can be provided,
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  as well as the quality of training given
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  to new clinicians.
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  If the pipeline gets starved, everyone feels the
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  impact.
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  As a practice owner and trainer, what I
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  want clinicians and practice owners to take away
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  from this episode is that this is not
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  a billing technicality.
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  This is a workforce policy question that is
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  being decided right now state by state and
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  insurer by insurer without a lot of public
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  conversation.
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  Maryland showed that legislation is one lever, advocacy
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  through your professional associations is another.
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  And knowing what your own state's laws and
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  insurer contracts actually say about supervised billing is
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  the starting point.
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  If you are a business owner, look at
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  your payer contracts.
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  If you are a pre-licensed clinician looking
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  for placement, ask whether the practices you are
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  considering have examined this.
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  If you are a fully licensed clinician and
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  you supervise, understand that the financial infrastructure supporting
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  that work is not guaranteed.
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  This story is not finished, but the direction
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  of travel is really worth paying attention to
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  right now, looking at how that's going to
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  impact especially private practice.
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  Thanks for listening to this podcast today.
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  I hope this was helpful as we talk
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  about the changing landscape in the mental health
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  industry.
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  Before we wrap up, I want to point
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  you to three pieces that inform today's conversation
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  that are worth reading if you want to
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  go deeper.
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  All of these links will be in the
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  show notes.
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  First article is from Psychology Today titled New
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  Insurance Policy on Limited Licensed Therapists by Dr.
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  Joel L.
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  Young.
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  That's from June 2026 and it was written
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  by the medical director of a behavioral medicine
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  clinic in Michigan who is watching this change
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  affect his own hiring decisions in real time.
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  He makes the workforce pipeline argument clearly and
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  asks the question that nobody has a good
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  answer to.
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  At a time when access to mental health
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  care is one of our greatest public health
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  challenges, is reducing opportunities for developing therapists really
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  the direction that we want to go?
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  Article 2 is from the Maryland Insurance Administration,
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  Bulletin 26-14 on HB 1094 and SB
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  910, also from June 2026.
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  This is the official regulatory bulletin implementing Maryland's
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  new law.
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  It is dry reading, but it's the primary
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  source for what Maryland is actually requiring of
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  insurers starting January 1, 2027.
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  If you are in Maryland or curious about
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  what a legislative fix to this problem looks
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  like, this is a good place to start.
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  And Article 3 from Bridge Maryland, Michigan Blue
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  Cross to Limit Mental Health Benefit Will Thousands
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  Lose Care?
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  by Robin Erb, June 11, 2026.
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  This is the best on-the-ground reporting
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  I found on the Michigan story.
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  Bridge, Michigan is a non-profit newsroom and
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  Robin Erb spoke directly to practice owners who
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  are already calculating how many limited license clinicians
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  they will have to let go in March.
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  One practice owner estimated 250 of his clients
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  will lose coverage.
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  Another said simply, this will sink some practices.
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  It's an important read, and the link is
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  here.
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  Thanks for listening today.
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  Bye for now.
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  Thanks for listening to the Mental Health Evolution
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  podcast.
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  Join the conversation, find us on social, send
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  us your thoughts, and tell us what you're
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  seeing in your corner of the mental health
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  world.
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  Until next time, stay curious and keep evolving.