May 22, 2025
Following are reminders and guidance for claims filed by behavioral health providers:
No pass-through billing: Out-of-network providers may be added to a group practice, but they should bill under their own rendering National Provider Identifier. They should perform services only within their scope of practice.
- Claims may not be submitted under the NPI of someone who did not render the service unless there is a formal supervisor-trainee relationship.
- To be eligible for reimbursement, the trainee or out-of-network Qualified Healthcare Provider must abide by the same contractual requirements as the contracted provider or group practice.
Trainees must always be under the QHP’s supervision: All claims billed for services rendered to our members by a QHP shall be performed personally by that QHP or by a trainee under that QHP’s direct and personal supervision, except as otherwise authorized and communicated by Blue Cross and Blue Shield of Texas.
Direct personal supervision requires that the QHP be in the immediate vicinity 100% of the time to perform or manage the procedure if necessary.
- If a trainee is performing services under the direct and personal supervision of a supervising QHP, all laws and regulations applicable to the relevant state and professional licensing board for the type of license and services being delivered must be followed.
- A QHP who is not a trainee should bill under their own license, not the license of another QHP.
- Implementation of a modifier (HL) to designate services performed by a trainee will be required at a future time. Please do not append this modifier until notification is communicated by BCBSTX.
Claims submission and reimbursement: If claims are submitted under your individual NPI, you are certifying that those services were rendered. Claim reimbursement is subject to the terms of a member’s coverage and medical necessity review. Claim forms and itemized statements not supported by documentation may result in processing delays or denial of services.
More information: Review our Clinical Payment and Coding Policy on Medical Record Documentation Guidelines CPCP029 and our Provider Reference Manual.
While this information is intended to provide guidance for behavioral health providers, the same billing requirements are in place for physical health services.
The information provided does not constitute coding or legal advice. Physicians and other health care providers should use their own medical judgment based upon all available information and the condition of the patient in determining the appropriate course of treatment, and to submit claims using the most appropriate code(s) based upon the medical record documentation, coding guidelines and reference materials.