Graduate Intern Billing in Maryland: What OMHCs Need to Know Before January 2027

Maryland's 2026 legislative session produced a change that will directly affect how OMHCs think about staffing, supervision, and billing. House Bill 1094 and Senate Bill 813, passed during the 2026 session, establish that insurance plans covering licensed professional counselor, licensed certified social worker, or licensed psychologist services must also reimburse for services provided by graduate-level clinical interns in those fields -- effective January 1, 2027.

This is not a minor billing technicality. For OMHCs struggling with a chronic workforce shortage and razor-thin margins on Medicaid reimbursement, the ability to bill for intern services meaningfully changes the economics of running a training program. But the reimbursement comes with specific conditions that every practice needs to understand before January 1.

What the Law Requires

The new law amends sections of Maryland's Insurance Article to establish reimbursement rights for graduate-level clinical interns under the following conditions:

The intern must be enrolled in a relevant graduate program. The law covers interns pursuing degrees in counseling, social work, or psychology. The intern must be actively enrolled -- this is not a provision for post-graduate residents or associates, but for students completing their supervised field placement or practicum hours.

Services must be delivered at an outpatient health facility. The law specifies outpatient settings. This covers OMHCs directly. It does not cover community-based settings where interns might otherwise work, such as a client's home or a community center.

The intern must work under direct supervision of an appropriately licensed and board-approved supervisor. The supervision must be direct -- meaning the supervisor is either physically present or immediately available, not just administratively responsible. The supervisor must also be board-approved for supervision of the specific intern's licensure track. Not every licensed clinician qualifies as an approved supervisor under Maryland's licensing board requirements.

Services must be billed by the supervising provider. The intern does not bill independently. The claim goes out under the supervising clinician's NPI, with the intern's services documented as services rendered under supervision. How this is reflected in claim submission (whether the intern's identity appears on the claim and in what capacity) is a billing compliance question worth clarifying with your billing team before January 1.

What This Means Practically

The Workforce Math

Maryland's behavioral health workforce shortage is severe -- with a documented gap of approximately 34,000 positions statewide, and persistent difficulty recruiting and retaining licensed clinicians at Medicaid-level reimbursement rates. Graduate interns represent a meaningful partial solution: they bring clinical capacity to practices at a lower cost than fully licensed clinicians, and many convert to employed staff after licensure.

The limiting factor has always been that intern services were generally not billable, which meant every intern hour was an overhead cost rather than a revenue-generating activity. Practices that ran training programs were essentially subsidizing graduate education out of their own margins.

The new law changes that calculus. If an intern's supervised sessions are reimbursable by commercial insurance carriers effective January 1, 2027, the cost-benefit of running a training program improves substantially. OMHCs that have avoided intern programs because they could not absorb the supervision overhead may find the economics more workable under the new framework.

What the Law Does Not Cover

A few important boundaries to understand:

This is a commercial insurance requirement, not a Medicaid mandate. The law amends the Insurance Article governing commercial health plans. It does not directly mandate Medicaid reimbursement for intern services. Maryland Medicaid has its own rules governing who can bill, and until BHA or MDH issues guidance specifically addressing intern billing under Medicaid, practices should not assume Medicaid will reimburse intern services in the same way.

The supervisor bills -- not the intern. This is not a pathway for interns to enroll as independent providers. The claim is submitted under the supervising clinician. The supervision relationship is the linchpin; without a properly qualified, board-approved supervisor, there is no reimbursement pathway.

Not every licensed clinician is an approved supervisor. Maryland's licensing boards have specific requirements for who qualifies as an approved supervisor for each licensure track. An LCPC supervisor for an LGPC candidate, an LCSW-C supervisor for an LMSW candidate -- the specific credential combinations matter. Before billing for intern services, confirm that your supervisors meet the relevant board's supervisor qualification requirements for the intern's specific licensure track.

Direct supervision is the standard. The law specifies direct supervision, not general oversight. Review your supervision model against the board's definition of direct supervision for the relevant license type.

Preparing Before January 1

Review your supervision relationships now. For each intern you currently employ or are considering hiring, confirm: (1) the supervising clinician holds the appropriate license and board-approved supervisor status for that intern's licensure track, (2) the supervision arrangement meets the direct supervision standard, and (3) the supervision is documented in a way that supports a billing audit.

Clarify billing procedures with your billing team. The claim will go out under the supervising provider's NPI. Work out now how intern-provided services will be identified and documented in your billing workflow -- what goes on the claim, what documentation supports the claim, and how you will distinguish supervised intern services from the supervising clinician's own direct services.

Do not assume commercial payer compliance on day one. January 1, 2027 is the effective date -- but commercial insurers may not have updated their systems and policies by that date. Expect a transition period where you may need to educate specific payers on the new requirement, submit corrected claims, or work through denials that reflect outdated payer policies.

Watch for Medicaid guidance. If MDH or BHA issues guidance on intern billing under Medicaid, it could significantly expand the scope of this change. Monitor BHA communications and provider bulletins from Carelon for any updates.

Update your intern agreements and onboarding. If you expand your intern program in anticipation of January 2027, make sure your practicum agreements with graduate programs, your supervision agreements with individual interns, and your internal compliance documentation all reflect the billing implications of the new arrangement.

The Bigger Picture: Workforce Development as a Clinical Strategy

The graduate intern billing change fits into a broader shift in how Maryland is thinking about its behavioral health workforce crisis. With 34,000 unfilled positions and Medicaid reimbursement rates that make it difficult to offer competitive salaries, building the pipeline -- training the next generation of licensed clinicians in your practice -- is increasingly both a workforce strategy and a clinical mission.

OMHCs that invest in supervision infrastructure now -- qualified supervisors, structured training programs, documented supervision models -- will be better positioned to benefit from the January 2027 change and any future expansions of intern billing to Medicaid. The practices that wait until January 1 to think about this will be playing catch-up.