Provider Notice issued 12/22/2025

Correction to submittal of Behavioral Health Encounter Claims for Sub-Clinical Behavioral Health Professional Services working under the supervision of a physician or advanced practice nurse in Federally Qualified Health Centers and Rural Health Clinics Effective January 1, 2024

This notice informs providers of corrections to billing guidance in the October 18, 2024 provider notice announcing coverage for behavioral health services provided by sub-clinical behavioral health professionals in accordance with Public Act 03-0102. 

Claims for services delivered by a sub-clinical behavioral health professional, regardless of the supervising clinician, are to be submitted as behavioral health encounters. In the October 18, 2024 notice, instructions were to submit behavioral health encounter claims (T1040) with no modifier to denote a supervising physician or nurse practitioner with a psychiatric specialty. This resulted in C31 (Procedure not on File for Date) claim rejections. A behavioral health encounter (T1040) claim is to always include one of the listed behavioral health (BH) modifiers below: 

• Modifier AJ = Licensed clinical social worker (LCSW)
• Modifier AH = Licensed clinical psychologist (LCP)
• Modifier HO = Licensed clinical professional counselor (LCPC) or licensed marriage and family therapist (LMFT)

To resolve the C31 claim rejection issue, clinics must use the T1040 behavioral health encounter code + the BH modifier that is specific to the rendering sub-clinical professional’s education. For example, when the supervising provider is a physician or APN, and the sub-clinical professional has met the educational requirements set forth for an LCPC, the claim must be submitted with T1040 and the modifier HO. Likewise, claims for services rendered by a sub-clinical professional who has met the educational requirements set forth for an LCSW must be submitted with T1040 and the modifier AJ. 

Reimbursement for services delivered by sub-clinical behavioral health professionals will continue to be at the clinic’s existing behavioral health encounter rate.

Please note, only sub-clinical behavioral health professionals, working under the supervision of a physician or APN, who were unable to previously submit a claim or received C31 claim rejections for behavioral health encounters (T1040) with no BH modifier are eligible for a timely filing override dating back to January 1, 2025 dates of service. An override request with the specified claims must be received within 180 days of the date of this notice. Please refer to the Timely Filing Override Submittal Instructions on the Non-Institutional Providers webpage for detailed instructions.

Questions regarding this notice may be directed to the Bureau of Professional and Ancillary Services at 877-782-5565, or the applicable MCO.

Laura Phelan, Administrator
Division of Medical Programs