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Information on EAP Billing for LPC-As in South Carolina
**The SCCA cannot guarantee billing or reimbursement from EAPs or any insurance company. 
This page is meant for you to utilize as a resource for educational purposes and as a reference for discussing billing related issues with EAPs.**


Licensed Professional Counselor Associates (LPC-As) in South Carolina are provisionally licensed mental health providers trained to offer a range of therapeutic and counseling services. These professionals are equipped to diagnose, create treatment plans, maintain case notes, and conduct therapy sessions. However, their practice is conducted under the close supervision of a Licensed Professional Counselor Supervisor (LPC-S), who oversees their work and signs all documentation to ensure compliance with professional standards and ethical guidelines.

Role and Capabilities of LPC-As

LPC-As, although provisionally licensed, possess the requisite training and skills to provide high-quality mental health services. Their scope of practice includes:

  • Therapy and Counseling Services: LPC-As are trained to conduct individual, group, and family therapy sessions.

  • Diagnosis: They can diagnose mental health conditions based on comprehensive assessments.

  • Treatment Planning: LPC-As develop treatment plans tailored to the needs of their clients.

  • Case Notes: They maintain detailed case notes documenting the therapeutic process and client progress.


Role of LPC-S

The LPC-S plays a crucial role in the professional development and oversight of LPC-As. Key responsibilities include:

  • Supervision: Providing regular supervision sessions to guide and support LPC-As in their clinical work.

  • Documentation Oversight: Reviewing and signing all documentation, including treatment plans, case notes, and progress reports, to ensure accuracy and compliance.

  • Ethical and Professional Standards: Ensuring that LPC-As adhere to the American Counseling Association (ACA) Code of Ethics and the South Carolina state licensing board requirements.

  • See more information on Supervisory Billing below!


Client Protections

Clients receiving services from LPC-As are protected under several regulatory frameworks:

  • ACA Code of Ethics: LPC-As must adhere to the ACA Code of Ethics, ensuring they provide services with integrity, competence, and respect for client confidentiality and autonomy.

  • State Licensing Requirements: LPC-As operate under provisional licenses issued by the South Carolina Board of Examiners for Licensure of Professional Counselors, Marriage and Family Therapists, and Psycho-Educational Specialists, which mandates adherence to specific professional standards and continuous supervision.


Billing Practices for LPC-As

Billing for services provided by LPC-As follows a structured process under the supervision of an LPC-S:

  • Supervisory Relationship

    • The provisionally licensed provider works under the direct supervision of a fully licensed LPC-S. The supervisory relationship involves:

      • Clinical Oversight: Regular review and guidance on the clinical work performed by the LPC-A.

      • Documentation: Maintenance of supervision logs, progress notes, and other relevant documentation as required by licensing boards and regulatory bodies.

  • Billing Responsibility

    • Billing Under Supervisor’s Name: All services provided by the LPC-A are billed under the LPC-S's name and credentials. This practice signifies that the supervisor is responsible for the services rendered.

    • Insurance Paneling: The LPC-S is paneled with insurance companies and has the necessary credentials to submit claims for reimbursement. They handle all billing processes on behalf of the LPC-A.

  • Insurance Company Policies

    • It is essential for LPC-As and their supervisors to confirm in writing that the insurance companies they work with allow for supervisory billing, also known as Pass-Through Billing, incident-to billing, or other similar terms. This verification ensures that the billing practices comply with the insurance provider's policies.

  • Reimbursement and Compensation

    • Reimbursement Process: The LPC-S submits claims for services provided by the LPC-A to the insurance company or directly to the client, using their credentials. Reimbursement is received by the LPC-S.

    • Compensation Agreement: A compensation agreement between the LPC-S and the LPC-A outlines the payment structure. This agreement can include a set salary, a percentage of the reimbursement, or other mutually agreed-upon terms.



The provision of therapy and counseling services by LPC-As in South Carolina is conducted under a structured supervisory framework to ensure high standards of care and compliance with ethical and professional guidelines. By adhering to the ACA Code of Ethics and state licensing requirements, LPC-As can deliver effective mental health services while progressing toward full licensure. The billing practices under the supervision of an LPC-S facilitate the financial and administrative aspects of their practice, ensuring that clients receive the care they need with the appropriate oversight and accountability.

What is Supervisory Billing?


When a provisionally licensed mental health provider issues a bill under their supervisor's name, it indicates that the supervisor is taking responsibility for the services provided by the provisionally licensed provider. This billing arrangement is common during the early stages of a mental health professional's career when they are still acquiring their full licensure. It is important for providers to confirm in writing that the insurance companies they are billing allow supervisory billing, Pass-Through Billing, incident-to billing or any other name used by an insurance company that applies to this type of billing.


Here's a general explanation of how mental health billing works for a provisionally licensed provider when the bill is issued under the supervisor's name:


Supervisory Relationship: The provisionally licensed provider, often referred to as an associate, supervisee in social work, LMSW, practicum intern, etc., works under the direct supervision of a fully licensed and experienced mental health professional. The supervisor oversees the associate's clinical work, provides guidance, and ensures that they meet the required standards.


Billing Responsibility: The supervisor takes responsibility for billing and reimbursement on behalf of the provisionally licensed provider. This means that the services provided by the associate are billed under the supervisor's name and credentials.


Insurance Paneling: The supervisor, being a fully licensed provider, is paneled with insurance companies and has the necessary credentials to bill for services. They have established contracts with insurance providers and have the required billing processes in place.


Supervisory Relationship Documentation: The supervisor and the provisionally licensed provider maintain documentation related to the supervisory relationship, including progress notes, supervision logs, and any necessary forms required by the licensing board or regulatory body.


Reimbursement: When services are provided by the provisionally licensed provider, the supervisor submits the bill to the insurance company or the client directly, using their own credentials. Reimbursement for the services is then received by the supervisor.


Compensation Agreement: The supervisor and the provisionally licensed provider typically have a compensation agreement in place, which outlines how the associate will be compensated for their services. The compensation arrangement may involve a set salary, a percentage of the reimbursement received by the supervisor, or other mutually agreed-upon arrangements.


Thank you to the following for assisting in the development of this resource page:

Catreace Brown-Baker with Bakers Counseling Service LLC

The South Carolina Counseling Association

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