To help states address SUD workforce challenges and identify cutting-edge solutions, NASHP conducted a comprehensive review of how each state Medicaid program was paying for and overseeing non-licensed SUD staff.
Background
NASHP analyzed publicly available materials to identify:
- How Medicaid agencies reimburse for SUD services provided by non-licensed, non-master’s-level workforce;
- What services they provide and in what settings; and
- State education, training, and supervision requirements for non-licensed staff.
NASHP used the most recently available Medicaid provider and billing manuals, state regulations, and other public policy documents (including state plans and waivers) for all 50 states and Washington, DC. Findings were grouped and coded to allow for easier cross-state analysis. The data collected was shared with Medicaid and other state leaders.
States’ non-licensed workforce was categorized as:
Peers: Individuals with lived experience providing Medicaid-billable SUD services.
Counselors: Individuals providing Medicaid-billable SUD counseling or therapy services without a state license.
Other Qualified Staff: Other non-licensed professionals providing Medicaid-billable SUD services who did not meet the definition of a “peer” or “counselor.”
Services funded by resources other than Medicaid (e.g., state grant funding) were considered outside the scope of this research.
The majority of state Medicaid agencies (42) reimburse for SUD treatment services provided by non-licensed, non-master’s-level SUD staff. NASHP’s scan identified 45 types of peers in 39 states, 52 types of counselors in 31 states, and 43 types of other qualified staff in 24 states. The services these staff may provide, where they provide the service and how they are reimbursed, as well as education, training, and supervision requirements all varied to some degree across states. Key findings are summarized below.
Service Delivery
State Medicaid programs pay for a range of services and supports delivered by non-licensed staff. These services were grouped in the following categories:
- Peer services;
- Screening, assessment, and evaluation;
- Brief intervention;
- Community and rehabilitative supports (e.g., education, skills training, and family support);
- Case management/care coordination; and
- Crisis intervention.
States reimburse counselors for a broad range of SUD services. In addition to counseling/therapy services, more than half of non-licensed counselors can be reimbursed by state Medicaid programs for screening, evaluation, assessment, community and rehabilitative support, case management/care coordination, and/or crisis intervention services. Most state Medicaid agencies pay peers to provide peer support services-only, although approximately one-quarter of peers may also be reimbursed to provide rehabilitative or supportive services. Other qualified staff generally fell into one of two groupings: individuals primarily providing case management or care coordination services or unlicensed staff providing rehabilitative or supportive services who did not meet state qualifications to provide counseling services.
States vary in the types of counseling/therapy services that may be provided by non-master’s-level counselors. For example, every state permits their non-master’s-level counselors to provide individual and/or group counseling services, but only two-thirds of states reimburse certified counselors for family counseling services. Florida only reimburses its bachelor’s-level counselors for group services, limiting reimbursement for individual and family services to those with a master’s degree.
Setting and Reimbursement
Non-licensed staff deliver services in licensed behavioral health agencies or facilities, typically working within a multidisciplinary care team. Although employed by licensed agencies or facilities, services may often be provided in home and/or community settings to meet the needs of individuals receiving treatment.
How services delivered by this workforce can vary, depending on whether services are provided in outpatient or residential settings. State Medicaid agencies commonly pay licensed behavioral health clinics for services delivered by non-licensed staff on a fee-for-service basis, through Current Procedural Technology or Healthcare Common Procedure Coding System codes that may include modifiers to designate provider type. In contrast, services delivered by non-licensed staff in intensive outpatient programs (including day treatment and partial hospitalization) or residential treatment programs tend to be reimbursed as part of a bundled, per-diem rate. States may also include these types of staff in bundled rates for specialty opioid treatment programs. For example, Maine, Michigan, and Rhode Island all include peers in their opioid health home programs.
Education, Training, and Supervision
Training for peers tends to be more individualized and state-specific. Most states require peers to complete an in-person training program (typically one to two weeks), often offered through a state health agency. Counselors, on the other hand, may receive training though approved courses offered by community colleges or other professional development programs. States generally rely on national exams for counselors but were more likely to use state-developed training and exams for peers. Whether the state’s board membership was with the National Association for Alcoholism and Drug Abuse Counselors (NAADAC) or the International Certification & Reciprocity Consortium (IC&RC) determined which national exam the state required for certification. Some states, particularly those with multiple credentialing boards, allow either exam.
Most states require that non-licensed, non-master’s-level SUD treatment staff be supervised by certified or licensed SUD providers, who often held a master’s degree. In many cases, state regulations identify multiple eligible providers who could supervise staff rather than requiring one specific provider type. For example, a bachelor’s-level counselor might be supervised by a psychiatrist, an advanced practice nurse with specialized addictions training, or a master’s-level counselor with supervisory training. It is also common for individuals, particularly for those without a counseling certification, to be supervised by a more experienced colleague holding a similar credential – for example, a peer with two years of experience would supervise another peer. States also routinely set minimum standards for the supervisory relationship, such as defining frequency of meetings and on-call availability. Positions requiring less training and experience typically required closer supervision. Clinical oversight requirements were generally less specific than supervisory requirements and sometimes vary by type of service. State Medicaid agencies generally require assessments and treatment plans to be signed/authorized by a physician, master’s-level provider, or nurse care manager.
Some state Medicaid programs offer and reimburse for trainee positions. Several states noted the importance of trainee programs in expanding their non-licensed staff capacity. Louisiana reimburses services provided by counselors-in-training, who are permitted to provide screening/evaluation/assessment services, counseling, and crisis intervention services under the supervision of a licensed mental health provider. Similarly, Washington State reimburses a chemical dependency professional trainee, who can provide screening/evaluation/assessment services, counseling, and case management/care coordination under the supervision of a certified individual who has completed some college.
Looking Forward
The number of state Medicaid agencies utilizing non-licensed, non-master’s-level SUD treatment staff is expected to increase in the coming years. Since 2015, the number of states using Section 1115 Medicaid Demonstration Waivers to augment or entirely transform their SUD treatment systems has grown significantly,[5] and many of these states now pay for services delivered by non-licensed staff.[4] The use of these and other relevant Medicaid authorities (e.g., the Medicaid rehabilitative services option or health home state plan option) to increase access to peers and other non-licensed SUD treatment professionals presents both opportunities and challenges for states.
- How to support best practices while recognizing state variability. Given the wide range of definitions and standards currently used by states, resources are needed for policymakers to better understand best practices, including where and how these non-licensed staff add the most value. While most non-licensed counselors need to pass a nationally recognized exam for certification, the roles permitted within diverse state Medicaid programs can be quite different. Similarly, training and examination requirements for peers and other qualified staff vary significantly from state to state. Sharing state resources on how non-licensed staff can support best clinical practices for SUD treatment and recovery may be helpful for future policy development.
- Ensuring cross-system collaboration to address co-occurring needs in integrated care Given the significant correlation between SUD diagnoses and co-occurring mental health and physical health conditions, appropriate training and use of non-licensed staff offers another opportunity for states to promote integrated care for high-cost, high-needs individuals. Moreover, as states increasingly look to health clinics and primary care providers to provide SUD and opioid use disorder (OUD) treatment, defining how these non-licensed staff can and should operate within those settings raises additional issues (and potential opportunities) for state policymakers to promote access to treatment and better integrate care.
- Supporting managed care: In states with managed care systems, important questions remain as to how plan-employed staff (particularly peer supports and care coordination/case management staff) can best work with their provider-level counterparts to efficiently and effectively meet the needs of individuals needing or receiving SUD treatment.
- How to integrate non-licensed staff in larger inpatient and residential facilities: Historically, the “Institutions for Mental Disease exclusion” has prevented states from paying for Medicaid services provided to adults ages 21 to 64 in behavioral health facilities with more than 16 beds. Recent federal guidance and programmatic changes have enabled state Medicaid agencies to pay for services for adults in these settings using Section 1115 waiver authority.[6] While models exist, how to incorporate non-licensed staff into these settings will likely be of significant interest for state policymakers going forward.
Conclusion
State Medicaid agencies are increasingly using non-licensed workforce – including counselors, peers, and other qualified staff – to meet the growing need for SUD treatment and recovery services by their Medicaid-enrolled populations. NASHP’s review of how states oversee and pay for these services highlights opportunities. Understanding key trends in oversight and payment for this staff will provide a baseline for states as they seek to leverage and expand this workforce. Additionally, the significant variability in how states use these staff, what services they provide, and the kinds of training, education, and supervision they receive speak to a larger need for additional resources for state policymakers to effectively utilize this valuable part of the SUD workforce.
Other Resources
State Medicaid agencies are increasingly leveraging non-licensed workforce, including peers, to meet the growing need for SUD treatment and recovery services by their Medicaid-enrolled populations. For an overview of cross-cutting themes and additional analyses of how states are paying for other non-licensed workforce, please refer to the following companion documents in this series: