Select Health Policy #3 and Utah’s Behavioral Health Workforce
What is happening?
Select Health has announced that it will begin enforcement of its “incident-to” billing policy on November 1, 2026. The clarification has significant implications for Utah’s behavioral health training and service-delivery system. Read Select Health's Policy Update Notification HERE.
Under Select Health’s guidance:
- Graduate students/interns who are not yet provisionally licensed cannot provide reimbursable services under incident-to billing.
- Provisionally licensed clinicians may provide ongoing care, but a fully licensed and Select Health-credentialed provider must first conduct the initial evaluation and establish the treatment plan.
- The credentialed provider must also make official changes to the treatment plan throughout care.
- Existing patients being treated by provisionally licensed clinicians will generally be grandfathered when enforcement begins.
Read NASW Utah's Public Statement HERE & access our Sample Message to Select Health HERE
Why are we concerned?
This is bigger than a billing issue. It could affect access to care, clinical training, and Utah’s behavioral health workforce pipeline.
Access to care: A practice may have licensed associate clinicians with immediate openings, but new Select Health patients cannot begin care with them until a credentialed fully licensed provider completes the initial evaluation. When those providers are already at capacity, this creates another potential bottleneck between patients and available care.
Clinical training: Utah licenses associate therapists to practice mental health therapy under supervision. Assessment, diagnosis, case conceptualization, and treatment planning are core skills clinicians need to develop during this supervised period. Select Health’s policy restricts associate clinicians from performing some of these functions for reimbursable care rather than allowing them to perform the work with appropriate supervisory oversight.
Student internships: Prohibiting reimbursement for services provided by graduate interns may make clinical placements less financially sustainable for community agencies and practices. This could reduce the number or quality of training opportunities available to Utah students.
What are we asking for?
We are not advocating for the elimination of supervision or appropriate payer safeguards.
We are asking Select Health to reconsider how Policy #3 is applied to behavioral health and work with Utah providers, educators, professional associations, and other stakeholders on an approach that:
- maintains appropriate clinical supervision and accountability;
- recognizes the state-authorized scope of provisionally licensed professionals;
- supports sustainable student training opportunities; and
- avoids creating unnecessary barriers between Utahns and available mental health care.
How partners can help
We encourage organizations with a stake in behavioral health access, workforce development, higher education, clinical training, or healthcare policy to review the implications of Policy #3 within their own organization and consider elevating the concern through their leadership, policy committees, membership, and existing relationships with Select Health.
Partners may also consider requesting clarification or reconsideration directly from Select Health and joining broader conversations about how payer policies can support—rather than unintentionally restrict—Utah’s behavioral health workforce and access to care.
The central question is simple: If qualified professionals are available to provide care under appropriate supervision, are our policies making it easier or harder for Utahns to reach them?