Committee signs supervised-billing Medicaid rule to clarify supervisee enrollment and remove five-year billing limit

The Legislative Committee on Administrative Rules on July 10 approved amendments to the Agency of Human Services’ health care administrative rule 9.103 governing supervised billing in Vermont Medicaid.

The rule clarifies eligibility for supervisors and supervisees, aligns terminology with the Office of Professional Regulation and removes a five-year billing limitation so supervisees can enroll in Vermont Medicaid while they complete licensure requirements. The agency said it will issue guidance and a manual ahead of a Jan. 1, 2026 effective date to help providers comply.

Ashley Berliner, director of Medicaid policy for the Agency of Human Services, told the committee the revised rule was developed with input from the Department of Health, the Office of Professional Regulation, Vermont Legal Aid, Blue Cross Blue Shield of Vermont, the Medicaid and Exchange Advisory Committee and hundreds of mental-health providers. "We will also hold multiple open forums to help providers enroll, and we'll be issuing comprehensive manual to supplement the rule and elaborate on the new provisions and requirements ahead of the 01/01/2026 effective date," she said.

Berliner said the changes are intended to reduce provider confusion and to align Medicaid billing policy with anticipated professional-licensing rules coming from the Office of Professional Regulation. Key changes include updates to terminology, removal of the five-year billing limit for supervisees so they can be enrolled while pursuing licensure, clarified eligibility criteria for supervisees and supervisors, and a clearer list of non-reimbursable services.

Committee members offered no additional questions; the committee voted to approve the rule package (identified in the meeting as rule 25 P 16) by voice vote. The Agency of Human Services said it does not expect the amendments to change who may practice or the services that may be provided, and that it expects no significant environmental or economic impacts from the technical and alignment changes.

The agency will implement the substantive clarifications through the rule and through supplemental guidance and provider forums ahead of the rule’s Jan. 1, 2026 effective date.