Act 93 Update: Associate Licensure Continues to Take Shape

Implementation of Hawaii’s Act 93 continues to evolve as payers, licensing boards, and provider organizations work through the operational impacts of the new associate licensure pathways for post-graduate master’s-level behavioral health professionals.

Several Hawaii health plans have begun outlining their anticipated approaches.

HMSA

HMSA has begun developing a framework for credentialing associate-level providers. Additional guidance is expected as implementation progresses.

UHA

UHA has also indicated that it is actively working on its credentialing process for associate providers.

HMAA

HMAA has stated that it does not anticipate treating associate-level providers differently than independently licensed master’s-level clinicians for contracting or reimbursement purposes. At this time, HMAA expects a similar billing structure and reimbursement methodology.

UnitedHealthcare / Optum

UnitedHealthcare and Optum have indicated that associate providers will likely credential as supervised providers. Since both organizations already credential Licensed Social Workers (LSWs), we anticipate the associate credentialing process may resemble the existing supervised provider framework, although formal guidance has not yet been released.

Many Questions Still Remain

While progress is being made, many questions remain regarding both licensing and billing.

There are still inconsistencies between the language contained within Act 93 itself and interpretations being discussed by various licensing boards. In particular, the absence of a clear associate pathway for Licensed Clinical Social Workers (LCSWs) has created uncertainty.

One possible explanation is the longstanding existence of the Licensed Social Worker (LSW) credential in Hawaii. Because the LSW has traditionally functioned as a permanent license rather than a temporary associate credential, regulators may be viewing social work differently than the other master’s-level professions. However, until additional guidance is released, this remains only an interpretation.

Access Revenue Hawaii continues to closely monitor developments involving credentialing, billing, supervision requirements, and payer implementation. As more definitive information becomes available, we’ll continue sharing updates with our clients and the behavioral health community.