How Hawaiʻi’s new associate-level licensure pathways are working with payers, why TRICARE is taking a different position, and what TriWest’s corrected IOP guidance means for behavioral health facilities.
Behavioral health providers in Hawaiʻi are navigating several important changes at once.
Hawaiʻi’s Act 93 has created new opportunities for associate-level and provisionally licensed clinicians to enter the workforce and provide reimbursable services under supervision. At the same time, health plans are not necessarily implementing these new licensure categories in the same way.
Recent TRICARE West guidance adds another layer of complexity. TriWest has now made clear that provisional credentialing is not permitted for TRICARE network participation, while also correcting earlier guidance regarding the number of weekly clinical-programming hours required for Intensive Outpatient Programs.
For behavioral health practices and facilities, these developments demonstrate why licensure, payer credentialing, authorization, clinical programming, and reimbursement must be evaluated separately.
Hawaiʻi’s Act 93: What Changed?
Hawaiʻi’s Act 93 was enacted to help expand the state’s behavioral health workforce by establishing provisional or associate-level licensure pathways for certain behavioral health professionals, including marriage and family therapists, mental health counselors, and psychologists.
Applicable provisional licensure provisions took effect July 1, 2026.
The goal is relatively straightforward: allow qualified clinicians who have completed their educational requirements, but are still accumulating required supervised experience, to begin practicing sooner under appropriate supervision.
Act 93 also created reimbursement pathways for certain supervised behavioral health services when applicable payer requirements are satisfied.
Read the legislation
Hawaiʻi Act 93, Session Laws of Hawaiʻi 2024
How Is Act 93 Working in Practice?
From Access Revenue Hawaii’s early credentialing experience, implementation has been encouraging, but not entirely consistent across health plans.
We have successfully credentialed clinicians holding qualifying provisional or associate licenses with several Hawaiʻi health plans, including:
- HMSA
- UHA
- HMAA
This is an encouraging sign that Hawaiʻi’s new licensure pathways are beginning to translate into real-world payer participation.
However, the experience has not been uniform.
UnitedHealthcare and Optum Have Been Less Predictable
Our initial understanding from Optum was that appropriately licensed associate-level clinicians in Hawaiʻi could be credentialed for participation with applicable UnitedHealthcare commercial plans.
In several cases, the process moved well beyond an initial application:
Application → Credentialing → Contract Offered → Contract Signed → Contract Executed
More recently, however, Access Revenue Hawaii has begun receiving notices stating that certain clinicians:
“do not meet Optum’s licensure requirements for the State of Hawaiʻi.”
In some instances, these notices have arrived even after the contracting process had already advanced through execution.
That has resulted in appeals and additional follow-up.
At this time, we have not received enough formal clarification to determine whether this represents:
- a deliberate Optum credentialing policy,
- an implementation issue involving Hawaiʻi’s newly created license categories,
- or a credentialing-system configuration problem.
Our hope is that this ultimately proves to be an administrative or systems issue as national payer credentialing platforms are updated to recognize Hawaiʻi’s new licensure types.
Access Revenue Hawaii will continue monitoring these cases and updating Hawaiʻi’s behavioral health provider community as additional guidance becomes available.
ARH Takeaway: A license being legally recognized by the State of Hawaiʻi does not automatically mean every health plan will immediately recognize, credential, and reimburse that license category in the same way.
TRICARE West Takes a Different Position on Provisional Licensure
For providers hoping to use Hawaiʻi’s new provisional licensure pathways within the TRICARE West network, TriWest has provided a much clearer answer.
In its August 2026 Provider Pulse, TriWest Healthcare Alliance reminded network providers that:
Provisional credentialing is not permitted under the TRICARE contract.
According to TriWest, providers may not participate in the TRICARE West Region network based on:
- Provisional licensure
- Provisional certification
- Temporary credentialing approval
- Incomplete credentialing requirements
Providers must satisfy applicable TRICARE credentialing and certification requirements before they may participate as TRICARE network providers.
Read the TRICARE guidance
August 2026 TRICARE Provider Pulse
View the August 2026 Provider Pulse
TRICARE West Provider Handbook
Review Provider Information and Credentialing Requirements
What Does This Mean for Hawaiʻi Practices?
This is especially important for practices hiring newly licensed clinicians under Act 93.
A clinician may be:
- legally permitted to practice under Hawaiʻi law,
- eligible for credentialing with certain commercial health plans,
- and eligible to provide reimbursable supervised services,
while still not qualifying for TRICARE network participation.
Before allowing a newly hired clinician to treat TRICARE beneficiaries as an in-network participating provider, practices should verify that the clinician has:
- Met applicable TRICARE professional qualification requirements.
- Completed TriWest credentialing and certification.
- Met TRICARE’s applicable licensure requirements.
- Received final approval for participation in the network.
The critical distinction is:
State licensure eligibility and payer network eligibility are not the same thing.
Act 93 establishes a pathway under Hawaiʻi law. TRICARE remains governed by separate federal participation and credentialing standards.
TRICARE Also Corrected Its IOP Guidance
TRICARE issued another important clarification in August regarding Intensive Outpatient Programs, or IOPs.
Many behavioral health organizations traditionally think of IOP as:
3 hours per day × 3 days per week = 9 hours per week
That structure is common, but it is not necessarily an absolute TRICARE requirement.
TriWest acknowledged that a previous July Provider Pulse article incorrectly suggested that IOPs must include a minimum of nine hours of weekly clinical programming.
TRICARE’s official definition describes an IOP as a program that typically consists of:
6 to 9 or more hours per week
with a:
Minimum of 2 hours per treatment day
Review the governing TRICARE policy
TRICARE Policy Manual, Chapter 7, Section 3.15
Review TRICARE Intensive Outpatient Program Policy
Why the IOP Correction Matters
For behavioral health facilities treating TRICARE beneficiaries, this clarification may affect several operational areas:
- Initial authorization requests
- Weekly programming schedules
- Attendance requirements
- Concurrent reviews
- Continued-stay requests
- Clinical documentation
- Step-down planning
- Discharge decisions
For example:
2 hours per day × 3 treatment days = 6 hours per week
A structure like this may still fall within TRICARE’s stated IOP framework, provided the patient otherwise satisfies applicable clinical, medical-necessity, authorization, certification, and program requirements.
That distinction is important.
However, providers should not interpret the correction to mean that simply delivering six hours of treatment automatically guarantees IOP authorization or reimbursement.
It does not.
The patient must still meet the applicable medical-necessity requirements, and the program must continue satisfying the other requirements associated with the authorized level of care.
“IOP Always Means Nine Hours” Is Not a Safe Payer Strategy
This correction provides a useful lesson for behavioral health organizations more broadly.
Facilities should be cautious about applying statements such as:
“IOP always equals nine hours.”
Different payers may use different definitions, authorization standards, clinical criteria, and reimbursement rules.
The requirements of:
- TRICARE,
- ASAM,
- Medicare,
- Medicaid,
- HMSA,
- UnitedHealthcare,
- and other commercial carriers
should not automatically be treated as interchangeable.
For utilization review and billing teams, the safest approach is to use the actual payer policy applicable to the patient, benefit plan, and date of service.
The Bigger Revenue Cycle Lesson
These August updates highlight a larger issue facing behavioral health practices and treatment facilities:
Clinical standards, state licensing laws, credentialing rules, and reimbursement policies do not always change at the same time.
Hawaiʻi has opened a new pathway for associate-level behavioral health professionals through Act 93.
Some health plans are adapting quickly.
Others appear to still be working through implementation.
TRICARE has taken a clear position that provisional credentialing is not permitted for network participation.
At the same time, TRICARE’s IOP correction demonstrates that payer policies can sometimes be more flexible than conventional industry assumptions.
The challenge is knowing which requirement applies.
Access Revenue Hawaii Perspective
For behavioral health organizations, revenue cycle management is increasingly dependent on understanding how several interconnected requirements work together:
Licensure
↓
Credentialing
↓
Authorization
↓
Clinical Documentation
↓
Billing
↓
Reimbursement
When one component changes, the effect can travel through the entire revenue cycle.
A clinician may be appropriately licensed but not credentialed.
A provider may be credentialed but not yet loaded into the payer’s claims system.
A level of care may be clinically appropriate but inadequately supported in an authorization request.
A service may be authorized but billed incorrectly.
And a perfectly submitted claim may still fail if the credentialing or authorization foundation was incorrect.
That is why payer-specific knowledge matters.
Labor Day Office Closure
Access Revenue Hawaii’s offices will be closed on Monday, September 7, 2026, in observance of Labor Day.
Our billing operations will continue according to the normal billing schedule; however, our offices will remain closed for the holiday.
Please note that during the closure:
- Routine emails and phone calls will be addressed when our offices reopen.
- Non-urgent requests will be handled on the next business day.
- VOB access and VOB support will be unavailable during the office closure.
- Scheduled billing activity will continue as planned.
We encourage clients to submit any time-sensitive verification or VOB requests before the holiday whenever possible.
We appreciate your understanding and wish our clients, partners, and behavioral health community a safe and enjoyable Labor Day.
Staying Ahead of Changing Payer Requirements
Access Revenue Hawaii continues to monitor payer policy, credentialing, authorization, utilization review, and reimbursement changes affecting behavioral health providers throughout Hawaiʻi.
Our goal is not simply to report that a policy changed.
It is to help providers understand:
What changed?
Who does it affect?
What needs to change operationally?
And what can be done now to prevent denials, authorization problems, and reimbursement delays?
Need help navigating payer requirements?
Access Revenue Hawaii supports behavioral health practices and facilities with:
- Credentialing and contracting
- Insurance verification
- Prior authorization
- Utilization review
- CMS-1500 billing
- UB-04 billing
- Denial management and appeals
- Accounts receivable follow-up
- Revenue cycle management
- Clinical and payer-readiness education
Sources & Further Reading
Hawaiʻi Act 93
Hawaiʻi Act 93, Session Laws of Hawaiʻi 2024
TRICARE August 2026 Provider Pulse
August 2026 Provider Pulse
TRICARE Provider Credentialing
TRICARE West Provider Handbook: Provider Information
TRICARE Intensive Outpatient Programs
TRICARE Policy Manual, Chapter 7, Section 3.15