1. In the state of Arizona, someone in supervised private practice cannot bill under their supervisor's NPI. This is because the practice owner/supervisee would be required to use their own tax ID for billing. Since they are associates, they can't use their tax ID to credential with insurance payers

2. A potential workaround is for the supervisor to come on as an employee of the supervised private practice, which the board doesn't allow associates to do and would likely represent a conflict of interest in the supervisory relationship.

3. Additionally, a supervised practitioner cannot bill under their supervisor’s insurance contracts unless they represent a direct financial expense to the supervising provider or their group. This requirement means that the practitioner must be classified as a W-2 employee, a leased employee, or an independent contractor. Consequently, they would need to work directly for the supervisor, effectively ceasing to operate their own independent practice.

Referring clients from your private practice to another practice where you work

1. Referring a client from your private practice to another practice where you work, specifically because the latter can accept insurance, appears to be a conflict of interest (A.5.a) under the American Counseling Association (ACA) Code of Ethics, especially if it financially benefits you directly. The ACA Code of Ethics requires counselors to avoid actions that seek to meet their personal needs at the expense of clients. It is imperative to ensure that the referral is in the best interest of the client and not primarily for personal gain.