A QUESTION EVERY MICHIGAN PRACTICE WITH A LIMITED-LICENSE HIRE OWNS RIGHT NOW · ANSWERED FROM THE PRIMARY RECORD

“My limited-licensed counselor can’t bill the way they used to. Can they work as a behavioral health care manager instead?”

VERDICT · CITED LLPC × BHCM × COLLABORATIVE CARE × MICHIGAN

Yes — the role is open to them. Whether those hours count toward full licensure is a separate question the Board has not answered.

In the Collaborative Care Model, the behavioral health care manager’s services are billed by the treating physician, NP, or PA — not by the care manager. Because the limited-license holder is not the billing provider, a limited-licensed counselor may hold the care-manager seat. That much is settled by how the model is built. What is not settled is whether time in that seat counts toward the supervised experience required for full LPC licensure — Michigan’s Board of Counseling has issued no guidance, and when asked directly in August 2026 it declined to interpret the rule. Treat the role as available today; treat the licensure credit as an open question until the Board speaks.

WHAT TO DO

✓ A limited-licensed counselor may take a care-manager role in a Collaborative Care program — the CoCM codes (99492–99494, G2214) and the general integration code 99484 are billed by the treating physician, NP, or PA

✓ Keep the care-management activities documented separately and distinctly from any behavioral-health counseling the same person provides

✓ Confirm the supervising LPC actually qualifies as a supervisor — either the completed supervision training (2 graduate credits or 30 contact hours across nine topics) or the CCE Approved Clinical Supervisor credential

✓ Do not promise a supervisee that care-manager hours will count toward full licensure — the Board has not confirmed that they do

✓ If those hours are decisive for someone’s licensure timeline, request a written determination from the Board of Counseling before relying on them

WHERE THE LAW STANDS

THE ROLE The federal description of Collaborative Care places the behavioral health care manager on the care team and has the treating physician bill the codes. Nothing in that model requires the care manager to hold independent licensure — which is why the limited-license billing restriction is not the gate. · CMS Behavioral Health Integration booklet, MLN909432

THE SUPERVISION A limited-licensed counselor practices under the ongoing supervision of a qualified licensed professional counselor. Michigan defines “under the supervision of a licensed professional counselor” by the supervisory relationship — who supervises, and that it is ongoing — not by the work setting. · R 338.1751(g)

THE SUPERVISOR The supervising LPC must have completed training in the function of counseling supervision — two graduate credits or thirty contact hours covering nine enumerated topics — or hold the Approved Clinical Supervisor credential from the CCE. · R 338.1781; MCL 333.18106

THE OPEN QUESTION Whether care-manager activities count toward the supervised experience required for full LPC licensure is unresolved. The Board of Counseling has published no guidance, and asked the question directly in August 2026, the department declined to interpret the rule — it may only point to the statute and rules. Until the Board speaks, the role is available; the licensure credit is not settled. · Michigan Board of Counseling, Aug 2026

✓ Reviewed and signed, Dr. Elizabeth M. Teklinski, PhD, LPC, NCC, NPT-C SIGNED 08 · 2026 · NEXT REVIEW SEP 5 2026

¹ CMS, Behavioral Health Integration Services (MLN909432) ↗ ² Mich. Admin. Code R 338.1751(g) ↗ (definition of “under the supervision of a licensed professional counselor”) ³ Mich. Admin. Code R 338.1781 ↗ (requirements to provide counseling supervision; ACS credential route at (1)(d)) ⁴ MCL 333.18106 ↗ (supervision of limited-licensed counselor; training required) ⁵ MCL 333.18109, 333.18111 (limited license; restricted practice under supervision)

Why this page is careful. Two questions hide inside one. The role is answerable from how the payment model is built, so we answer it plainly. The licensure credit is not answerable yet, because the body that decides it has not decided — so we say that, rather than guess in your favor. A page that told you the hours count would be doing you the opposite of a favor.

Rules change, and open questions close. This page is dated for a reason. The app tells you the moment it moves.

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