I am not sure how I can bill for a CPST working under a PhD or can that be done without the Phd being in the same building as required in incident to? There is no difference from the perspective of her licensure. I know there are two community mental health agencies in town that work strictly with medicaid clients, have "case managers" (counselors and social workers without independent licenses), and use a model where one licensed person supervises the case managers but is not out in the field with them. That does not fit with the rules for services provided incident to in section 160 of the manual, although it is a CP who is supervising. I know a primary difference is that the case managers are providing clinical services, but are not providing psychology services. Can I legally bill under the supervising doctor with her numbers etc...even though she was not present?