Hiring and supervising associates and interns in Texas

The short answer

In Texas, an associate or intern can see clients only when three things are true before the first session:

1. They hold the right license or registration, verified on the board's lookup: an LPC Associate or LMFT Associate license or an LMSW from the Behavioral Health Executive Council (BHEC), or an LCDC counselor intern registration from HHSC.
2. A qualified supervisor is in place under a signed agreement: an LPC-S, LMFT-S or LCSW-S approved by BHEC, or for counselor interns, supervision that meets HHSC's rules in a facility registered as a clinical training institution.
3. You know, plan by plan, whether their services can be billed. Many insurance plans credential only independently licensed clinicians. Check each plan in writing before you put an associate on that plan's clients.

Who licenses whom

Supervisee	Regulator	Working toward	Supervisor
LPC Associate	BHEC (Texas State Board of Examiners of Professional Counselors)	LPC	LPC-S
LMFT Associate	BHEC (Texas State Board of Examiners of Marriage and Family Therapists)	LMFT	LMFT-S
LMSW (clinical experience)	BHEC (Texas State Board of Social Worker Examiners)	LCSW	LCSW-S
Counselor intern (LCDC-I)	HHSC	LCDC	A certified clinical supervisor (CCS), or at a clinical training institution its coordinator or the intern's supervising QCC

LPC Associates

From BHEC's supervision FAQs and 22 TAC 681.92, the LPC Associate experience rule, as of October 2026:

• Hours: 3,000 clock-hours of supervised experience, at least 1,500 of them direct client counseling. Only time actually spent counseling counts toward the 1,500.
• Time: the 3,000 hours can't be completed in less than 18 months.
• Supervision: at least 4 hours a month, individual (one or two associates) or group (three or more), with no more than half of all supervision hours in group.
• Supervisors: no more than two BHEC-approved LPC supervisors at a time.
• Who can supervise: an LPC-S. BHEC says applicants for LPC Supervisor need an unrestricted LPC license in good standing for at least five years and a 40-clock-hour supervision course (or a for-credit doctoral course in supervision).
• Conflicts: under 22 TAC 681.93, the supervisor can't be an employee of the associate or a close relative, and must avoid relationships that impair their judgment.
• Paperwork: the supervisor files the Supervised Experience Documentation (SED) form with the Council within 30 days after supervision ends or the hours are complete.
• Shared risk: an LPC-S can be disciplined for an associate's counseling violations they knew about, or should have known about given the supervisory relationship.

LMFT Associates

From 22 TAC 801.142, the LMFT Associate experience rule, and 801.143 on supervisors:

• Hours and time: at least two years of work experience including 3,000 hours of supervised clinical practice.
• Direct services: at least 1,500 hours of direct clinical services, no more than 750 of them by technology-assisted services as the supervisor approves, and at least 500 hours with couples or families.
• Supervision: at least 200 hours by an LMFT-S, at least 100 of them individual. Up to 100 graduate internship supervision hours can count toward the 200.
• Frequency: at least one hour of supervision every week the associate provides services, except for good cause. In person or by live video; by phone only if those aren't accessible.
• Who can supervise: an LMFT-S, which requires a Texas LMFT in good standing, at least 3,000 hours of independent practice over at least three years, and a supervision course (a 3-semester-hour graduate course, a 40-hour continuing education course, or AAMFT's Fundamentals of Supervision).

LMSWs working toward the LCSW

From BHEC's requirements for LMSWs seeking the LCSW:

• Hours and time: at least 3,000 hours of supervised professional clinical experience over at least 24 months.
• Supervision: at least 100 hours of supervisory sessions over the 3,000 hours, from a Texas LCSW-S. Supervision should happen in proportion to the hours actually worked; BHEC's own example is about one hour a week for someone working about 30 hours a week.
• Supervisors: current rules don't limit how many LCSW-S supervisors an LMSW may have at once.
• Paperwork: the clinical supervision plan goes in with the application, and each LCSW-S completes a separate clinical supervision verification form.

LCDC counselor interns

From HHSC's page on becoming an LCDC and 26 TAC chapters 562 and 564:

• Register first. HHSC must issue the counselor intern registration before the person practices or starts counting hours in Texas. The registration lasts five years, and the intern must finish every LCDC requirement, including the exam, in that time.
• Hours: 4,000 hours of supervised work experience, within the scope of chemical dependency counseling. Education (270 classroom hours) and a 300-hour supervised practicum are separate requirements unless a waiver applies; practicum hours don't count toward the 4,000.
• Your facility registers too. 26 TAC 564.601 requires a licensed facility with counselor interns to register with HHSC as a clinical training institution (CTI).
• Who supervises: under 26 TAC 562.21, a CTI appoints a single training coordinator who is a qualified credentialed counselor (QCC). Direct supervision comes from a certified clinical supervisor (CCS), or at a CTI from the coordinator or the intern's supervising QCC, and they take responsibility for the intern's actions within the scope of clinical training. HHSC's CCS application is Form 3237.
• Hours have to be earned. A supervisor can't approve hours if the intern hasn't substantially completed the assignments, and must use HHSC's current forms.
• Telehealth: in a 2024 rule adoption published in the Texas Register, HHSC declined to let counselor interns provide telehealth services before passing the licensing exam. Check the current rule before you schedule an intern on video.

In a licensed SUD program, counseling is provided by or under QCCs. An LPC Associate or LMFT Associate isn't a QCC as the definition reads today. Our guide to IOP staffing requirements in Texas covers who counts.

Side by side

License	Supervised hours	Minimum time	Supervision
LPC Associate	3,000 (1,500 direct)	18 months	4+ hours a month; group no more than half
LMFT Associate	3,000 (1,500 direct, 500 couples or families)	2 years	200 hours (100+ individual); weekly
LMSW to LCSW	3,000 clinical	24 months	100+ hours, in proportion to hours worked
Counselor intern	4,000	Within the 5-year registration	By a CCS or, at a CTI, the coordinator or supervising QCC

Documenting supervision

Boards, payers and HHSC surveyors all read supervision records, and a missing log can cost an associate months of hours. Put this in writing:

• A signed supervision agreement before the first client: the supervisor's license and designation, the supervisee's license and number, the board rule it's for, how often and in what format you'll meet, what supervision covers, who pays for it, and how either side ends it. Where the agreement and the board's rules differ, the rules control.
• A log for every session: date, length, individual or group, topics, cases reviewed by chart number or initials (never full names), and both signatures. Each keeps a copy.
• The board's own forms, filed on the board's deadline: BHEC's SED form for LPC Associates, the clinical supervision plan and verification forms for social workers, HHSC's current forms for counselor interns.
• Disclosure to clients that the clinician is under supervision and who the supervisor is, as the board requires. Put it in the consent to treatment.
• Expirations on a calendar: the supervisor's designation, the associate license, the intern registration's five-year term. If the supervisor's status lapses, the hours stop counting.
• The agreement, logs and registration in the credential file, which HHSC surveyors and accreditors pull. Our IOP staffing guide lists everything else that file needs.

Co-signing notes

Many practices and programs have a licensed clinician review and co-sign associates' and interns' notes and treatment plans. Some plans require it as a condition of paying; some policies require it for quality. Either way, co-signing only works if it's fast and visible: a note waiting a week for a signature is a note that can't be billed and a risk nobody reviewed.

In Cima EHR for group practices, notes by an LPC-A, LMFT-A, LCDC-I, intern, tech or peer specialist wait for a licensed clinician's co-sign, show up on the supervisor's Today list, and don't create a charge until they're co-signed. Whatever system you use, write the co-sign rule in your policy: who co-signs what, and by when.

Billing: the question to ask first

We write that supervision plan as part of the Group Practice Launch, and in it we decide, plan by plan, where each associate can work. A supervision plan that satisfies the board doesn't mean any insurance plan will pay for the associate's work. Each plan decides whom it credentials and under what rules, and they vary:

• Many commercial plans credential only independently licensed clinicians (LPC, LMFT, LCSW, psychologist and so on). An associate can't join those networks and can't bill them under their own name.
• Some plans allow supervised associates under conditions they set, such as billing under the supervisor or the group with a modifier, or an associate credentialing program. The terms differ plan by plan, so check each plan and get the answer in writing, from the provider manual or your contract.
• Never bill an associate's session as if the supervisor provided it unless the plan's written policy allows it. Billing a service under someone who didn't render it can be a false claim.
• Medicare enrolls LPCs and LMFTs (since January 1, 2024), LCSWs, psychologists, nurse practitioners and physicians, but not associates on their own. Medicare has its own "incident to" rules; have your biller check the current ones before relying on them.
• Texas Medicaid and its managed care plans set their own rules for which credentials may bill. Check TMHP and each plan's provider manual.
• Programs billing a daily rate under a facility contract should read the contract's staffing terms: some list which credentials count toward billable program hours.

Many groups solve this by putting associates on self-pay clients, EAP referrals and the plans that allow them, and moving them onto other panels the week they're fully licensed. Start that credentialing before the license arrives so the gap is short. Our credentialing service files each plan and follows up every two weeks.

A hiring checklist

1. Verify the associate license or intern registration on the BHEC or HHSC lookup; print it with the date.
2. Confirm the supervisor's designation is current, and that no conflict (employee of the associate, close relative) exists.
3. For counselor interns, confirm your facility's clinical training institution registration first.
4. Sign the supervision agreement and set the meeting schedule before the first client.
5. Decide plan by plan which clients the associate will see, and write it down for the front desk.
6. Run the background check, drug test (in a licensed SUD facility) and exclusion checks against the OIG exclusion list, and build the credential file.
7. Budget the supervisor's time. Supervision hours aren't billable, and someone has to cover them. For an LPC Associate that's at least 4 hours a month; for an LMFT Associate, an hour every week they see clients.
8. Set up co-signing in your EHR, and put the license and designation expirations on the calendar.

Opening a solo practice first and hiring later? Start with how to start a private practice in Texas, then move to the group launch when the first associate signs. In a licensed program, the program launch covers this inside the staffing plan, and the medical director guide covers the physician side.

Questions

Can an LPC Associate work in private practice in Texas?

An LPC Associate practices under the supervision of an LPC-S, wherever they work. A proposed amendment to 22 TAC 681.91 addresses associates operating a private practice under supervision; check the current rule with BHEC before setting one up.

Can the practice owner supervise their own associates?

The LPC rule bars a supervisor from being an employee of the associate or a close relative, and from relationships that impair objective judgment. Read 22 TAC 681.93 and your own board's rule for the full list, and ask BHEC if your arrangement is unusual.

How many associates can one supervisor take on?

For LPC Associates, individual supervision is with one or two associates and group is three or more. Check the current rule for any cap on total supervisees, and be honest about the time: four hours a month per LPC Associate adds up fast.

Can an associate's notes be billed under the supervisor's NPI?

Only if that plan's written policy allows it, under the conditions it sets. Otherwise, no. Check each plan.

Does supervision by video count?

For LMFT Associates, the rule allows live video, and phone only if in-person or video isn't accessible. For the other licenses, check the board's current rule. Counselor interns face a separate limit on providing telehealth before passing the exam.

Running a program? The IOP / PHP Program Launch covers the staffing plan and credential files, and a live supervision or documentation training for your team is $500 per session. Or book a free 30-minute call.

Sources

• BHEC supervision FAQs: bhec.texas.gov
• 22 TAC §681.91, §681.92 and §681.93 (LPC Associate license, experience and supervisor requirements): §681.91, §681.92, §681.93
• BHEC, applying to be a Texas LPC Supervisor: bhec.texas.gov
• 22 TAC §801.142 and §801.143 (LMFT Associate experience and supervisor requirements): §801.142, §801.143
• BHEC, requirements for LMSWs seeking an LCSW: bhec.texas.gov
• HHSC, becoming a licensed chemical dependency counselor: hhs.texas.gov; HHSC Form 3237, certified clinical supervisor application: hhs.texas.gov
• 26 TAC §562.21 and §562.22 (training and supervision of counselor interns): Cornell LII, Justia; 26 TAC §564.601 (clinical training institution registration): Justia
• Texas Register, February 16, 2024 (counselor interns and telehealth): UNT Portal to Texas History
• CMS, Medicare enrollment of marriage and family therapists and mental health counselors: cms.gov