The Supervision Arrangement That Will Not Survive Review
Maya Ruiz finished her PsyD in June and was hired by Riverbend Community Counseling, a clinic owned by an LCSW. Riverbend has no psychologist on staff, so the director contracted with Dr. Patel, a psychologist in solo practice 50 miles away, to 'supervise' Maya's postdoctoral hours for licensure for a $400 monthly fee that Maya pays personally. No written agreement exists. Dr. Patel and Maya meet by video for 90 minutes once a month; between meetings Dr. Patel reviews the spreadsheet of hours Maya emails him and signs it. In month 12 Maya submits 2,000 hours: 1,180 direct client service, 260 'administrative and team meetings,' 300 'case notes and report writing,' 200 'intake reports' (3 hours credited per intake), and 60 'professional development webinars.' The clinic bills Medicaid for Maya's services under Dr. Patel's NPI, although Dr. Patel has never spoken with any of Maya's clients or read a treatment plan.
1. Evaluate Maya's 2,000 hours and the structure of the supervision. Which hours are likely to survive a board review, and which features of the arrangement create risk?
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Sort the hours first, then the structure.
Direct client service: the 1,180 hours are the core of a legitimate log, assuming they are accurately recorded. Intakes at 3 hours each: an intake is the service time plus its documentation; crediting 3 hours per intake inflates the log and cannot be defended on audit. Administrative and team meetings: generally not supervised professional experience in the delivery of psychological services, so these usually do not count. Case notes and report writing: typically part of the service hour rather than a separate countable category. Professional development webinars: not clinical experience. A realistic starting figure is close to the 1,180 direct hours, and some of those may be disallowed if supervision was inadequate.
The structural problems are more serious than the arithmetic: no written supervision agreement defining the supervisor's authority, roles, and evaluation; monthly rather than regular, typically weekly, individual supervision; a supervisor who never observes a session, reviews a recording, or speaks with a client; a supervision fee paid by the supervisee; logs signed without verification; and billing under a supervisor's NPI for services he neither rendered nor meaningfully oversaw.
2. What must Dr. Patel do now, given that he has already signed twelve monthly logs?
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He should stop signing immediately and put everything in writing. Correct the record: send Maya and the clinic a dated letter identifying the logs he signed, stating that he did not verify the underlying services and cannot attest to their accuracy, and describing exactly what supervision he did provide. Do not 'fix' the past by backdating a supervision agreement or reconstructing notes; that is falsification and would put his own license at risk. Stop the billing under his NPI today. Billing for services he neither rendered nor supervised is a potential false claim, and the clinic, not he, must correct any claims already submitted. He should consult his malpractice carrier and a health-care attorney about self-disclosure obligations to the payer.
If he continues, it must be on a defensible footing: a written agreement among the clinic, the supervisee, and himself; a defined weekly individual supervision schedule; direct observation or recording review; authority over case assignment and discharge; availability between sessions; and his own contemporaneous supervision notes. If the clinic will not agree to those terms, he should decline and terminate the arrangement rather than continue signing.
3. What should Maya do to protect her licensure and her hours?
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Maya's exposure is real and time-sensitive. She should: (1) stop paying personally for supervision that does not meet the Rules and ask the clinic to fund compliant supervision with a psychologist who can genuinely oversee her cases; (2) request a written supervision agreement specifying frequency, format, the supervisor's authority, and evaluation procedures; (3) rebuild her log from source documents, including appointment records, progress notes, and billing data, keeping only hours she can substantiate and moving documentation time into the service hours it belongs to; (4) ask IDFPR in writing how to correct or withdraw previously submitted logs before her application is reviewed, because a self-corrected record is treated very differently from a record the Board discovers on its own; (5) expect that some or all of the first year may not count and plan financially and professionally for extended supervised practice.
She should also recognize that her name is on the application. 'My supervisor signed it' is not a defense when the hours were inflated, and she is the person who will be answering questions about them. If the clinic pressured her to inflate or to accept the arrangement, she should document that as well.