09/03/2026
If you are a provider that accepts SelectHealth, or a person with SelectHealth, please reach out to your reps ASAP! They are making changes that will create significant bottlenecking in behavioral health treatment and continuity of care. It will also disproportionately negatively impact children and teens. This is what I sent:
Dear [SelectHealth Representative],
I am writing regarding the revision to SelectHealth Policy #03, “Incident to Qualified Healthcare Professional Services,” particularly its impact on associate clinicians and graduate-level trainees.
We support appropriate clinical oversight and share SelectHealth’s goal of safe, high-quality behavioral healthcare. However, we are concerned this policy creates barriers beyond Utah’s established licensure and supervision framework and may significantly reduce access to mental healthcare—particularly for children and adolescents.
Utah Licensure and DOPL Oversight
Utah already has a comprehensive regulatory framework governing mental health practice and supervision. Utah law specifically recognizes clinical supervision of Certified Social Workers (CSWs), Associate Marriage and Family Therapists (AMFTs), and Associate Clinical Mental Health Counselors (ACMHCs). Mental health therapy includes evaluation, diagnosis, treatment planning, and psychotherapy.
These are licensed professionals practicing within a scope established by Utah law and subject to DOPL requirements for supervision, training, ethics, and eventual independent licensure.
DOPL and the Behavioral Health Board are charged with establishing professional scope of practice, competency, and supervision standards. While SelectHealth may establish reimbursement and credentialing requirements, we are concerned when an insurance policy effectively creates a substantially narrower clinical practice model than Utah’s licensing framework permits.
If SelectHealth has determined that Utah’s supervision requirements are insufficient to protect members, we would appreciate understanding the clinical basis for that determination.
Commercial Insurance and “Incident To”
We are also concerned about applying a Medicare “incident to” framework to commercial behavioral health contracts. “Incident to” originates within Medicare Part B reimbursement and does not necessarily govern commercial arrangements in the same manner. CMS has also modernized behavioral health policies to allow broader use of general supervision for certain behavioral health services.
We request clarification regarding the regulatory or clinical basis for applying these restrictions to SelectHealth commercial behavioral health services.
Impact on Children and Adolescents
Our greatest concern is access to care.
Utah already has a significant shortage of clinicians who treat children and adolescents. Families seeking therapy for children frequently encounter waiting lists of several months; six-month waits are not unusual. Many therapists do not treat minors at all.
Associate clinicians and supervised trainees substantially increase available appointments. Restricting this workforce does not reduce the number of children needing mental healthcare—it reduces the number of clinicians available to treat them.
This is particularly concerning given Utah’s youth mental health statistics. Su***de was the second-leading cause of death among Utah youth ages 10–17 in 2023. Utah’s 2023 Youth Risk Behavior Survey found that 22.9% of high school students seriously considered attempting su***de and 9% reported attempting su***de during the preceding year.
Children and adolescents also have less ability than adults to navigate limited access. They depend on parents, insurance networks, school schedules, transportation, and clinicians willing and qualified to treat minors. Policies that reduce provider capacity therefore disproportionately affect an already vulnerable population.
The Initial Evaluation Requirement Creates a Bottleneck
We are particularly concerned about requiring an independently licensed, SelectHealth-credentialed clinician to complete the initial evaluation and treatment plan before a supervised clinician can continue treatment.
A clinic may have an appropriately licensed ACMHC, AMFT, or CSW with immediate availability while its independently licensed clinicians are at capacity. Instead of beginning treatment, the patient must wait for an additional provider simply to enter care.
For a child or teenager in distress, this is not merely an administrative inconvenience; it is delayed access to mental healthcare.
Meaningful oversight does not require the supervisor to personally conduct every initial evaluation. At WORTH IT counseling + consulting, supervisors remain actively involved through consultation, review and approval of diagnoses and treatment plans, documentation review, co-signatures when applicable, risk consultation, and direct observation when appropriate.
Impact on Utah’s Behavioral Health Workforce
Graduate training and associate licensure exist because clinicians must obtain supervised clinical experience before independent practice. DOPL already regulates this progression.
If supervised services become financially unviable, agencies will have fewer opportunities to employ and train emerging clinicians. The long-term result is fewer clinicians progressing to independent licensure and an even smaller behavioral health workforce.
Request for Reconsideration
We respectfully ask SelectHealth to reconsider this policy and clarify:
1. The basis for applying Medicare “incident to” requirements to commercial behavioral health contracts;
2. Whether ACMHCs, AMFTs, and CSWs may conduct initial diagnostic evaluations within their Utah-authorized scope when appropriately supervised;
3. Whether a credentialed supervisor may review, approve, and/or co-sign an associate clinician’s assessment and treatment plan rather than personally conducting the evaluation;
4. How the policy applies differently to licensed associate clinicians versus graduate student interns; and
5. Whether SelectHealth has evaluated the impact on provider capacity, waitlists, children and adolescents, and Utah’s behavioral health workforce.
We would welcome the opportunity to discuss these concerns with SelectHealth leadership.
Our goals are aligned: members should receive timely, ethical, high-quality mental healthcare with meaningful clinical oversight. Our concern is that this policy may unintentionally reduce access to qualified clinicians—particularly for Utah’s children and adolescents, who can least afford additional barriers to treatment.
We sincerely hope SelectHealth will reconsider this policy before its November 1 implementation and collaborate with Utah behavioral health providers on an alternative that preserves both clinical accountability and access to care.
Thank you for your consideration.
Warmly,
Aimee Mortensen, CMHC, CST, CST-SIT
Founder & CEO
WORTH IT counseling + consulting