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Does Your EHR Track Supervision Hours Toward Licensure?

By Steven Van ·

Oasys says it does not total licensure hours, and describes its five-state sign-off log, default billing block and modifier handling instead.

Oasys does not total supervision hours toward a licensing board, and the vendor says most EHRs don't either. In its post on supervision tracking, Oasys Health says that job belongs to a dedicated hours-ledger tool such as Time2Track or Tevera, which a practice should run alongside its EHR.

Oasys says the two functions get conflated. A supervisee may assume the EHR is counting hours, then find at renewal that nothing was, and have to reconstruct dates by hand. Oasys notes that session duration can be derived from start and end times and attendance is recorded per session, but nothing totals them into a figure a board would accept. The company adds that supervision came up in more than 10 of its last 100 conversations with practice owners.

Sign-off record

Oasys tracks supervisor approval as a status with five values: not required, pending review, approved, needs revision and resubmitted. Each supervisor action (viewed, approved, requested revisions, resubmitted) is written to an append-only review log. Nothing is overwritten, so the full back-and-forth on a note is kept for audit if a payer or board asks who reviewed it and when.

The "not required" state lets sign-off follow a supervisee's actual credential status. Oasys gives the example of provisionally licensed clinicians who are independently credentialed with some payers while still supervised under state licensure.

Billing gate and modifiers

  • Billing on unapproved supervised sessions is blocked by default. A practice can opt in to billing before approval.
  • The HO modifier is applied for associate-level supervision and HN for intern-level supervision, with HP also available. The modifier is tied to the supervision status on the session.
  • Incident-to billing identity is resolved per claim, which determines whose name and credentials appear in Box 24j and Box 33.

Multiple supervisors and group supervision

A supervisee can have more than one assigned supervisor, with exactly one marked primary per practice. Group supervision is recorded as its own structure, with date, start and end time, and a per-supervisee attended flag for each session.

The post closes with a checklist splitting the question into two jobs: the ledger tool owns hours toward licensure, while the EHR owns the sign-off record and billing gate. The source text provided ends partway through the list of properties to check.

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