09/14/2025
FYI this was recentky shared by MI-NASW and think its important to share it here:
LLMSW Scope of Practice: Dos & Don’ts
In 2015, a NASW-Michigan blog posed the question of whether LLMSWs can bill for services. This question continues to come up each year since along with many other variations of questions related to what is within the scope of practice for an LLMSW, so here are our dos and don’ts for LLMSWs.
Bill insurance for services.
DON’T (or at least not directly).
Individually, LLMSWs (limited licensed master social workers) cannot bill for psychotherapy services as they have not completed the licensure requirements.
However, Medicaid and many private insurance companies will allow LLMSWs to bill for services under a fully licensed clinical social worker who the insurance company has paneled. So many agencies hire LLMSWs in therapist roles, credential them this way, and then bill under the LMSWs on-site. While this is often a licensure supervisor, it does not have to be - so as an LLMSW, you can still receive licensure supervision from an LMSW off-site, while an LMSW at your agency is covering you for billing purposes.
Take cash for services.
DO - Under supervision from a social worker who is licensed as an LMSW-Clinical.
While there may be technically less oversight when clients are paying out of pocket and not using insurance for services, it is important to remember to abide by the NASW Code of Ethics as well as Michigan’s Public Health Code - both of which do not support LLMSWs providing psychotherapy unsupervised. It is not ethical for an LLMSW to promote themselves as being a fully licensed social worker who bills for cash (or insurance), so we always recommend that this be done only under an employer and under a LMSW, just like if you were billing insurance. The standard of care and competence should be the same for cash clients as it is for insurance clients.
That is all to say - as an LLMSW, you should not be providing therapy as a solo practitioner but should be working for an agency until you are fully licensed with your clinical master’s social work license.
Open a private practice.
DON’T. (See above statement)
While many of these questions have gray areas or workarounds, this one is quite clear - ethically as well as according to Michigan’s Public Health Code: you are not qualified to open and run a Private Practice until you are fully licensed with your full LMSW-clinical license in the state of Michigan.
The NASW Code of Ethics states that social workers should only practice within area(s) of competence and their scope of practice. “Social workers should provide services and represent themselves as competent only within the boundaries of their education, training, license, certification, consultation received, supervised experience, or other relevant professional experience. (b) Social workers should provide services in substantive areas or use intervention techniques or approaches that are new to them only after engaging in appropriate study, training, consultation, and supervision from people who are competent in those interventions or techniques (1.04)”. Limited licensed social workers should be aware of potential liability and ethical concerns if working in private practice without proper training or supervision.
Forget about any continuing education since it’s not a requirement for LLMSWs.
DON’T - there are two training requirements for LLMSWs
Human trafficking training - Must complete a human trafficking training. This is required before you apply for your LLMSW, so we recommend you do it as soon as possible once you’ve graduated and are preparing for your LLMSW
Implicit bias training - Must have completed at least 2 hours of implicit bias training within the five years before applying.
NASW-Michigan offers continuing education opportunities for these requirements if you are struggling to meet this requirement:
NASW-Michigan Chapter: Upcoming CE Opportunities
The many schools of social work in Michigan also offer these post-grad continuing education courses.
Continuing education requirements exist for fully licensed social workers. Once you’ve completed your requirements and received your full license, make sure to familiarize yourself with the ongoing continuing education requirements for LMSWs.
Take the ASWB exam after the completion of your supervision hours.
DO - at this time and for the foreseeable future.
While we are working diligently at NASW to create a more equitable pathway to licensure that does not require the ASWB exam, we do not have a target date for when these changes would take place. We anticipate that it will be at least 18 months after any bills are actually passed by both the House and the Senate, and then also signed into law by the Governor. Because of this, we recommend that you plan your LLMSW career and path according to the current requirements, which means preparing for the ASWB exam and taking it as soon as you finish your 4,000 hours of supervision. ASWB exam prep can be found here:
NASW-Michigan Chapter: Licensure Exam Preparation
Most schools of social work also have resources or courses available.
Familiarize Yourself with the Scope of Practice for your Desired Licensure and Review Experiences with a Supervisor
DO - this is the time to hone in on what you enjoy and where you may need more practice!
While it can feel cumbersome to have to work 4,000 hours under supervision before you are able to complete the ASWB test requirement and then go on to receive your full license status, this time serves a very important purpose. As a profession, we recommend and support lifelong learning and supervision, but often supervision can be hit or miss after you're fully licensed, depending on your work environment. Private Practice, in particular, tends to be an isolating experience for fully licensed social workers. Take full advantage of the time that you are in supervision and having the ear of an experienced mentor to help guide you through the first years of your career.
Below are some practice and policy resources for clinical social workers to help them develop and maintain an effective clinical practice. Information is listed under categories such as billing codes,
documentation, practice, reimbursement, and standards
NASW Code of Ethics
NASW Assurance (Liability Insurance)
Michigan Public Health Code
Where can I review the codes and rules for Michigan social workers?
Visit the webpages below, published by the Michigan Legislature and the Michigan Department of Licensing and Regulatory Affairs (LARA):
Michigan Legislature: Public Health Code, Social Work
Michigan Legislature: Continuing Education section, Social Work
LARA: Social Work - General Rules
LARA: Social Work FAQs (PDF)
Jordan Freeman, LMSW-Clinical (she/her)
Work Force Program Manager, Contract
741 N Cedar St, Suite 100. Lansing, MI 48906
Phone: (517) 487-1548
Website: www.nasw-michigan.org
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