PAYMENT OF SUPERVISION BY LARTEY WELLNESS GROUP

Maryland Policy for Provisionally Licensed Clinicians (LGPC, LMSW, and Similarly Situated Licensees) Purpose, Applicability, and Governing Authority

This policy establishes the terms under which Lartey Wellness Group (“LWG”) provides financial support for required clinical supervision for provisionally licensed clinicians practicing in the State of Maryland, including Licensed Graduate Professional Counselors (LGPCs), Licensed Master Social Workers (LMSWs), and any other clinicians who are legally required to practice under supervision as a condition of licensure. This policy is intended to ensure compliance with Maryland law, protect clients, and clarify financial responsibility for supervision while supporting lawful and ethical clinical practice. The supervision framework applicable to counselors is governed by the professional supervision and ethics provisions of COMAR Title 10, Subtitle 58, including COMAR 10.58.03, while social work supervision requirements are governed by COMAR Title 10, Subtitle 42, including COMAR 10.42.08. This policy is to be interpreted consistently with those regulations and does not supersede any requirement imposed by the Maryland licensing boards.

Requirement of Written Supervision Contract and Scope of Practice

Maryland law requires that provisionally licensed clinicians practice only pursuant to a written supervision contract with a Board-approved supervisor, and prohibits independent clinical practice outside of that supervision relationship. Accordingly, prior to providing any clinical services through LWG, each provisionally licensed clinician must have a valid, written supervision agreement in place that complies with Maryland regulations and accurately reflects the clinician’s scope of practice, supervision frequency, and evaluative structure. LWG may request verification that such a supervision contract exists and may require confirmation that supervision remains active and compliant throughout the clinician’s engagement.

Supervisor Responsibilities, Oversight Duties, and Record Retention

Under Maryland regulations, supervisors bear defined responsibilities for clinical oversight, including ensuring that supervision focuses on substantive clinical material, monitoring ethical compliance, evaluating professional competence, and confirming that the supervisee practices within lawful scope. Maryland regulations require supervisors to maintain supervision records for a minimum of seven years, including documentation of dates, duration, and content of supervision sessions. While record retention obligations rest primarily with the supervisor as a matter of regulation, LWG reserves the right to request reasonable confirmation of supervision engagement for compliance, credentialing, payer, or risk-management purposes.

Supervisee Responsibilities and Documentation Obligations

Maryland regulations also impose independent obligations on supervisees, including compliance with the written supervision contract, maintenance of supervision documentation, and production of supervision records upon Board request. Consistent with those requirements, LWG requires provisionally licensed clinicians to maintain accurate supervision documentation and to cooperate with reasonable compliance requests from LWG that are necessary to confirm lawful practice, payer compliance, or regulatory readiness. Failure to maintain supervision documentation or comply with supervision obligations may result in corrective action.

Ethical and Client-Protection Obligations During Supervised Practice

Provisionally licensed clinicians must adhere to the ethical standards applicable to their discipline, including the professional conduct and counseling relationship obligations set forth in COMAR 10.58.03 for counselors and the corresponding ethical standards applicable to social workers. These obligations include practicing within competence, ensuring informed consent, safeguarding client welfare, and addressing clinical risks through appropriate supervision. LWG expects supervision to actively incorporate ethical review and risk management, and LWG may intervene where supervision deficiencies pose a risk to clients or to regulatory compliance.

Definition of Supervision Session

For purposes of this policy, a “supervision session” means a formal, scheduled clinical supervision meeting conducted by a Maryland-licensed, Board-approved supervisor that is intended to satisfy Maryland supervision requirements. A supervision session may be conducted individually or in a group format were permitted by regulation, must meet the minimum duration required by the applicable licensing board, and may occur in person or through approved telehealth modalities were permitted by Maryland law. Informal consultations, administrative check-ins, peer discussions, or ad hoc communications that do not meet regulatory supervision standards do not qualify as supervision sessions under this policy.

LWG Position on Payment of Supervision

LWG treats required supervision as an organizational support benefit designed to facilitate compliance with Maryland law and continuity of care. Payment of supervision by LWG does not transfer regulatory responsibility away from the clinician or supervisor, does not guarantee licensure outcomes, and does not alter any Board-imposed requirements. Supervision must remain compliant regardless of whether supervision costs are paid by LWG or directly by the clinician.

Eligibility Standard for Part-Time Clinicians

For part-time clinicians, eligibility for LWG-paid supervision is contingent upon maintaining an active and consistent clinical workload. LWG’s baseline expectation is that part-time clinicians complete an average of twenty client sessions per week, or the equivalent monthly volume, as reflected in completed and documented clinical encounters. Once a clinician completes up to forty client sessions during a given month, LWG will pay for a maximum of two supervision sessions for that month. This structure aligns supervision support with active clinical service delivery and standard supervision cadence.

Allocation of Supervision Costs When Productivity Threshold Is Not Met

If a part-time clinician does not meet the minimum productivity threshold for the applicable period, LWG may allocate supervision costs to the clinician by deducting the cost of supervision from compensation otherwise owed, to the extent permitted by the governing contract and applicable law. Any such deduction will be implemented only in a manner consistent with contractual terms and applicable wage-and-hour restrictions. In lieu of deduction, LWG may elect alternative compliance measures, including modification of scheduling, temporary suspension of clinical assignments, or requiring the clinician to independently fund supervision until minimum productivity is restored.

Additional Supervision Beyond LWG Coverage

Clinicians who elect to pursue supervision beyond the two monthly sessions covered by LWG, including to accelerate progress toward independent licensure or to meet personal professional development goals, are solely responsible for the cost of those additional supervision sessions and must remit payment directly to the supervisor. Nothing in this policy prohibits clinicians from contracting independently for additional supervision, provided such supervision complies with Maryland law and Board approval requirements.

Supervisor Qualification and Approval Verification

All supervision must be provided by a supervisor who holds the appropriate Maryland license and Board-approved supervisor status for the supervisee’s discipline. LWG may require reasonable verification of a supervisor’s licensure and approval status when supervision is funded by LWG or when such verification is necessary to confirm lawful practice.

Implementation, Enforcement, and Contractual Alignment

This policy is implemented in coordination with clinician employment or independent contractor agreements and is intended to be read in harmony with those agreements. Where this policy authorizes cost allocation, deduction, or modification of supervision coverage, such actions shall be enforceable only to the extent they are consistent with the applicable written agreement and Maryland law. LWG reserves the right to enforce this policy through compliance monitoring, corrective action, suspension of clinical services, or termination of engagement where supervision requirements are not met.

No Waiver, No Guarantee, and Policy Amendments

This policy does not waive any statutory or regulatory requirement, does not guarantee licensure outcomes, and does not limit the authority of Maryland licensing boards. LWG may amend this policy to reflect changes in COMAR, Board guidance, payer requirements, or operational needs, and the most current version of this policy shall control.

Conclusion and Compliance Statement

This policy is adopted to ensure that clinical supervision for provisionally licensed clinicians engaged by Lartey Wellness Group is administered in a manner that is consistent with Maryland law, applicable COMAR provisions, and professional standards of care. It reflects Lartey Wellness Group’s commitment to ethical practice, client safety, regulatory compliance, and operational clarity, while balancing organizational resources with clinician responsibility.

All provisionally licensed clinicians remain independently responsible for maintaining lawful supervision, complying with their applicable licensing board requirements, and practicing within their authorized scope at all times. Lartey Wellness Group’s provision of supervision support under this policy does not relieve clinicians or supervisors of their statutory, regulatory, or ethical obligations.

This policy shall be implemented and enforced in good faith, interpreted consistently with governing law, and applied in coordination with applicable employment or independent contractor agreements. Any questions regarding interpretation or application of this policy should be directed to Lartey Wellness Group’s compliance or administrative leadership.