Washington State Medicaid
Behavioral Health Provider Ghost Audit

Three-way analysis: 22,696 BH providers × Molina directory × WA DOH license verification

Data: CMS T-MSIS Provider Spending (2018–2024) • Molina WA Apple Health Directory (scraped April 2026) • WA DOH License Lookup • Generated: April 18, 2026

Molina Healthcare — BH Counseling Directory Audit (Three-Way)

22%

of Molina's listed BH Counseling providers are verifiably active for Medicaid

Only 149 of 679 directory listings show active Medicaid billing. 83 have both claims and a verified WA BH license. 66 have claims but their license couldn't be matched by name (likely name variants).

59%

are “phantom access” — licensed but won't see Medicaid patients

399 providers hold active WA BH licenses but have zero Medicaid claims — real practitioners who simply don't participate. The true ghost rate (no claims and no license) is 19% after improved name matching.

Three-Way Classification (Claims × License × Directory)

Status	Count	%	What it means
Verified Active (claims + license)	83	12.2%	Active Medicaid claims and active WA BH license — gold standard
Active claims, license not matched	66	9.7%	Billing Medicaid but license couldn't be linked (name variants, credential type)
Phantom access — licensed, no Medicaid	399	58.8%	Active WA license but zero Medicaid claims — real providers who won't see Medicaid patients
Lapsed (had claims, no active license)	29	4.3%	Once billed Medicaid, stopped, and license is no longer active
No claims, no license found	102	15.0%	Zero Medicaid claims and no active WA BH license — true ghosts

399

“phantom access” — licensed providers not billing Medicaid

19%

true ghost rate (no claims + no license)

78%

claims-only ghost rate (before license layer)

679

total directory listings analyzed

Why the three-way analysis matters: Claims-only analysis overstates the ghost rate (78%) by counting licensed, practicing providers who simply don't accept Medicaid. Adding WA DOH license data and improved name matching reveals the real picture: 59% of listed providers are what we call “phantom access” — real practitioners with active licenses who won't see Medicaid patients. The true ghost rate (no claims and no license) is 19%. The directory problem isn't dead providers — it's a network where 59% of listings direct Medicaid members to providers who will tell them “we don't take your insurance.”

Regulatory context: Under the July 2025 Medicaid Managed Care Access Final Rule, MCOs must verify provider directories and update within 30 days. States must conduct independent secret shopper surveys by July 2027. Whether a provider is a true ghost or simply doesn't accept Medicaid, the member experience is the same: they can't get care from that listing.

Parity Analysis — BH vs Primary Care at Molina

Under MHPAEA, if behavioral health network adequacy is measurably worse than medical/surgical, that may constitute a nonquantitative treatment limitation. We ran the same claims cross-reference against Molina's Primary Care directory (464 providers) to compare.

2.6x

Primary Care providers are 2.6x more likely to be actively billing Medicaid than BH Counseling providers

35pp

gap in active Medicaid billing rates between PC and BH directories

Side-by-Side Comparison

Metric	BH Counseling	Primary Care	Gap
Directory size	679 providers	404 providers
Verifiably active (Medicaid claims)	22%	57%	35 pp
No Medicaid claims	59%	25%	34 pp
Ghost/inactive (claims-only)	78%	43%	35 pp

Parity finding: A Medicaid member using Molina’s directory to find a therapist has a 22% chance of reaching a provider actively billing Medicaid. The same member looking for a primary care doctor has a 57% chance — 2.6x better odds. This measurable disparity between BH and medical/surgical network accessibility may constitute a nonquantitative treatment limitation under the Mental Health Parity and Addiction Equity Act (MHPAEA). Under the 2024 final rule, health plans must demonstrate that access limitations for BH services are no more restrictive than those for M/S services.

Statewide Analysis — All WA Medicaid BH Providers

52%

of all Washington Medicaid BH providers show no claims activity in 12+ months

Of 22,696 behavioral health providers who have ever billed Washington Medicaid, 11,891 have not submitted a BH claim since at least January 2023.

10,805

Active (billed in 2024)

2,688

Stale (last billed 2023)

2,537

Inactive (last billed 2022)

6,666

Ghost (no claims since 2021)

Activity by Provider Type

Provider Type	Total	Active	Inactive	Rate
Counselor	8,672	3,587	5,085	59%
Social Worker	1,461	534	927	63%
Registered Nurse (Psych)	1,377	630	747	54%
Student	1,307	819	488	37%
Other (207Q00000X)	1,062	635	427	40%
Psychiatry	785	446	339	43%
Other (175T00000X)	608	256	352	58%
Other (363LF0000X)	598	315	283	47%
Case Manager	518	189	329	64%
Other (208000000X)	472	297	175	37%
Other (122300000X)	464	284	180	39%
Other (363A00000X)	453	251	202	45%

Activity by City (Top 15)

City	Total	Active	Inactive	Rate
SEATTLE	3,192	1,422	1,770	56%
SPOKANE	2,292	1,125	1,167	51%
VANCOUVER	1,339	597	742	55%
EVERETT	1,060	509	551	52%
TACOMA	1,037	476	561	54%
YAKIMA	708	324	384	54%
BELLINGHAM	708	367	341	48%
OLYMPIA	677	291	386	57%
LONGVIEW	533	286	247	46%
BREMERTON	469	231	238	51%
WENATCHEE	435	235	200	46%
LAKEWOOD	400	160	240	60%
BELLEVUE	388	157	231	60%
KENNEWICK	359	157	202	56%
PUYALLUP	358	163	195	54%

WA Medicaid BH Billing Volume — 2024

Total behavioral health spending by service category for providers with BH taxonomy codes billing Washington Medicaid in 2024.

$579M

Total BH spending (2024)

5.3M

Total claims

1,795K

Unique beneficiaries served

Spending by Service Category

Category	Providers	Claims	Total Paid	Share
Case Management	501	459,763	$237,682,972	41%
SUD Treatment	154	1,876,868	$113,580,108	20%
Community BH Services	2,340	1,071,078	$86,195,785	15%
Psychotherapy & Evaluation	2,708	634,528	$53,953,301	9%
E&M (by BH providers)	1,859	441,094	$34,348,725	6%
Testing & Intervention	1,305	669,620	$31,458,721	5%
Other	47	67,348	$16,536,230	3%
Applied Behavior Analysis	33	33,220	$5,023,736	1%

Top 15 Procedure Codes by Spending

Code	Description	Providers	Claims	Total Paid
T1015	Clinic visit/encounter	475	445,606	$212,122,239
H0018	H0018	37	124,937	$67,599,749
90837	Psychotherapy, 60 min	1,403	446,936	$43,311,623
H0020	SUD services	103	1,629,937	$34,230,525
H0004	BH counseling & therapy	1,358	388,441	$29,861,718
96165	Health behavior (add-on)	647	328,558	$21,976,160
T1041	T1041	24	7,808	$21,821,000
H0043	Supported housing	96	187,592	$20,668,559
99214	E&M office visit (moderate)	962	186,728	$12,861,086
H0019	H0019	14	121,994	$11,749,833
G9149	G9149	37	43,203	$10,700,217
99213	E&M office visit (low)	632	130,805	$6,837,126
90834	Psychotherapy, 45 min	777	106,766	$6,778,942
96164	Health behavior intervention	652	329,856	$6,629,398
H2023	H2023	62	61,445	$6,369,306

Methodology

This audit combines three data sources to assess behavioral health provider directory accuracy in Washington State Medicaid. The three-way analysis (claims × directory × license) distinguishes true ghosts from licensed providers who don't participate in Medicaid.

Data Sources

CMS Medicaid Provider Spending (T-MSIS): Provider-level claims data released February 14, 2026. Covers January 2018 through December 2024. Aggregated by billing/servicing provider NPI, HCPCS procedure code, and month. Includes fee-for-service, managed care, and CHIP claims.
NPPES NPI Registry: February 2026 dissemination. Provider demographics, taxonomy codes, and practice addresses.
Molina Healthcare WA Apple Health Directory: Scraped April 18, 2026 via Molina Sapphire CareSelect provider search. Counseling category, 680 providers within 10 miles of Seattle.
WA Department of Health License Lookup: Active behavioral health credentials queried April 2026 via WA DOH Provider Credential Search. Matched to directory providers by name. License types include Licensed Mental Health Counselor (LMHC), Licensed Marriage and Family Therapist (LMFT), Licensed Independent Clinical Social Worker (LICSW), and related BH credentials.

BH Procedure Codes

Psychotherapy: 90791, 90792, 90832, 90834, 90837, 90839, 90840, 90846, 90847, 90853, 90863 • ABA: 97151-97158 • SUD/MAT: H0015, H0020, G2086-G2088 • BH Counseling: H0004-H0006, H0031-H0040 • Day Treatment: H2012, H2017, H2019 • Case Mgmt: T1017 • Psych Testing: 96130-96137

Known Limitations

License matching: WA DOH licenses are matched to directory providers by name. 83 providers with active claims could not be matched to a license (12.2%), likely due to name variants, maiden/married names, or credential type mismatches. These providers are likely active but not confirmed via the three-way match.
Medical billing: ~14% of providers listed as inactive may bill under E&M codes (99213/99214) rather than BH-specific codes. Psychiatrists commonly do this for medication management. These are false positives in BH-code-only analysis.
Group billing: 86.6% of WA BH claims bill through group NPIs. Individual providers billing exclusively through groups are captured via servicing NPI, but some may be missed if their individual NPI never appears in claims.
Data lag: Claims data is through December 2024. A provider who started billing in 2025 would appear as inactive.
Scope: Molina directory analysis covers BH Counseling category only (680 of an estimated 1,500+ total BH listings). Additional categories (Psychiatry, Psychology, Social Work, SUD, ABA, Mental Health Clinics) were not included in this initial analysis.
“Licensed, no claims” interpretation: The 59% of providers classified as “phantom access” have active WA BH licenses but no Medicaid claims. They are real practitioners. They may serve commercial/Medicare patients only, or may have recently obtained their license and not yet started billing. From a Medicaid member access perspective, the result is the same: these providers won't see them.

Next Steps

The three-way analysis (claims + directory + license) provides a more nuanced picture than claims alone. A complete audit would include:

Cross-reference of all 5 WA Apple Health MCO directories (Molina, UHC, Coordinated Care, CHPW, Wellpoint)
All BH subcategories (Psychiatry, Psychology, Social Work, SUD, ABA)
Improved license matching using NPI-to-license crosswalks to resolve the 12.2% unmatched active providers
Phone verification of the 102 true ghost providers (no claims, no license) to confirm status
Parity analysis comparing BH ghost rates against medical/surgical directory accuracy