According to the proposed rule expansion for Medicare coverage it will include Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) as well as the ability for Addiction Counselors to enroll as MHC’s.
The services furnished by an MFT and MHC will be covered when furnished in a rural health clinic (RHC) and federally qualified health center (FQHC).
Reimbursable at the All-Inclusive Rate (AIR) beginning January 1, 2024.
The definitions of MFTs and MHCs, as well as what will be considered MFT/MHC services can be found below. Additionally, MFTs and MHCs will be subject to the same policies and supervision requirements as a PA, NP, CNM, CP, and CSW.
Marriage and Family Therapist
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An individual who:
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Possesses a master’s or doctor’s degree which qualifies for licensure or certification as a MFT pursuant to State law of the State in which such individual furnishes marriage and family therapist services.
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Is licensed or certified as a MFT by the State in which such individual furnishes such services.
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After obtaining such degree has performed at least 2 years of clinical supervised experience in marriage and family therapy; and
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Meets such other requirements as specified by the Secretary.
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Mental Health Counselor
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An individual who:
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Possesses a master’s or doctor’s degree which qualifies for licensure or certification as a mental health counselor, clinical professional counselor, or professional counselor under State law of the State in which such individual furnishes MHC services.
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Is licensed or certified as a mental health counselor, clinical professional counselor, or professional counselor by the State in which the services are furnished.
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After obtaining such degree has performed at least 2 years of clinical supervised experience in mental health counseling; and
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Meets such other requirements as specified by the Secretary.
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CMS acknowledges that the “at least 2 years of clinical supervised experience” may not match the clinical supervised hours required for licensure in different states; therefore, they are proposing that MFTs/MHCs have at least 2 years OR 3,000 hours of post master’s degree supervised clinical experience.
CMS is also proposing to allow the following to enroll in Medicare as MHCs beginning January 1, 2024:
“Addiction counselors that meet all of the applicable requirements of clinical supervised experience in mental health counseling, and that are licensed or certified as MHCs, clinical professional counselors, or professional counselors by the State in which the services are furnished.”
https://public-inspection.federalregister.gov/2023-14624.pdf Addiction Counselor page 335 of 2033
MFT / MHC Services
“Services furnished by an MFT/MHC for the diagnosis and treatment of mental illnesses (other than services furnished to an inpatient of a hospital), which the MFT/MHC is legally authorized to perform under State law (or the State regulatory mechanism provided by State law) of the State in which such services are furnished, as would otherwise be covered if furnished by a physician or as an incident to a physician’s professional service.”
Marriage and Family Therapists and Mental Health Counselors will also be eligible to bill G0511 for general behavioral health integration services.
CMS acknowledges that individual states use varying terminology in licensure for MFTs and MHCs and are specifically seeking information as to what other types of professionals may also meet requirements to fall into the MHC category.
When can Marriage and Family Therapist and Mental Health Counselors start enrolling in Medicare?
Congress proposed to expand Medicare coverage to include Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs). These providers in the RHC setting will be able to generate a Medicare encounter, reimbursable at the RHC’s All-Inclusive Rate (AIR) beginning January 1, 2024.
Are you a Clinic/Facility or provider type MFT/MHC wondering when you can begin submitting provider enrollment applications?
The rule making process determines that to be after the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) final rule is displayed at the Federal Register, which is usually around November 1, 2023. Proposed Rule: https://public-inspection.federalregister.gov/2023-14624.pdf
Rulemaking Process:
July-Proposed Rules Released
September-Comments Due
November- Final Rules Released
January- Provisions go into effect.
MFTs and MHCs can enroll electronically using the Provider Enrollment, Chain, and Ownership System (PECOS) or the paper CMS-855I enrollment application.
However, as the new benefits do not take effect until January 1, 2024, MFTs/MHCs will not be granted an effective date earlier than January 1, 2024, and claims with dates of service prior to January 1, 2024, will not be payable.
Provider Enrollment Frequently Asked Questions (FAQs) https://www.cms.gov/files/document/marriage-and-family-therapists-and-mental-health-counselors-faq-09052023.pdf
