Understanding Medicare's Inclusion of MFTs and MHCs: An Informative Guide for Therapists

By TherapyNotes, LLC on December 8, 2023

The Centers for Medicare & Medicaid Services (CMS) expanded its coverage to include Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) in September 2023. The inclusion of MFTs and MHCs by Medicare is a pivotal moment in mental health care and goes into effect January 1, 2024. This development brings both opportunities and responsibilities for practitioners in these fields and demonstrates the growing recognition of diverse mental health professionals in providing quality care.

MFTs and MHCs can begin submitting their enrollment applications as of November 2023. However, the benefits authorized by Section 4121(a) of Division FF of the Consolidated Appropriations Act, 2023, will not be in effect until January 1, 2024. Therefore, MFTs and MHCs will not be given an effective date before January 1, 2024, and any claims for services provided before this date will not be eligible for payment.

Clarifying the Roles of MFTs and MHCs

In the context of the recent Medicare changes, it's essential to understand the specific roles and qualifications of MFTs and MHCs.  Medicare's criteria for MFTs and MHCs emphasize stringent educational and professional standards. Section 4121 Division FF of the CAA, 2023, outlines the definitions and criteria for Medicare coverage of MFT (Marriage and Family Therapist) and MHC (Mental Health Counselor) services.

For MFT services, an individual must possess a master’s or doctorate degree, be licensed or certified in the state where services are provided, have at least 2 years of supervised clinical experience, and meet other requirements determined by the Secretary of Health and Human Services. Similarly, licensed or certified MHC, clinical professional counselor (LPCC), and professional counselor (LPC) services are defined with the same educational and experience criteria, subject to state law, and additional requirements determined by the Secretary of HHS. 

Both these roles require extensive supervised clinical experience before they are eligible to practice to ensure that MFTs and MHCs are well-equipped to provide high-quality mental health care.

The Enrollment Procedure

To enroll in Medicare, MFTs and MHCs can use the online Provider Enrollment, Chain, and Ownership System (PECOS) or the paper CMS-855I application. PECOS offers a scenario-driven application for faster enrollment, and CMS-855I is completed by physicians and non-physician practitioners providing Medicare Part B services.

  • Accessing PECOS To access PECOS, users must create an account in the Identity & Access Management System (I&A). This system allows users to apply for and manage National Provider Identifiers (NPIs) through NPPES, enroll in Medicare, and update or revalidate current enrollment information in PECOS.
  • Identifying MFT and MHC Specialties on CMS-855I On the paper CMS-855I application, which does not currently list MFT (Marriage and Family Therapist) and MHC (Mental Health Counselor) specialties, these professionals should select the 'Undefined Non-Physician Practitioner Specialty' option in section 2H and specify their specialty (MFT or MHC) in the provided space. A future update to include these specialties in the CMS-855I is planned.

Typically, online applications without issues will undergo processing within 15 calendar days from the date of receipt, while paper applications without complications will be processed within 30 calendar days. However, these timeframes may vary if the application is incomplete or lacks necessary information or documentation.

Upon identifying such issues, the Medicare Administrative Contractor (MAC) will issue a development letter to the provider, seeking the required additional information. The provider is allotted a period of 30 calendar days to respond. Failure to respond within this timeframe will result in the rejection of the application. It is crucial for providers to promptly address all requests for additional information from the MAC to prevent any further delays.

Other Key Takeaways

  • MFTs and MHCs undergo verification of licensure and a wide range of database checks to ensure compliance.
  • If a practitioner renders services in multiple states, a separate application is required for each state.
  • A provider can be enrolled as an individual practitioner and as an owner of a group.
  • If the group practice already has a Provider Transaction Access Number (PTAN), the group does not have to enroll again to include any MFT/MHC. The individual practitioner must complete enrollment and receive a PTAN prior to being linked to the group.
  • Providers enrolling or updating their enrollment must receive payments via EFT, except when reassigning all Medicare benefits.
  • Providers are periodically required to revalidate their Medicare enrollment. Alternatively, there's an option to opt-out of Medicare and enter private contracts with Medicare beneficiaries.

Centers for Medicare & Medicaid Services/Center for Program Integrity. (2023). Marriage and Family Therapists (MFT) and Mental Health Counselors (MHC) Provider Enrollment Frequently Asked Questions (FAQs). https://www.cms.gov/files/document/marriage-and-family-therapists-and-mental-health-counselors-faq-09052023.pdf

Centers for Medicare & Medicaid (CMS), Health and Human Services (HHS). (2023). CY 2024 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies  https://www.federalregister.gov/documents/2023/11/16/2023-24184/medicare-and-medicaid-programs-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other

* The content of this post is intended to serve as general advice and information. It is not to be taken as legal advice and may not account for all rules and regulations in every jurisdiction. For legal advice, please contact an attorney.


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