New Details on Medicare Coverage of Marriage and Family Therapists and Mental Health Counselors in RHCs
Beginning January 1, 2024
Sarah Hohman, Director of Government Affairs
The CY 2024 Medicare Physician Fee Schedule (MPFS) Proposed Rule implements provisions from the Consolidated Appropriations Act of 2023 passed by Congress in December, including allowing RHCs to bill for Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) beginning January 1, 2024.
Consistent with the statute, CMS is proposing to add MFTs and MHCs as qualified RHC providers meaning that they can generate a Medicare encounter, reimbursable at the RHC’s All-Inclusive Rate (AIR). Further, MFTs and MHCs will be subject to the same policies and supervision requirements as a PA, NP, CNM, CP, and CSW.
The definitions of MFTs and MHCs, as well as what will be considered MFT/MHC services can be found below.
Marriage and Family Therapist
- An individual who:
- 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;
- Is licensed or certified as a MFT by the State in which such individual furnishes such services;
- After obtaining such degree has performed at least 2 years of clinical supervised experience in marriage and family therapy; and
- Meets such other requirements as specified by the Secretary.
Mental Health Counselor
- An individual who:
- 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;
- Is licensed or certified as a mental health counselor, clinical professional counselor, or professional counselor by the State in which the services are furnished;
- After obtaining such degree has performed at least 2 years of clinical supervised experience in mental health counseling; and
- Meets such other requirements as specified by the Secretary.
- 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”
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.
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.
The addition of MFTs and MHCs as billable providers in the RHC setting marks the first time a new provider type was added to the list of RHC practitioners in decades and NARHC acknowledges that there are likely ongoing questions as RHCs consider incorporating these providers into their behavioral health services.
Please contact Sarah Hohman, NARHC Director of Government Affairs at Sarah.Hohman@narhc.org with any questions or other feedback, and don’t forget to review NARHC’s August 30th webinar on these CMS proposed rules here.
CMS has provided FAQs regarding provider enrollment of MHCs and MFTs.
