Medicare Coverage of Marriage and Family Therapists

MFTs in Medicare Bill is Now Federal Law

Medicare Webinars

The implementation of Medicare Part B Coverage of MFTs and Counselors will involve a comprehensive regulatory process throughout 2023. The Medicare Mental Health Workforce Coalition has hosted several webinars so far, which can be viewed below. Among other issues, these sessions cover the basics of the Medicare Program, key provisions of the specific legislation that included MFTs and Counselors in Medicare, and overviews of key implementation features such as provider enrollment, the Medicare Physician Fee Schedule, and related regulatory and administrative initiatives that will be conducted by the Centers for Medicare and Medicaid Services (CMS). 

Medicare 601 Video and Slides

Enrolling as a Medicare Provider

The process to enroll as Medicare provider can seem complicated, so we first encourage members to review the Medicare 301, 401, and 601 webinars and slides, which specifically focus on provider enrollment issues. We also encourage any MFTs planning to enroll as a Medicare provider to review the CMS Marriage and Family Therapists (MFT) and Mental Health Counselors (MHC) Provider Enrollment Frequently Asked Questions (FAQs) in its entirety.  

The provider enrollment page can be found here. This will bring you to the Medicare Provider Enrollment, Chain, and Ownership System (PECOS). 

You will also need to apply for a National Provider Identifier (NPI) via the National Plan & Provider Enumeration System (NPPES). This is required of all medical providers and suppliers before enrolling as a Medicare provider. 

FAQs about MFTs as Medicare Providers

In September, CMS released its initial FAQs regarding the enrollment of MFTs and MHCs. You can access these FAQs at this site. Below are a few of the most commonly asked questions pertaining to MFTs and MHCs serving as Medicare-eligible providers:

·       When can MFTs start providing services to clients as Medicare-eligible providers? - Under this new law, MFTs and MHCs would not be able to serve as Medicare-eligible providers and bill Medicare until January 1, 2024. This delay in implementing the new law is needed so that the federal government can make the necessary arrangements for MFTs and MHCs to serve as Medicare providers.

·       When can I enroll as a Medicare provider? – The omnibus legislation that includes language allowing MFTs and MHCs to serve as Medicare providers was signed into law in December 2022. It will take several months for the Centers for Medicare and Medicaid Services (CMS), the federal agency that administers the Medicare program, to draft the policies pertaining to MFTs and MHCs in Medicare and to begin the process of enrolling MFTs and MHCs. According to CMS, MFTs and MHCs can start to submit their enrollment applications around November 1, 2023 or later. AAMFT will keep members updated regarding when MFTs can enroll as Medicare providers.     

·       In what settings can MFTs see Medicare enrollees? – MFTs can enroll as a Medicare provider and offer services to enrollees in most practice settings, including private practice and most clinical settings. MFTs will also be able to serve as eligible providers in Medicare Advantage plans and provide services to Medicare enrollees in Federally Qualified Health Centers and Rural Health Clinics.

·       Which MFTs are eligible to enroll in Medicare? – Once enrollment opens, an MFT must be licensed by a State to practice independently in order to enroll as a Medicare provider. MFT associates, interns, and students are not eligible to enroll as Medicare-eligible providers. This eligibility standard is similar for other Medicare-eligible mental health professions, as well as for MHCs under the new law. To enroll in Medicare an MFT must possess a master’s or doctoral degree which qualifies for licensure as an MFT, have two years of clinical supervised experience in marriage and family therapy, and be licensed as an MFT by a State.

Next Steps

AAMFT is elated that MFTs have now been added to federal law as a Medicare-eligible profession, effective in January 2024. However, advocating for MFTs in Medicare is not over. In July 2023, CMS released the proposed regulations regarding the inclusion of MFTs and MHCs as Medicare providers. AAMFT provided feedback to CMS regarding these proposed rules. The final rules will likely be released around November 1, 2023. CMS will also be setting up the process for enrolling MFTs as Medicare providers later this year. Enrollment of MFTs and MHCs as Medicare providers is expected to start around November 1, 2023 or later. 

AAMFT has joined with its allies in the Medicare Mental Health Workforce Coalition to work with CMS this year to help ensure a smooth process for enrollment of MFTs as Medicare providers. AAMFT is planning to provide additional information to members on the Medicare program, how to enroll as a Medicare provider, and the policies MFTs will need to follow while treating Medicare enrollees.

Are you a member of AAMFT’s Family TEAM? The Family TEAM is AAMFT’s network of advocates who are interested in MFT advocacy and wiling to volunteer some time to advocate for important MFT goals. TEAM members will receive additional information on the progress of onboarding MFTs as Medicare providers throughout the year. Please click here to join the Family TEAM today!

Please contact us at FamilyTEAM@aamft.org if you have any questions.