Congress should adequately fund Department of Defense
(DOD) behavioral healthcare, and should prod DOD to improve access to
mental health services provided by licensed Marriage and Family
Therapists (MFTs) at DOD facilities by eliminating specific bureaucratic
MFTs are licensed in every State
and D.C. to provide a full range of behavioral-health diagnostic and
treatment services. They hold a minimum of a Master’s degree and are the
only behavioral-health profession required to obtain training in
relational aspects of behavioral problems, such as how a Servicemember
family, fellow Servicemembers, and friends may affect that
Servicemember’s problems. A growing number of MFTs have training in
clinical areas of special interest to the military, such as
family-separation issues and Post Traumatic Stress Disorder.
2004, Congress enacted PL 108-375, Section 717, which clarified prior
law at 10 USC § 1091 (for DOD contractor staff) and § 1094 (for DOD
civilian employees), explicitly providing that the Department may hire
MFTs for clinical positions. MFTs serve in all Service Branches in
military hospitals and clinics (Military Treatment Facilities), Family
Advocacy programs, and the Chaplain Corps. MFTs in private practice are
eligible to be TRICARE providers.
It appears MFTs’ most frequent
military roles are as: 1) TRICARE providers, and 2) DOD contractor
healthcare staff. Historically, the Navy/Marines has been the Branch
using MFTs most widely, but in recent years, the Army has added about
150 MFTs as contractor hospital/clinic staff and also added a number as
Army Substance Abuse Program
(ASAP) civilian employees.
Because MFTs serve in a wide variety of military settings and job types, specific situations pose different challenges:
- TRICARE providers:
No known problems at this time. But provider payments under the TRICARE
Fee Schedule are tied to the Medicare Part B Physician Fee Schedule.
- Contractor healthcare staff:
As these positions generally are for short terms (e.g. 2 years),
promotional and "career" opportunities are rare. Also, there are reports
of MFTs whom contractors have hired away from existing jobs, only to
find that DOD has then cancelled or early-terminated its contractor
agreements, leaving these MFTs without jobs or apparent legal recourse.
- DOD civilian employees:
The key problem here is the lack of a Government-wide (or DOD- wide)
MFT-specific Job Classification system. Thus, MFTs are hired under one
of the following Job Series: 0101, Social Science (not elsewhere
classified); 0180, Psychology (generally as Counseling Psychologist), or
0185, Social Work. None of those Series fully describe the skills,
experience, or State Licensure status of MFTs, thus impeding MFT
hirings, promotions, and lateral transfers.
Only the Office
of Personnel Management (OPM) may promulgate a new Job Series, and only
upon petition of an Agency. In response to Congress’s 2006 enactment of
PL 109-461 establishing 38 USC § 7401(3) to permit the Department of
Veterans Affairs (VA) to hire MFTs, VA petitioned OPM for an
MFT-specific Series, but when that did not occur, VA established an
Agency-specific Series. Discussions between staffs of OPM and the
American Association for Marriage and Family Therapy (AAMFT) indicate
that OPM may establish an MFT-specific Job Series as part of its current
review of multiple behavioral-health Series, but that such action would
not occur until at least mid-2013.
In addition to this DOD-wide
job classification problem, AAMFT is aware of recent problems in the
Army Substance Abuse Program (ASAP). On 26 July 2011, Army Secretary
McHugh issued a memo regarding another behavioral-health profession,
Counseling, permitting ASAP to hire Counselors, but only if they hold
degrees from academic programs accredited by the Council for
Accreditation of Counseling and Related Educational Programs. It appears
this change, coupled with the functional transfer of ASAP from Army
MEDCOM to INCOM, has created uncertainty about the ASAP job criteria
applicable to MFTs. This has reportedly resulted in a freeze in MFT
hirings and promotions within ASAP, at a time when the rate of
substance-use disorders among Soldiers is growing.
Pending Sequestration of DOD Funding
2011 Budget Control Act (PL 112-25) provides that DOD may incur a
sequester budget cut.. As DOD naturally would subsequently minimize cuts
to Forward Operations, sequestration could well cause disproportionate
cuts in civilian and contractor healthcare staffing.
- Reach agreement to avoid any Budget Sequestration funding cuts.
- Urge DOD to either petition OPM for a Government-wide MFT Job Series, or establish an analogous DOD-specific Series.
TRICARE Fee Schedule pay-rate cuts (either as a result of fixing the
Medicare Fee Schedule, or by de-coupling TRICARE from that Schedule).
- Press DOD to expedite correction of the cited bureaucratic impediments to hiring MFTs as civilian and as contractor staff.
Contact Roger Smith
Director of Government and Corporate Affairs