MFT’s are eligible to enroll in the Medicare program effective January 1, 2024. As MFT’s consider enrolling in the Medicare program, it is important to understand the enrollment standards required. This article summarizes the Medicare Program Integrity manual that Medicare Administrative Contractors (“MAC” or “contractor”) must follow when enrolling MFT providers.

The program manual can be seen in its entirety at https://www.cms.gov/files/document/r12356pi.pdf.

Marriage and Family Therapists (MFTs)

CMS recognizes an MFT as an individual who:

1. 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 the services defined as MFT services;
2. After obtaining such degree, has performed at least 2 years or 3,000 hours of postmaster’s degree clinical supervised experience in marriage and family therapy in an appropriate setting such as a hospital, SNF, private practice, or clinic; and
3. Is licensed or certified as an MFT by the state in which the services are performed.

MFT services means services furnished by an MFT for the diagnosis and treatment of mental illnesses (other than services furnished to an inpatient of a hospital), which the MFT 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. The services must be of a type that would be covered if they were furnished by a physician or as incident to a physician’s professional service and must meet the requirements

Verification

When enrolling as an MFT, the MAC (“contractor”) processing the enrollment application must require verification of meeting the program requirements. That includes:

1. The MAC will require the provider/supplier to submit a copy of their master’s or doctor’s degree. Whether a master’s or, instead, a doctor’s degree is required will depend on the applicable state’s requirements. (exceptions noted below)
2. The MAC shall require the provider/supplier to submit documentation verifying that they have performed, at a minimum, either 2 years or 3,000 hours of post-master’s clinical supervised experience in marriage and family therapy in an appropriate setting, such as a hospital, SNF, private practice, or clinic. (The supplier need only meet the 2-year or the 3,000-hour standard, not both.) Such documentation shall be one of the following: (exceptions noted below)
   • (i) A statement from the provider/supplier at which the MFT performed the services in question (e.g., hospital, clinic) verifying that the MFT performed services at that setting for the required number of years or hours. The statement shall:
     • (a) Be on the provider’s/supplier’s letterhead (e-mail is not acceptable); and
     • (b) Be signed by: (1) the provider/supplier supervisor under whom the MFT performed the services; (2) an applicable department head (e.g., chief of psychology) of the provider/supplier; or (3) a current authorized or delegated official of the provider/supplier (i.e., the AO/DO has already been approved as such in the provider/supplier’s enrollment record) if the provider/supplier is Medicare-enrolled.
   • The statement need not contain standard, boilerplate language. It need only confirm to the contractor’s satisfaction that the year or hour requirement was met. Also, the contractor may accept statements from multiple providers/suppliers if the year or hour requirement was met by performing services at more than one setting. For instance, suppose Dr. Smith earned her MFT experience by performing 1,000 hours at Hospital X and 2,000 hours at Hospital Y. The contractor can accept one statement from Hospital X concerning the 1,000 hours and another from Hospital Y regarding the remaining 2,000 hours so long as each statement meets the requirements of subsections (B)(2)(i)(a) and (B)(2)(i)(b) above. Put otherwise, the MFT can combine years and hours from multiple providers/suppliers to meet § 410.53(a)(2).
   • In addition:
     • A statement from the MFT’s current employer that the MFT met the year or time requirement at other settings besides the employer is not acceptable. All statements must be from the provider/supplier in which setting(s) the MFT performed the services. Using our example above, suppose Dr. Smith’s supervisor at Hospital X was Dr. Jones. Dr. Jones is no longer with Hospital X, however. Dr. Smith submits a statement from Dr. Jones stating that Dr. Smith performed 1,000 hours of MFT services at Hospital X. This statement cannot be accepted because it is not from Hospital X.
     • The setting can be any provider/supplier at which MFT services are furnished. It need not be one of the four provider/supplier types listed in § 410.53(a)(2). Moreover, the provider/supplier need not have been (or currently be) enrolled in Medicare at the time the MFT performed the services there.
   • OR
   • (ii) A statement verifying that the MFT meets the year or hour requirements from a: (1) licensing or credentialing body for the state in which the MFT is enrolling; or (2) national MFT credentialing organization. The statement can be signed by any official of the state licensing/credentialing or national credentialing body. It must, however, be on the body’s letterhead.
   • If the MFT fails to furnish the above documentation, the contractor shall develop for it consistent with the instructions in this chapter. (The enrolling provider/supplier has 30 days to reply to the development request before the application is rejected with cause)

Verification Exceptions

The verification requirements above are very strict. However, the Medicare Program Integrity manual goes on to say that if a state’s licensing board requires meeting the above education and work experience requirement in order to be licensed as an MFT then the enrollment verification criteria are met by default. The exact wording of the manual is:

§ 410.53(a)(3) – The contractor shall verify state licensure or certification consistent with existing policies for doing so in this chapter. If the contractor confirms to its satisfaction that the state already requires, as a condition of licensure or credentialing, the MFT to have:

1. Performed, at a minimum, either 2 years or 3,000 hours of post-master’s clinical supervised experience in marriage and family therapy in an appropriate setting such as a hospital, SNF, private practice, or clinic, the contractor can forgo verifying separate compliance with the § 410.53(a)(2) requirement described above; the MFT need not submit the documentation specified in subsection (B)(2). (This is because the licensure/credentialing already includes the year/hour requirement.)
2. A master’s or doctor’s degree (as applicable), the MFT need not submit a copy of his or her degree nor need the contractor verify that the MFT received said degree.

Additional Information

Pre/Post Degree – As indicated above, all 2 years/3,000 hours of clinical supervised experience must have been performed post-degree. Pre-degree experience does not count towards the required time total under § 410.53(a)(2), even if the state permits pre-degree experience to be counted towards meeting state requirements. For example, suppose State X requires 1,000 hours of supervised experience for licensure. The hours can be performed pre-degree or post-degree. Jones, who is licensed by X, performed her 1,000 hours before receiving her degree. Jones cannot apply these hours towards the § 410.53(a)(2) time requirement – even though she is licensed – and must furnish evidence of 2 years/3,000 hours post-degree experience. If, however, Jones had performed 500 hours pre-degree and 500 hours post-degree, she could apply the latter (but not the former) to the § 410.53(a)(2) time requirement.

Additional Policies – Like certain other individual practitioners, MFTs may opt-out of Medicare, form groups, reassign their benefits, receive reassigned benefits, and order/certify services to the extent otherwise permitted by law. They will complete the Form CMS-855I to bill for services and be subject to limited-risk screening. Until the Form CMS-855I is revised to include MFTs, the MFT shall check the “Undefined Non-Physician Practitioner Specialty” box and state “marriage and family therapist” in the line next thereto.

Mental Health Counselors (MHCs)

CMS recognizes an MHC as an individual who:

1. Possesses a master’s or doctor’s degree which qualifies for licensure or certification as an MHC, clinical professional counselor, or professional counselor under the state law of the state in which such individual furnishes the services defined as mental health counselor services;
2. After obtaining such degree, has performed at least 2 years or 3,000 hours of post-master’s degree clinical supervised experience in mental health counseling in an appropriate setting such as a hospital, SNF, private practice, or clinic; and
3. Is licensed or certified as an MHC, clinical professional counselor, professional counselor, addiction counselor, or alcohol and drug counselor (ADC) by the state in which the services are performed.

MHC services means services furnished by an MHC for the diagnosis and treatment of mental illnesses (other than services furnished to an inpatient of a hospital), which the MHC is legally authorized to perform under state law (or the state regulatory 1417 mechanism provided by state law) of the state in which such services are furnished. The services must be of a type that would be covered if they were furnished by a physician or as incident to a physician’s professional service.

MHC services furnished by an MHC to an inpatient of a Medicare-participating hospital are not MHC services for purposes of billing Medicare Part B.

Verification

When enrolling as an MHC, the MAC (“contractor”) processing the enrollment application must require verification of meeting the program requirements. That includes:

1. The MAC will require the provider/supplier to submit a copy of their master’s or doctor’s degree. Whether a master’s or, instead, a doctor’s degree is required will depend on the applicable state’s requirements. (exceptions noted below)
2. The MAC shall require the provider/supplier to submit documentation verifying that they have performed, at a minimum, either 2 years or 3,000 hours of post-master’s clinical supervised experience in marriage and family therapy in an appropriate setting, such as a hospital, SNF, private practice, or clinic. (The supplier need only meet the 2-year or the 3,000-hour standard, not both.) Such documentation shall be one of the following: (exceptions noted below)
   • (i) A statement from the provider/supplier at which the MHC performed the services in question (e.g., hospital, clinic) verifying that the MHC performed services at that setting for the required number of years or hours. The statement shall:
     • (a) Be on the provider’s/supplier’s letterhead (e-mail is not acceptable); and
     • (b) Be signed by: (1) the provider/supplier supervisor under whom the MHC performed the services; (2) an applicable department head (e.g., chief of psychology) of the provider/supplier; or (3) a current authorized or delegated official of the provider/supplier (i.e., the AO/DO has already been approved as such in the provider/supplier’s enrollment record) if the provider/supplier is Medicare-enrolled.
   • The statement need not contain standard, boilerplate language. It need only confirm to the contractor’s satisfaction that the year or hour requirement was met. Also, the contractor may accept statements from multiple providers/suppliers if the year or hour requirement was met by performing services at more than one setting. For instance, suppose Dr. Smith earned her MHC experience by performing 1,000 hours at Hospital X and 2,000 hours at Hospital Y. The contractor can accept one statement from Hospital X concerning the 1,000 hours and another from Hospital Y regarding the remaining 2,000 hours so long as each statement meets the requirements of subsections (B)(2)(i)(a) and (B)(2)(i)(b) above. Put otherwise, the MHC can combine years and hours from multiple providers/suppliers to meet § 410.53(a)(2).
   • In addition:
     • A statement from the MHC’s current employer that the MHC met the year or time requirement at other settings besides the employer is not acceptable. All statements must be from the provider/supplier in which setting(s) the MFT performed the services. Using our example above, suppose Dr. Smith’s supervisor at Hospital X was Dr. Jones. Dr. Jones is no longer with Hospital X, however. Dr. Smith submits a statement from Dr. Jones stating that Dr. Smith performed 1,000 hours of MHC services at Hospital X. This statement cannot be accepted because it is not from Hospital X.
     • The setting can be any provider/supplier at which MHC services are furnished. It need not be one of the four provider/supplier types listed above. Moreover, the provider/supplier need not have been (or currently be) enrolled in Medicare at the time the MHC performed the services there.
   • OR
   • (ii) A statement verifying that the MHC meets the year or hour requirements from a: (1) licensing or credentialing body for the state in which the MHC is enrolling; or (2) national MHC credentialing organization. The statement can be signed by any official of the state licensing/credentialing or national credentialing body. It must, however, be on the body’s letterhead.
   • If the MHC fails to furnish the above documentation, the contractor shall develop for it consistent with the instructions in this chapter. (The enrolling provider/supplier has 30 days to reply to the development request before the application is rejected with cause)

Verification Exceptions

The verification requirements above are very strict. However, the Medicare Program Integrity manual goes on to say that if a state’s licensing board requires meeting the above education and work experience requirement in order to be licensed as an MHC then the enrollment verification criteria are met by default and will not be required to be submitted with the application. The exact wording of the manual is:

§ 410.54(a)(3) – The contractor shall verify state licensure or certification consistent with existing policies for doing so in this chapter.

If the contractor confirms to its satisfaction that the state already requires, as a condition of licensure or credentialing, the MHC to have:

1. Performed, at a minimum, either 2 years or 3,000 hours of post-master’s clinical supervised experience in marriage and family therapy in an appropriate setting such as a hospital, SNF, private practice, or clinic, the contractor can forgo verifying separate compliance with the § 410.54(a)(2) requirement described above; the MHC need not submit the documentation specified in subsection (B)(2). (This is because the licensure/credentialing already includes the year/hour requirement.)
2. A master’s or doctor’s degree (as applicable), the MHC need not submit a copy of his or her degree nor need the contractor verify that the MHC received said degree.

Additional Information

Addiction Counselors – Addiction counselors and ADCs may enroll as MHCs if they meet the MHC requirements. They cannot, however, enroll as addiction counselors or ADCs

Pre/Post Degree – As indicated above, all 2 years/3,000 hours of clinical supervised experience must have been performed post-degree. Pre-degree experience does not count towards the required time total, even if the state permits pre-degree experience to be counted towards meeting state requirements. For example, suppose State X requires 1,000 hours of supervised experience for licensure. The hours can be performed pre-degree or post-degree. Jones, who is licensed by X, performed her 1,000 hours before receiving her degree. Jones cannot apply these hours towards the § 410.53(a)(2) time requirement – even though she is licensed – and must furnish evidence of 2 years/3,000 hours post-degree experience. If, however, Jones had performed 500 hours pre-degree and 500 hours post-degree, she could apply the latter (but not the former) to the § 410.53(a)(2) time requirement.

Additional Policies – Like certain other individual practitioners, MHCs may opt-out of Medicare, form groups, reassign their benefits, receive reassigned benefits, and order/certify services to the extent otherwise permitted by law. They will complete the Form CMS-855I to bill for services and be subject to limited-risk screening. Until the Form CMS-855I is revised to include MHCs, the MHC shall check the “Undefined Non-Physician Practitioner Specialty” box and state “mental health counselor” in the line next thereto.

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