by Wyn Staheli, Director of Content - innoviHealth
Oct 24th, 2023
The COVID-19 public health emergency (PHE) put a spotlight on the shortfall of behavioral health providers available to patients in need of these services. To address this problem, the Consolidated Appropriations Act, 2023 (CAA, 2023), established a new Medicare benefit category for Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) when those services are furnished by and directly billed by MFTs and MHCs.This change becomes effective on January 1, 2024.
This is a big change. Previously, Medicare did not allow MFTs and MHCs to provide behavioral health (BH) services. Now is the time for BH organizations to start preparing to expand their services to Medicare beneficiaries. Healthcare providers will need to meet the educational requirements (see Medicare Frequently Asked Questions below) as well as go through the enrollment process to become a Medicare provider. You can’t just start seeing Medicare patients on January 1, 2024 unless you have met their criteria. if you don’t want to bill Medicare directly, but there are strict requirements for doing this and an opt-out affidavit must be submitted to your Medicare Administrative Contractor (MAC).
You can begin the enrollment process once the 2023 Final Medicare Physician Fee Schedule (MPFS) has been officially posted which usually happens the first week of November. Applications made on the PECOS system are processed within 15 calendar days; whereas paper applications will take 30 days.
See the Medicare Frequently Asked Questions document listed below for additional important information about this change including group applications, opt out requirements, and supervision requirements. For example:
30. Can I perform telehealth services to patients located in another state?
During the COVID-19 public health emergency (PHE), CMS used emergency waiver and other regulatory authorities so you could provide more services to your patients via telehealth. Section 4113 of the CAA, 2023 extended many of these flexibilities through December 31, 2024, and made some of them permanent. For more information refer to the Telehealth Services Fact Sheet.
CMS has proposed to add MFTs and MHCs to the list of practitioners who can furnish Medicare telehealth services. Practitioners who wish to perform telehealth services must enroll in the state where they are located when furnishing the service. The practitioner must also have a valid medical license in the enrolling state. In section 4B of the CMS-855I, enter the location where the telehealth service is performed (e.g., office, home). Select the practice location type as Business Office for Administrative/Telehealth Use Only or Home Office for Administrative/Telehealth Use Only. If you will be reassigning your Medicare benefits to an organization/group, the practitioner and the organization/group must be enrolled in the same state. For more information refer to Inter-Jurisdictional Reassignments.
About Wyn Staheli, Director of Content - innoviHealth
Wyn Staheli is the Director of Content Research for innovHealth. She has over 30 years of experience in the healthcare industry. With her degree in Management Information Systems (MIS), she has been a programmer for a large insurance carrier as well as a California hospital system. She is also the author and editor of many medical resource books and the founder of InstaCode Institute.