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Calendar Year (CY) 2024 Medicare Physician Fee Schedule Proposed Rule
Medicare Releases New Information on Enrollment Procedures and Related Processes for MFTs and MHCs
OFFICIAL ENROLLMENT LIKLEY BEGINS IN NOVEMBER
CMS has alerted AMHCA that they have just posted a new “MedicareEnrollment for Providers & Suppliers” page with an additional special section under “News and Additional Resources” entitled “New Provider Type: Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs).”
You can find the new posting on Marriage and Family Therapist and Mental Health Counselor Enrollment materials at:
https://www.cms.gov/medicare/enrollment-renewal/providers-suppliers/chain-ownership-system-pecos
Please keep in mind that Centers for Medicare and Medicaid Services (CMS) and the Medicare Administrative Contractors (MACs) are not officially accepting enrollment applications for Marriage and Family Therapists and Mental Health Counselors until November when it is likely that the Final 2024 Medicare Physician Fee Schedule Rule is published in the Federal Register (when at that time you can officially begin to enroll). However, you can get a head start now by reviewing the forms you will need to complete and supporting documentation.
To assist in this process, the CMS Center for Program Integrity has developed a comprehensive document entitled: “Marriage and Family Therapists (MFT) and Mental Health Counselors (MHC) Provider Enrollment Frequently Asked Questions (FAQs) September 2023.”
https://www.cms.gov/files/document/marriage-and-family-therapists-and-mental-health-counselors-faq-09052023.pdf
The CMS FAQ document contains 36 questions and answers in the following categories:
- How Medicare Recognizes Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs)
- National Provider Identifier (NPI) and Taxonomy Codes
- Enrolling as an MFT or MHC
- Reassigning Medicare Benefits
- Telehealth
- Supervision and Documentation Requirements
- Enrollment Revalidation
- Opting-Out of Medicare
Disclaimer: CMS highlights in the FAQ document link that while the FAQs generally reflect the statutory requirements in section 4121 of the Consolidated Appropriations Act (CAA) regarding MFTs and MHCs, CMS is in the process of implementing these requirements via notice and comment through the Medicare Physician Fee Schedule Notice of Rulemaking in CMS-1784-P, which likely will be published as a final rule in November of 2023 with an effective date of 1/1/24. The CMS Center for Program Integrity will revise the FAQs to the extent the final rule changes any of the requirements discussed in these FAQs (for example, the proposed 3000 hours post master’s degree clinical supervised experience provision added in the proposed Fee Schedule rule).
In addition to the actions of the Center for Program Integrity on enrollment procedures and forms, CMS has posted through it Medicare Learning Network (MLN) Connects Newsletter a special section entitled:
“New Provider Types 2024: Marriage and Family Therapists & Mental Health Counselors”
https://www.cms.gov/training-education/medicare-learning-network/newsletter/2023-09-14-mlnc#_Toc145581410
The MLN Connects Newsletter highlights that providers can start submitting enrollment applications after the CY 2024 Physician Fee Schedule final rule is on display at the Federal Register, usually around November 1 and the effective enrollment date won’t be earlier than January 1.
In the meantime, the newsletter emphasizes how to become a Medicare provider, and get ready to enroll by following these steps: