Medicare Implementation Planning Underway

Mar 14, 2023

On March 9, the Centers for Medicare and Medicaid Services (CMS) Division of Practitioner Services for Medicare and the American Counseling Association (ACA) met to discuss program implementation.

ACA has identified four areas in which we have requested CMS to consider providing clarification. These areas, except for Crisis Care Services (CCS), will allow Licensed Professional Counselors to use the Medicare codes that are currently in place when diagnosing and billing. Our goal is to ensure the regulations governing the Medicare program fully represent the profession's needs.

The four areas identified are:

  1. Behavioral Health Integration (BHI)

    BHI services use a Psychiatric Collaborative Care Model involving a team, including a Treating (Billing) Practitioner who can be a physician or nonphysician practitioner. The beneficiary may have, but is not required to have, comorbid, chronic, or other medical condition(s) that are managed by the billing practitioner.

  2. Caregiver Behavior Management Training (CBMT)

    CBMT codes cover services that involve training caregivers in interventions and strategies to help manage or treat the patient’s condition, which can improve beneficiaries’ clinical outcomes.

  3. Health and Behavioral Assessment and Intervention (HBAI) Services

    HBAI services help Medicare beneficiaries with emotional and psychosocial concerns that arise because of a medical condition (such as a diagnosis of cancer or an exacerbation of multiple sclerosis) unrelated to a mental health condition.

  4. Crisis Care Services (CCS)
    The Secretary of Health and Human Services must establish new HCPCS (Healthcare Common Procedure Coding System) codes under the physician fee schedule for mental health crisis services provided at sites other than an office or facility setting (i.e., mobile crisis intervention services).

    For Crisis Care Services, there are currently no codes in place. ACA would like CMS to consider including LPCs in the CCS update prior to the January 1, 2024 Medicare enrollment period opening for Licensed Professional Counselors.

What’s Next

In July 2023, ACA will respond to the CMS Public Comment for the Proposed Rule for Implementation where we will also address the above items in detail. ACA will request counselors also respond to the rule. The Association will provide a template and guidance on how to respond to CMS public comment period.

Prior to July, ACA will host virtual events to help counselors understand Medicare Implementation, and how to prepare for enrolling into the program.

For more information, please contact the ACA Government Affairs and Public Policy team at

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