The Centers for Medicare and Medicaid Services Release Final Rule for Medicare Reimbursement

November 3, 2023 (Alexandria, VA) — The Centers for Medicare and Medicaid Services (CMS) has released the 2024 Physician Fee Schedule Rule. Many of the policies within the rule relate to mental health counselors (MHC) and marriage and family therapist (MFT).

The American Counseling Association in collaboration with CMS would like to highlight some of the rules here:

• CMS is implementing Section 4121 of the Consolidated Appropriations Act, 2023, which provides for Medicare Part B coverage and payment under the Medicare Physician Fee Schedule (PFS) for the services of MHCs and MFTs when billed by these professionals. Additionally, this includes addiction counselors that meet all the applicable requirements to be MHCs to enroll in Medicare as MHCs.
• CMS will make corresponding changes to Behavioral Health Integration codes to allow MHCs and MFTs to provide integrated behavioral health care as part of primary care settings.
• CMS has finalized to allow the Health Behavior Assessment and Intervention (HBAI) services to be billed by clinical social workers, MHCs and MFTs, in addition to clinical psychologists. HBAI codes are used to identify the psychological, behavioral, emotional, cognitive and social factors included in the treatment of physical health problems.
• CMS has also finalized an increase in the valuation for timed behavioral health services under the PFS. Specifically, we are finalizing an increase to the valuation for psychotherapy codes payable under the PFS. Based on comments, we are also increasing the valuation of psychotherapy performed after an E/M visit and the HBAI codes.

To review additional information and read the full rule please select the links below:

• Press Release: CMS Finalizes Physician Payment Rule that Advances Health Equity
• Fact Sheet: Calendar Year (CY) 2024 Medicare Physician Fee Schedule Final Rule 
• Final Rule: Medicare and Medicaid Programs: Calendar Year 2024 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; etc.
• CMS Public Q&A for the MHC/MFT FAQs: Marriage and Family Therapists (MFT) and Mental Health Counselors (MHC) Provider Enrollment Frequently Asked Questions (FAQs)

ACA is in the process of reviewing the rule in its entirety and will provide additional updates as they become available. To stay up to date, please join ACA and the Medicare Mental Health Workforce Coalition during our monthly webinars. The next webinar, “Medicare 601: The Enrollment Process for Counselors and MFTs” is scheduled for November 17, 2023. Register here: https://bit.ly/Medicare601

Access additional information on Medicare reimbursement for counselors by visiting the Medicare Mental Health Workforce Coalition page on the ACA website.