DECEMBER 2023 E-NEWSLETTER

In addition to possessing either a master’s or doctorate degree in marriage and family therapy and being licensed to practice marriage and family therapy, Medicare eligible providers are required to have at least 2 years or 3,000 hours of post-degree clinical supervised experience. While California providers may not earn their hours toward licensure in less than two years and must have a total of 3,000 to qualify for licensure, California MFTs may gain up to 1,300 hours of clinical supervised experience pre-degree. This means not all of California’s licensees will have gained the 2 years or 3,000 hours of post-degree clinical supervised experience upon receiving their licenses.

However, in the Calendar Year 2024 Physician Fee Schedule final rule released on November 2nd, CMS indicated it will accept any post-degree clinical supervised experience, including experience gained after becoming licensed, toward the 2 years or 3,000 hours of clinical supervised experience for Medicare provider enrollment purposes. As part of our advocacy efforts, CAMFT and the Medicare Mental Health Workforce Coalition asked CMS to accept providers’ attestations as evidence of having met this requirement. Unfortunately, that request was denied. This means that CA-licensed providers will likely be expected to produce one of two statements.

According to CMS’s Medicare Program Integrity Manual and its September 2023 FAQs document which answers questions about LMFTs’ involvement in Medicare, CMS with accept EITHER of the following:

A statement from the setting or settings where the MFT/MHC performed the services verifying that the MFT/MHC performed services at that setting for the required number of years or hours. The statement must be: On the setting’s letterhead (e-mail is not acceptable); and Signed by: (1) the supervisor under whom the MFT/MHC performed the services; (2) an applicable department head (e.g., chief of psychology) of the setting; or (3) a current authorized or delegated official of the setting

OR 

A statement verifying that the MFT/MHC meets the year or hour requirements from a: 

(1) licensing or credentialing body for the state in which the MFT/MHC is enrolling; or

(2) national MFT/MHC credentialing organization. The statement can be signed by any official of the state licensing/credentialing or national credentialing body and must be on the body’s letterhead (email is not acceptable).

Note: A statement from current employers that the year or hours requirement have been met at other settings besides the employer’s is not acceptable. All statements must be from the setting(s) where the required experience was gained. The California Board of Behavioral Sciences (BBS) notified CMS and CAMFT that it will not be providing statements to its licensees because it has no way to extrapolate data showing its licensees have met the 2 years or 3,000 hours of post-degree experience requirement.

Therefore, to meet Medicare’s eligibility requirements, California licensed MFTs who want to qualify to work in the Medicare system should obtain a statement from a setting or settings where they gained clinical experience either  
post-degree or after having become licensed. Providers who are licensed in multiple states, may want to see if the other state(s) licensing bodies will furnish a statement. Providers who do not submit one of the statements should expect to receive a development letter  from their MAC and will have 30 days to produce the required documentation or face having their applications denied.

Although Medicare Administrative Contractors (MACs) are accepting applications now, providers will not be approved prior to January 1, 2024 , when LMFTs (and LPCCs) become eligible Medicare providers. Also note that while provider approval is retroactive up to 30-days prior to an official approval date, LMFTs (and LPCCs) will not be reimbursed for seeing Medicare patients prior to January 1, 2024 because January 1st is the first day of LMFTs and LPCCs’ provider eligibility.

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