For years, many therapists simply could not bill Medicare for their own services. That changed on January 1, 2024, when marriage and family therapists (MFTs) and mental health counselors (MHCs) became able to enroll in Medicare and bill Part B directly. Clinical social workers were already eligible before that change, so today the large majority of licensed outpatient therapists can serve Medicare patients under their own enrollment.
This guide covers who qualifies, how enrollment works for behavioral health clinicians and the issues we see most often when therapists enroll for the first time.
What changed in 2024
Section 4121 of the Consolidated Appropriations Act, 2023 created a new Medicare benefit category for services furnished and billed by MFTs and MHCs. CMS implemented it in the 2024 Physician Fee Schedule, with payment beginning January 1, 2024. CMS states that MFTs and MHCs can bill Medicare independently for services furnished for the diagnosis and treatment of mental illness, and that no enrollment effective date earlier than January 1, 2024 is granted.
Who qualifies
Clinical social workers (LCSW and equivalents)
Clinical social workers have been a recognized Medicare provider type for many years and enroll as "Clinical Social Worker" on the CMS-855I. If you are an LCSW who never enrolled, nothing in the 2024 change is required for you to start; you simply need to enroll.
Mental health counselors (LPC, LMHC, LCPC and similar)
CMS defines an MHC by function rather than by one license name. Under CMS guidance, an MHC:
- Holds a master's or doctoral degree that qualifies for licensure or certification as a mental health counselor, clinical professional counselor or professional counselor under the law of the state where they practice
- Has at least two years or 3,000 hours of post-degree supervised clinical experience in an appropriate setting, such as a hospital, skilled nursing facility, private practice or clinic
- Is licensed or certified by the state where services are performed. CMS's manual update lists mental health counselor, clinical professional counselor, professional counselor, addiction counselor, and alcohol and drug counselor
In practice, that covers most LPCs, LMHCs and LCPCs, and many licensed addiction counselors, depending on how their state defines the license.
Marriage and family therapists (LMFT)
The MFT criteria mirror the MHC criteria: a qualifying master's or doctoral degree, at least two years or 3,000 hours of post-degree supervised clinical experience in marriage and family therapy, and state licensure or certification as an MFT where services are furnished.
If you are not sure your license fits, that is exactly the kind of question we answer before any application is filed. Licensing titles vary from state to state, and the definitions above are what matter.
How enrollment works
Behavioral health clinicians enroll as individuals on the CMS-855I, either on paper or through PECOS. CMS's FAQ notes that on the paper form, MFTs and MHCs are reported under the undefined non-physician practitioner specialty and identified as MFT or MHC, and that a separate application is required for each state where you provide services. Our CMS-855I guide explains the form in general, and our CMS-855 form guide shows how it compares to the others.
The building blocks are the same as for any practitioner:
- An individual NPI from NPPES, with a taxonomy and address that match your license and practice
- An Identity and Access (I&A) account to reach PECOS
- A current license in each state where you will see Medicare patients
- Your group's Medicare enrollment, if a group practice will bill for you through a reassignment of benefits (see our reassignment guide)
Where therapists get stuck
License titles that do not obviously match
Medicare's categories are MFT and MHC. Your license might say something else. Documenting how your license and supervised experience meet the CMS definition avoids back-and-forth with the contractor.
Telehealth and multi-state practices
Many therapists see patients in more than one state. Each state where you provide services needs its own license and, per CMS, its own enrollment application. Practice locations, including how a home office is reported, deserve care.
NPPES records that are years out of date
Therapists who got an NPI early in their careers for commercial insurance often have old addresses or taxonomies in NPPES. Those mismatches create questions in PECOS.
Group practices adding clinicians all at once
When a group decides to start seeing Medicare patients, it may need its own enrollment plus individual enrollments and reassignments for every clinician. Coordinating signatures and records across the whole team is where these projects slow down.
Assuming enrollment means everything is set
Enrollment gives you Medicare billing privileges. Medicare Advantage plans and state Medicaid programs are separate. Depending on your patients, you may need those too, and our credentialing vs. enrollment guide explains the difference.
How Maverick helps behavioral health practices
We work with solo therapists and group practices. We confirm how your license maps to Medicare's categories, clean up your NPPES record, prepare your 855I in PECOS for each state you need, set up reassignments to your group, and submit once your file is complete. Then we follow up with the Medicare contractor on a set schedule, handle any requests for more information and keep you updated. We also track revalidations once you are enrolled.
See our Medicare and Medicaid enrollment service and our behavioral health practice page.
Sources: CMS, Marriage and Family Therapists and Mental Health Counselors (CMS.gov); CMS, MFT and MHC Provider Enrollment FAQs (May 2024); CMS MLN MM13331, Provider Enrollment Changes to the Medicare Program Integrity Manual; CMS Change Request 12448; CMS-855I Medicare Enrollment Application. Verified October 2026.