TRICARE Releases Rules Authorizing Independent Practice for CMHCs
By James K. Finley
AMHCA Director of Public Policy
Just before the end of the year, TRICARE released long-awaited rules authorizing independent practice for Certified Mental Health Counselors (CMHCs). Published in the Dec. 27 Federal Register, the new rules advance participation requirements for mental health counselor providers. Instead of working under the supervision and referral of a physician, CMHCs are now eligible for autonomous practice and third-party reimbursement.
The rule, released in interim final form, establishes a transition period to phase out the requirement for physician referral and supervision for mental health counselors. It also creates a new category of allied health professional known as “certified mental health counselors” (CMHCs).
Once phased in, CMHCs will be the only authorized mental health counselors to participate under TRICARE. The provider standards will be fully in force on Jan. 1, 2015, meaning that all CMHCs who want to serve TRICARE beneficiaries must qualify under the new rules by Dec. 31, 2014.
The new rules include a critical grandfather provision for current practitioners, and also rapidly accelerate national movement toward accreditation of clinical mental health counseling programs by the Council for Accreditation of Counseling and Related Educational Programs (CACREP).
During a transition period that is in effect from now through Dec. 31, 2014, mental health counselors who do not meet the requirements for independent practice as established in the rule may continue to provide services to TRICARE beneficiaries under the requirements of physician referral and ongoing supervision.
When the transition period ends on Dec. 31, 2014, all CMHCs who want to continue providing services under the TRICARE program must have met the independent practice requirements outlined in the rule. After that date, professionals who do not meet the requirements for CMHC participation will no longer be recognized by TRICARE, and payment for their services will not be allowed—even if they work under the supervision of a physician.
New Provider Participation Standard
Grandfather Provision: To practice independently, CMHCs must meet one of the following two quality standards on or before Dec. 31, 2014:
- Possess a master’s or higher-level degree from a mental health counseling program of education and training accredited by CACREP, and must have passed the National Counselor Examination (NCE); or
- Possess a master’s or higher-level degree from a mental health counseling program of education and training from either a CACREP or regionally accredited institution and have passed the National Clinical Mental Health Counseling Examination (NCMHCE)
Both the NCE and NCMHCE are managed by the National Board for Certified Counselors (NBCC).
Required CACREP accreditation and NCMHCE passage after Dec. 31, 2014: A CMHC entering the program on or after Jan. 1, 2015, must:
- Pass the NCMHCE or its successor as determined by TRICARE; and
- Possess a master’s or higher-level degree from a mental health counseling program of education and training accredited by CACREP.
A CMHC must also be licensed for independent practice in mental health counseling by the jurisdiction where practicing. In jurisdictions with two or more licenses allowing for differing scopes of independent practice, the licensed mental health counselor may only practice within the scope of the license he or she possesses.
The rules also permit TRICARE to amend or modify its requirements, qualifications, or criteria in the future to accommodate professional quality and licensing standards changes over time.
AMHCA Supervision Standards Incorporated
CMHCs must have a minimum of two years of post-master’s degree supervised mental health counseling practice, which includes a minimum of 3,000 hours of supervised clinical practice and 100 hours of face-to-face supervision. Required supervision must be provided by a mental health counselor who is licensed for independent practice in mental health counseling in the jurisdiction where practicing and must be conducted in a manner that is consistent with AMHCA’s guidelines for supervision.
In 2010, the Institute of Medicine (IOM) recommended that independent practice of mental health counselors under TRICARE should occur under certain circumstances. The IOM’s recommended provider participation criteria included,
“A master’s or higher-level degree in counseling from a program in mental health counseling or clinical mental health counseling that is accredited by CACREP;
A state license in mental health counseling at the clinical or the higher or highest level available in states that have tiered licensing schemes;
Passage of the NCMHCE; and
A well-defined scope of practice for practitioners.”
The TRICARE rule will implement these standards over time, while preserving the requirement for 3,000 hours of supervised clinical practice and 100 hours of face-to-face supervision. The rule also expresses TRICARE’s commitment to ensuring that the high-quality standards recommended by the IOM are adopted, but agency officials understand that the availability of CACREP-accredited mental health counseling training programs and the use of the NCMHCE as a quality standard are not yet widespread.
For more information about the TRICARE rules, contact James K. Finley, AMHCA director of public policy, at 800.326.2642, x105, or at JFinley@amhca.org.