Can LPCs and LMFTs Bill Medicare? What the 2024 Change Means for Employers

Section 4121 of Division FF of the Consolidated Appropriations Act, 2023 created a new Medicare benefit category for MFT and MHC services furnished by and directly billed by marriage and family therapists and mental health counselors, with payment under Part B beginning January 1, 2024.

Before that date there was no Medicare benefit category for these services billed under the clinician’s own enrollment — a counselor or MFT could not carry a Medicare caseload in their own name at all.

Two dates do the work.

Payment began January 1, 2024, and CMS cannot grant an MFT or MHC an effective date earlier than that day: claims with dates of service before January 1, 2024 are not payable, no matter when the clinician enrolled.

There is no retroactive lane for pre-2024 work.

MFTs and MHCs were also added to the list of practitioners who can furnish Medicare telehealth services, and to the practitioners who may opt out of Medicare — an option that matters at offer stage, covered in the last section below.

This page owns the 2024 benefit itself.

The sequence around it — NPI, then Medicare enrollment, then CAQH and each commercial panel — is the credentialing ramp covered in our guide to credentialing a new clinician.

Medicare defines both provider types in regulation — marriage and family therapists at 42 CFR 410.53, mental health counselors at 42 CFR 410.54 — and the definitions run on the same three-part test: a qualifying degree, supervised post-master’s clinical experience, and a state license or certification in the state where services are performed.

The license line is where the LPC question gets answered.

The regulation itself names mental health counselor, clinical professional counselor and professional counselor licenses, so a licensed professional counselor (LPC), licensed clinical professional counselor (LCPC) or licensed mental health counselor (LMHC) holds a title the regulation lists.

For titles it does not list, CMS finalized in the CY 2024 Physician Fee Schedule rule that people who meet the MHC education and supervised-experience requirements but are licensed under a different title to provide mental health counseling may enroll in Medicare as MHCs.

Either way, the acronym matters less than whether all three tests are met.

Documentation follows the same logic.

Where the state license itself requires the supervised experience, CMS says no additional action is necessary.

Where it does not, the application must prove the two-year requirement — for example, a signed statement on letterhead from the setting where the clinician was supervised (the FAQ is explicit that e-mail is not acceptable), signed by the supervisor, department head or authorized or delegated official, or a statement from the state licensing body or a national credentialing organization.

Ask which situation your hire is in before the application goes in; it is the one piece of paper you can gather in advance.

Part of your substance-use workforce can reach this benefit — through guidance, not the regulation text.

The MHC regulation names only mental health counselor, clinical professional counselor and professional counselor licenses; it does not list addiction counselors or alcohol and drug counselors.

What extends the benefit is CMS guidance: the agency’s Medicare & Mental Health Coverage booklet — the March 2026 edition is the current one — says addiction counselors or alcohol and drug counselors who meet the applicable MHC requirements can enroll in Medicare as MHCs.

The distinction matters for how firmly you plan on it: this is CMS explaining how it will apply its own definition, not a sentence in the rule itself.

The bar does not move for anyone.

The same three tests apply — qualifying master’s or doctoral degree, at least 2 years or 3,000 hours of post-master’s supervised experience, and the required state license or certification.

A bachelor’s-level certified addiction counselor does not meet that test, however experienced, so a Medicare line cannot be staffed on that credential alone.

For the clinician’s side of that credential question — what a CADC can and cannot do in its own name — see our can a CADC bill explainer.

The formula is statutory: Medicare pays 80 percent of the lesser of the actual charge or 75 percent of the amount determined for payment of a psychologist.

Leave the per-code arithmetic to the fee schedule — for planning, the point is that the MFT and MHC benchmark is defined downward from the psychologist amount, so build Medicare margin expectations accordingly.

Assignment is mandatory: MFTs and MHCs must accept assignment on Medicare claims.

That takes a pricing decision off the table for Medicare work, and it interacts directly with how you structure pay — our clinician pay models guide covers how to structure pay when fee schedules are fixed.

Two coverage boundaries matter when you map the benefit onto your programs.

Services to hospital inpatients are excluded from the MFT and MHC benefit.

And Medicare does not pay under the MHC benefit for MHC services that a hospital outpatient department or community mental health center provides to patients in a partial hospitalization program or intensive outpatient program — if you operate PHP or IOP programming inside one of those settings, that slice is not payable here.

The benefit does reach settings group practices forget about.

MFT and MHC services are covered when furnished in a rural health clinic or a federally qualified health center, and a hospice interdisciplinary team is required to include at least one social worker, MFT or MHC — more than one license type can fill that seat.

One boundary hits staffing design directly: Medicare does not cover services provided incident to an MFT’s or MHC’s own professional services, so an enrolled counselor or MFT cannot carry an associate’s work under their own enrollment.

CMS’s booklet notes the reverse can exist — it may cover MFT or MHC services as auxiliary personnel incident to the personal professional services of a physician, clinical psychologist, clinical nurse specialist, nurse practitioner, physician assistant or certified nurse midwife — but the MFT or MHC enrollment itself supports no one else’s sessions.

Where supervised billing does fit, the incident-to and supervised billing guide has the mechanics.

Each clinician enrolls individually — online through PECOS or on the paper CMS-855I.

On the paper form, CMS’s May 2024 FAQ instructs MFTs, MHCs and counselors licensed under another title to select the “Undefined Non-Physician Practitioner Specialty” option in section 2H and write in MFT or MHC; PECOS lists the MFT and MHC specialties directly.

Two features keep this enrollment light.

CMS places MFTs and MHCs in the limited screening category, which runs license verification and database checks, and they pay no Medicare enrollment application fee.

The group mechanics are familiar if you already bill Medicare.

An MFT or MHC can be enrolled as an individual practitioner and also be an owner of the group — the practitioner files the CMS-855I, the group files the CMS-855B.

If your group is already enrolled — billing for clinical social workers, say — it keeps its group PTAN when you add MFTs or MHCs, and each newly enrolled clinician gets an individual PTAN linking them to the group.

Timing is where hiring plans slip: billing cannot start before the clinician’s Medicare effective date, and how that date is set — and the narrow retroactive-billing window — is covered in the credentialing guide’s ramp section.

The one MFT- and MHC-specific rule is the floor covered above: no effective date earlier than January 1, 2024.

Screen for the definition, not the acronym.

The hire Medicare will enroll is the one who clears all three tests — qualifying degree, 2 years or 3,000 hours of post-master’s supervised experience, and the license.

A counselor who clears the degree and experience tests and holds an LPC, LCPC or LMHC license — or is licensed to provide mental health counseling under another title — is enrollable as an MHC; a counselor who clears them and holds a state MFT license is enrollable as an MFT.

“Medicare-enrollable” is now a screenable line in your job ad instead of a guess, and if the role is broader than Medicare work, our guide to hiring a therapist covers the license and screening questions from the employer’s side.

It does not reach everyone with a counseling-adjacent title.

Bachelor’s-level addiction counselors do not meet the MHC definition, and pre-licensed associates gain nothing here because nothing can be billed incident to an MFT’s or MHC’s own services — a Medicare staffing plan still needs an enrolled MFT or MHC at the center of the work.

Ask about Medicare status at offer stage.

MFTs and MHCs are among the practitioners who may opt out of Medicare, and a clinician who has opted out may receive no direct or indirect Medicare payment for privately contracted services — including as an employee of an organization or under a reassignment — so a group cannot bill Medicare for an opted-out hire’s services.

An opt-out also runs in two-year periods that renew automatically unless the practitioner properly cancels it, so it does not lapse on its own.

Medicare enrollment adds one workstream to the ramp; for the rest of the staffing playbook — screening, pay, contracts, onboarding — the behavioral health hiring hub collects the guide for each.