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Provision of Mental Health Counseling Services Under Tricare
fied disabilities, and people of any age who have permanent kidney failure (CMS, 2009). The program covers the cost of mental health–care visits with physicians, clinical psychologists, clinical social workers, clinical nurse specialists, nurse practitioners, and physician’s assistants (CMS, 2002). Those health-care professionals are recognized as independent providers of mental health services under Medicare regulations.
Medicare does not recognize licensed professional counselors as independent providers, so they are not directly reimbursed through the program. Provisions in several bills that have been introduced in the House of Representatives and the Senate would have added counselors and some other mental health professionals to those eligible to provide services (CRS, 2007), but the provisions have not been enacted into law. As of October 1, 2009, bills that would grant that authority were under consideration in both chambers (HR 1693 and S 671).
Medicare beneficiaries can receive services from counselors in two ways. They can visit practitioners and pay for the expense out of pocket, or the counselors can provide treatment through the Part B “incident to” clause. The latter method allows counselors to bill Medicare through physicians or psychologists. To be covered by the clause, a service must be an integral, although incidental, part of a physician’s or psychologist’s services; the counselor must work in the same facility as a physician or psychologist (as either an employee or independent contractor of the physician or psychologist or the facility); and the counselor must be under the supervision of the physician or psychologist. Supervision means that “the physician/psychologist must be present in the facility and immediately available to provide assistance and direction while the aide is performing services” (ACA, 2009a). The physician, psychologist, or facility bills Medicare for the service, and the counselor is paid as an employee or contractor of the physician, psychologist, or facility.
Association Between Independent Practice Authority Under theMedicare Program and Under TRICARE
The committee’s statement of task directed it to review the relationship, if any, between recognition of mental health professions under the Medicare program and independent practice authority for such professions under the TRICARE program. Only one non-doctoral-level mental health profession—clinical social work—has been granted independent practice authority by both TRICARE and Medicare. Clinical