Those needs are met by a set of professionals who have different education, training, and expertise. Among them are mental health counselors, who—like clinical social workers, marriage and family therapists, and psychiatric nurse specialists—typically hold master’s degrees and are obligated by state licensure and other requirements to have demonstrated clinical experience in order to practice. They provide services to individuals and groups through psychotherapy,¹ behavior modification, and other systematic intervention strategies.

Federal code and TRICARE policy require counselors² to deliver services subject to a physician’s referral and supervision for them to be eligible for reimbursement. That distinguishes counselors from some other providers.

In 2008, Congress directed the Department of Defense (DOD) to ask the Institute of Medicine (IOM) to conduct a study of the credentials, preparation, and training of people who were practicing as licensed mental health counselors and to make recommendations for permitting these counselors to practice independently under the TRICARE program. In response, IOM formed and convened the Committee on the Qualifications of Professionals Providing Mental Health Counseling Services Under TRICARE.

In TRICARE, independent practice frees providers from requirements that state that a beneficiary must be “referred for therapy by a physician” and that the referring physician “must actually see the patient to evaluate and diagnose the condition to be treated prior to referring the beneficiary” and provide “ongoing oversight of the course of referral related treatment throughout the period during which the beneficiary is being treated,” including “ongoing communication between the