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Guide

Medicare Enrollment For Counselors And MFTs (LPC, LMHC, LMFT): 2026 Step By Step

Medicare has paid LPCs, LMHCs and LMFTs since January 1, 2024. Who qualifies, the PECOS steps, which MAC you file with, effective dates and the 75% rate.

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Medicare Enrollment

Yes, LPCs, LMHCs and LMFTs can bill Medicare. Since January 1, 2024, Medicare has covered services from marriage and family therapists (MFTs) and mental health counselors (MHCs) who hold a qualifying master’s or doctoral degree, have at least 2 years or 3,000 hours of post-degree supervised clinical experience, and are licensed in the state where they practice. You enroll on the CMS-855I, usually online in PECOS, and Medicare pays you 75% of what it pays a clinical psychologist for the same service.

File in PECOS before your first Medicare visit, but not more than 60 days before the start date you list. Medicare won’t pay for visits much before your filing date, and a MAC can return an application that arrives more than 60 days early.

The Short Answer

Medicare made marriage and family therapists and mental health counselors their own provider types through Section 4121 of the Consolidated Appropriations Act, 2023, and payment started January 1, 2024. If you’re an LPC, LMHC, LCPC or LMFT who meets the federal definition, you can enroll, bill under your own NPI and get paid directly. Your license doesn’t have to use the words mental health counselor. CMS says a counselor licensed under a different title can enroll as an MHC if they meet every federal requirement, and so can addiction counselors and alcohol and drug counselors who meet them.

Who Qualifies

The definitions sit in 42 CFR 410.53 for MFTs and 42 CFR 410.54 for MHCs. Both have the same three parts, and you need all three.

Requirement Marriage And Family Therapist Mental Health Counselor
Degree A master’s or doctoral degree that qualifies you for MFT licensure or certification in the state where you practice A master’s or doctoral degree that qualifies you for licensure or certification as a mental health counselor, clinical professional counselor or professional counselor in that state
Supervised experience At least 2 years or 3,000 hours of post-master’s supervised clinical experience in marriage and family therapy, in a setting such as a hospital, SNF, private practice or clinic At least 2 years or 3,000 hours of post-master’s supervised clinical experience in mental health counseling, in the same kinds of settings
License Licensed or certified as an MFT by the state where you provide services Licensed or certified as an MHC, clinical professional counselor or professional counselor by that state. CMS also accepts addiction counselor and alcohol and drug counselor licenses when everything else is met

If your state requires the supervised hours for full licensure, the MAC checks them through your license. If it doesn’t, send proof with the application, either a letter on the letterhead of the place you did the work, signed by your supervisor, a department head or its authorized official, or a letterhead statement from your state licensing body or a national credentialing organization. CMS won’t accept email for either.

There’s no pre-licensed tier, so an associate can’t enroll. CMS’s mental health booklet says Medicare doesn’t cover services billed incident to an MFT’s or MHC’s own services. A licensed counselor can’t bill an associate’s sessions under their own NPI.

What You Need Before You Start

  • An I&A account. CMS’s Identity & Access Management System is the login for both NPPES and PECOS.
  • One Type 1 NPI with the right taxonomy. CMS lists 106H00000X for MFTs and 101YM0800X for MHCs. You only get one individual NPI, so Medicare uses the one Medicaid already has.
  • A license for each state. You need a license in every state where you see patients and a separate CMS-855I enrollment for each of those states. Medicare accepts licenses issued through an interstate compact.
  • A street address for every practice location. The CMS-855I won’t accept a P.O. box as a practice location.
  • Bank details for EFT. Medicare pays by electronic funds transfer, so you file the CMS-588 with a voided check or a bank letter. You can skip it if you reassign all of your payments to a group.
  • The group’s sign-off, if a group bills for you. The group has to be enrolled or enrolling at the same time, and its authorized or delegated official signs your reassignment.

There’s no application fee for an individual MFT or MHC. CMS puts both in its limited-risk screening category, which means license verification and database checks.

PECOS Step By Step

  1. Log in to PECOS with your I&A account and start an initial enrollment as an individual practitioner, choosing the MFT or MHC specialty. On the paper CMS-855I, CMS says to check Undefined Non-Physician Practitioner Specialty in section 2H and write in MFT or MHC.
  2. Report where you practice. If you’re the sole owner of your own PC, PA or LLC and bill through it, the CMS-855I covers that too. You report the business in section 4A, and you don’t need a separate reassignment to it.
  3. Add the reassignment if a group bills for you. CMS discontinued the CMS-855R. Reassignment now lives in the CMS-855I, in PECOS’s Reassignment topic or in section 4F on paper. You sign section 15B, and the group’s authorized or delegated official signs section 15C.
  4. Name a contact person. It can be you or whoever handles your credentialing, and the MAC will discuss only the pending application with them.
  5. Upload your documents and sign. Only you can sign your CMS-855I. An individual practitioner can’t delegate that signature to anyone, including a billing company.
  6. File the CMS-588 for EFT unless all of your payments go to a group.
  7. Answer every development letter within 30 days. CMS says clean web applications are generally processed within 15 calendar days and clean paper ones within 30. A request for more information stops that clock, and if you don’t respond within 30 calendar days, the application is rejected.
  8. Keep the approval letter. It carries your PTAN, the Medicare number you use with your MAC’s portal and phone lines. Claims still go out under your NPI.

Which MAC Processes Your Application

Your Medicare Administrative Contractor is set by the state where you see patients, not where you live or where your billing company sits. There are 12 A/B MAC jurisdictions. This table comes from CMS’s MACs by State list and each jurisdiction’s CMS page.

Jurisdiction MAC States And Territories
J5 WPS Iowa, Kansas, Missouri, Nebraska
J6 National Government Services (NGS) Illinois, Minnesota, Wisconsin
J8 WPS Indiana, Michigan
J15 CGS Kentucky, Ohio
JE Noridian California, Hawaii, Nevada, American Samoa, Guam, Northern Mariana Islands
JF Noridian Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington, Wyoming
JH Novitas Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, Texas
JJ Palmetto GBA Alabama, Georgia, Tennessee
JK National Government Services (NGS) Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, Vermont
JL Novitas Delaware, District of Columbia, Maryland, New Jersey, Pennsylvania, plus Part B for Arlington and Fairfax counties (including the cities of Fairfax and Falls Church) and the City of Alexandria in Virginia
JM Palmetto GBA North Carolina, South Carolina, Virginia (except the Northern Virginia areas listed under JL), West Virginia
JN First Coast Florida, Puerto Rico, U.S. Virgin Islands

The Medicare Coverage Database now lists newer National Government Services documents under the name Wellpoint Federal. Contracts get re-awarded, so check the official CMS MAC map before you mail anything.

Effective Dates And Billing Back

Your Medicare effective date comes from 42 CFR 424.520(d). It’s the later of two dates, the day you filed an application the MAC later approved or the day you started seeing patients at the new practice location. No MFT or MHC could get a date earlier than January 1, 2024, when the benefit began.

42 CFR 424.521(a) adds a small cushion. You can bill back up to 30 days before the effective date if circumstances kept you from enrolling in advance and you already met every requirement, state license included. The window is 90 days when a presidentially declared disaster is what stopped you. A counselor who starts seeing Medicare patients on March 1 and files on June 1 can bill back to early May. March and April are gone.

Filing too early has its own limit. Under 42 CFR 424.526(a)(2), a MAC can return an application it receives more than 60 days before the effective date you listed.

What Medicare Pays

Medicare pays MFTs and MHCs 75% of the amount it pays a clinical psychologist under the physician fee schedule. That’s 42 CFR 414.53, and the CY 2024 physician fee schedule rule walks through the statute behind it, section 1833(a)(1)(FF) of the Social Security Act. Medicare pays 80% of the lesser of your actual charge or that 75% amount, and the patient owes the rest as coinsurance after the Part B deductible.

In dollars, for every $100 Medicare allows a clinical psychologist for a service, your fee schedule amount is $75. Medicare pays $60 of it, and the patient’s coinsurance is $15.

You also have to accept assignment, so you can’t collect more from a Medicare patient than the deductible and coinsurance.

Hospital inpatient services don’t pay under these benefits, and CMS’s booklet says the same for partial hospitalization and intensive outpatient services that a hospital outpatient department or community mental health center provides.

Once you’re in, revalidate every 5 years when CMS asks. Report a new or closed practice location within 30 days and most other changes within 90, under 42 CFR 424.516(d).

Medicare Advantage Credentials Separately

A Medicare approval doesn’t put you in any Medicare Advantage network. Each MA plan runs its own credentialing under 42 CFR 422.204, with a signed application, primary-source verification of your license, a check of your disciplinary status and your eligibility for Medicare payment, and recredentialing at least every 3 years.

Order matters. CMS notes that some MA plans and state Medicaid agencies want you enrolled in Medicare first, so get the approval letter before you apply to the plans your patients carry.

Rather not take Medicare? Practitioners who see Medicare patients without enrolling have to opt out with an affidavit to their MAC. An opt-out runs 2 years, renews on its own, and generally keeps MA plans from paying you outside emergency or urgently needed care.

Why Applications Come Back

Medicare can reject an application or return it, and neither comes with appeal rights. After a rejection you start over. These are the regulatory reasons that fit a typical counselor or MFT file.

  • No answer to a development letter within 30 days. That’s grounds for rejection under 42 CFR 424.525(a)(1).
  • Signature problems. An unsigned or undated application, a stamped or copied signature, a signature from anyone but you, or one dated more than 120 days before the MAC received the application.
  • An incomplete reassignment package. If the forms needed for the reassignment don’t all arrive within 30 days, the package can be rejected.
  • The wrong form. A CMS-855R, an outdated paper version or the wrong CMS-855 type. MACs started returning the discontinued CMS-855R and the old CMS-855I version after November 1, 2023.
  • Filed too early or sent to the wrong MAC. More than 60 days before the listed effective date, or a paper application mailed to a contractor that doesn’t cover your state.
  • Supervised hours you can’t show. If your license doesn’t prove the 2 years or 3,000 hours, the MAC needs the letter described above, on letterhead.

That’s the list we check before anything is filed.

Questions We Get

Can LPCs Bill Medicare?

Yes. Since January 1, 2024, licensed professional counselors who meet Medicare's mental health counselor definition can enroll and bill Medicare directly. You need a qualifying master's or doctoral degree, at least 2 years or 3,000 hours of post-master's supervised clinical experience, and a state license. Medicare pays you 75% of the clinical psychologist rate.

How Do I Enroll In Medicare As An LMFT Or LMHC?

Set up a CMS Identity and Access account, confirm your Type 1 NPI shows the MFT taxonomy 106H00000X or the MHC taxonomy 101YM0800X, then file the CMS-855I in PECOS with your license and EFT details. Add a reassignment in the same application if a group bills for you. CMS says clean web applications are generally processed within 15 calendar days.

Do I Still Need The CMS-855R To Join A Group?

No. CMS discontinued the CMS-855R and moved reassignment into the CMS-855I. In PECOS you add it under the Reassignment topic, and on paper it's section 4F. You sign section 15B, and the group's authorized or delegated official signs section 15C. The group has to be enrolled already or enrolling at the same time.

Can I Bill Medicare For Patients I Saw Before I Enrolled?

Only for a short window. Your effective date is the later of your filing date and the day you started at the practice location, under 42 CFR 424.520(d). You can bill back up to 30 days before it if circumstances kept you from enrolling earlier, or 90 days after a presidentially declared disaster. Visits before that aren't payable.

Does Medicare Enrollment Put Me In Medicare Advantage Networks?

No. Each Medicare Advantage plan credentials providers on its own under 42 CFR 422.204, including primary-source license verification and recredentialing at least every 3 years. Some MA plans and state Medicaid agencies want your Medicare enrollment in place first, so get the Medicare approval letter, then apply to the plans your patients carry.

Keep Going

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Want Your Medicare Enrollment Handled?

We prepare your CMS-855I in PECOS, add the reassignment when a group bills for you, and follow up until the MAC confirms your effective date. Medicare enrollment is $500 per provider. Need commercial panels too? Therapist Credentialing covers five commercial payers for $2,500.

Price My Medicare Enrollment

General information, not legal or billing advice. CMS rules and MAC contracts change, so check the sources below before you file. Prescribers have their own guide to Medicare billing for PMHNPs, and how long credentialing takes covers commercial timelines.

Sources