Current Status of Medicare Enrollment for MFTs in Connecticut
What was the barrier for Connecticut MFTs enrolling in Medicare?
In 2023 Federal legislation passed the United States Congress providing for Medicare coverage of services provided by a Marriage and Family Therapist (MFT) effective January 1, 2024. MFTs are required to enroll in (or opt out of) Medicare as a covered provider. Since enrollment began in January 2024, MFTs in Connecticut have been experiencing barriers to enrolling as a Medicare provider because of different legislative language for the requirements in our CT state statute. To serve patients Medicare federal law requires that all licensed MFTs who enroll as Medicare providers must have performed “at least 2 years or 3,000 hours of post master’s degree clinical supervised experience.” Under this proposed rule, an applicant must have either 2 years or more of post-master’s clinical supervised experience or 3,000 hours of post-master’s clinical supervised experience but are not required to have both 2 years of experience and 3,000 hours of experience. Our former CT state statute of MFTs Practice Act (Sect 20-195c) states that MFTs must “completed twelve months of relevant postgraduate experience, including (A) a minimum of one thousand hours of direct client contact offering marital and family therapy services…” This was different legislative language and different licensing requirements than the federal language requires. Due to this inconsistency, the Federal Centers for Medicare and Medicaid Services (CMS) required CT MFTs applying to be Medicare providers to submit paperwork from a site or supervisor verifying that the MFT obtained this required experience. This additional paperwork requirement was where some MFTs are hitting the barrier.
What did CTAMFT do about this barrier?
CTAMFT became aware of this barrier for some CT MFTs and held several meetings with AAMFT, Connecticut’s Department of Public Health (DPH), Connecticut’s Legislative Public Health Committee, and has been in touch with the Federal Centers for Medicare and Medicaid (CMS). No one wanted to erect or uphold barriers to MFTs becoming paneled Medicare providers; as the point of the Consolidated Appropriations Act of 2023 was to expand access to Medicare, not restrict it. CTAMFT elevated this legislative initiative to our top legislative priority of the 2024 legislative session. CTAMFT proposed a change in our state legislative language of the MFT Practice Act to be changed from one year to two years. This legislative change would align with federal requirements and thus not burden our members with the barrier of seeking out additional documentation and slowing their enrollment process with CMS. Connecticut was the only state in the nation that had a requirement under two years for post graduate experience. MFTs were also the only mental health license in the state of Connecticut that had less than a two year post graduate requirement.
If this Medicare Barrier fixed?
Yes! There has been a change to the CT MFT Practice Act as a result of Public Act 24-68 that was effective July 1, 2024. This legislation was in direct response to CTAMFT and AAMFT lobbying for these changes. CTAMFT worked in collaboration with AAMFT, Centers for Medicaid and Medicare Services (CMS), CT Department of Public Health (DPH), legislators, and our members to remove the barriers to CT MFTs becoming Medicare eligible and paneling providers after the federal passage of Medicare expansion that included MFTs as Medicare eligible providers - something that we have been fighting for since the 1980s!
What are the Changes to our CT MFT Practice Act?
The changes are related to CT MFT licensure and all CT MFTs must meet criteria listed below to become a CT Licensed Marriage and Family Therapist. Applicants must have 1) completed a graduate degree in a specialty of Marriage and Family Therapy from an accredited program, 2) completed a supervised practicum/internship with an emphasis on Marriage and Family Therapy that is supervised by an accredited MFT program, 3) completed 24 months [this is a change from prior 12 month requirement and also aligns with the federal requirements for Medicare eligible mental health providers] of postgraduate clinical experience including a) minimum of 1,000 postgraduate direct client contact hours and b) minimum of 100 hours of postgraduate supervision by and LMFT, 4) successfully passed licensing exam and paid $200 fee application fee to DPH.
So What Does this Mean?
This small adjustment of requiring a minimum of 24 months of postgraduate clinical experience allows for CT MFTs to match the federal Medicare MH requirements as well as brings CT in parity with the majority of other state requirements of MFT licensure. This change to CT state laws will not only impact MFTs licensed after July 1, 2024, but will bind CMS and MACs (Medicare regional administrators) to no longer prompting requirements for further documentation of already licensed MFTs as a result of the current conformity of federal and state requirements. If you have any further questions or problems with opting in or opting out of Medicare as a CT MFT please contact CTAMFT Advocacy Chair, Jaime Rodriguez at advocacy@ctamft.org or FamilyTEAM@aamft.org
Special Thanks:
CTAMFT, AAMFT and many Connecticut MFTs submitted testimony on March 18, 2024 during the Public Health Committee's public hearing on HB 5488. The proposed legislative language was then moved to section 38 of HB 5682 and voted favorably. The Governor signed this bill on May 28, 2024 and has an effective date of July1, 2024. Please join us in thanking all our members, CTAMFT Advocacy Chair and Board, CTAMFT Lobbyist, as well as AAMFT, CMS, DPH and CT state legislators in supporting this very important change for CT MFTs and all CT Medicare recipients.