Medicare's 2024 opening: LMFTs and MHCs as enrolled providers

Yes — Medicare opened to LMFTs and MHCs on January 1, 2024

Licensed marriage and family therapists and licensed mental health counselors became Medicare Part B billing providers on January 1, 2024, under the Consolidated Appropriations Act, 2023 — the first time either license type could enroll and bill Medicare directly rather than working incident-to a physician or psychologist. Medicare's own mental-health coverage guidance documents the change alongside the provider types, codes, and constraints that came with it 1Ref 1Centers for Medicare & Medicaid Services (2025).Medicare and Mental Health Coverage.Supports that Medicare opened enrollment to LMFTs and mental health counselors in 2024, and describes their covered codes, telehealth rules, incident-to constraints, and payment percentage..

The opening didn't fold LMFTs and MHCs into an existing category. They're a distinct enrolled provider type with their own scope, sitting alongside — not inside — the rules that already governed clinical psychologists and clinical social workers.

For a solo practice, the practical effect is a client base that used to be off-limits: beneficiaries who'd previously have to pay out of pocket, seek out a psychologist, or find a physician-supervised arrangement can now stay with an LMFT or MHC directly once that clinician enrolls.

How to enroll: the standard Medicare provider path

Enrollment runs through the same door every other Medicare Part B provider uses: an NPI, a CMS-855I application submitted through PECOS, and a decision about participation, non-par, opt-out status before your first claim. There's no separate LMFT or MHC track — license type is a field on the same form, not a different process.

One eligibility line is worth flagging before you apply: Medicare requires the full, independent state license, not a provisional or associate one. That's a sharper bar than the rule many commercial payers use for can pre-licensed clinicians bill commercial insurance, where some networks extend limited billing rights to supervised associates. Medicare draws no equivalent exception — enroll once you're fully licensed, not before.

Budget real processing time. PECOS applications for a new provider type move through the same review queue as every other enrollment, and an incomplete CMS-855I — a missing supervising-relationship detail, an unsigned certification statement, a lapsed background-check attestation — resets the clock rather than pausing it. File early enough that a first rejection doesn't cost you a month of unbillable sessions.

What's covered: the codes that pay

LMFTs and MHCs bill the same psychotherapy CPT family everyone else in behavioral health uses — the diagnostic evaluation code and the timed individual, family, and group therapy codes, selected the same way psychologists select them 2Ref 2APA Services, Inc. (2025).Psychotherapy Codes for Psychologists.Supports the psychotherapy CPT family and time-band code-selection mechanics LMFTs and MHCs bill under the same rules as psychologists.. Medicare's mental-health guidance lists these as the covered service set for the new provider types, alongside the telehealth and incident-to constraints that apply to them specifically 1Ref 1Centers for Medicare & Medicaid Services (2025).Medicare and Mental Health Coverage.Supports that Medicare opened enrollment to LMFTs and mental health counselors in 2024, and describes their covered codes, telehealth rules, incident-to constraints, and payment percentage..

What's still out of scope: evaluation and management visits. E/M level selection runs on the medical decision-making or total-time framework CMS built for physician and other qualified health professional office visits 6Ref 6Centers for Medicare & Medicaid Services (2023).Evaluation and Management Services Guide.Supports that E/M code selection runs on the medical decision-making or time framework, the code set that remains outside LMFT/MHC scope., and that framework — and the codes it governs — sits outside the psychotherapy-and-evaluation set Medicare opened to LMFTs and MHCs. If a case needs an E/M-billed visit, that visit still has to come from a provider type Medicare recognizes for E/M.

Telehealth: covered the same way it is for everyone else

LMFTs and MHCs bill telehealth the same way other Medicare behavioral health providers do — against CMS's annually published list of codes payable as medicare telehealth, which marks each code permanent or temporary and flags audio-only eligibility separately 3Ref 3Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.Supports that Medicare telehealth eligibility, including audio-only status, is governed by CMS's published annual list rather than a separate rule for LMFTs and MHCs.. Enrollment as an LMFT or MHC doesn't create a separate telehealth rule; it just adds you to the pool of provider types the existing list already covers.

Because the list and its audio-only carve-outs change on a rolling basis, check it before every plan year rather than assuming last year's coverage holds — a code payable by telehealth in one year can move to in-person-only or vice versa with little notice.

Incident-to and supervision: what changes, what doesn't

Before 2024, an LMFT or MHC's work could only reach a Medicare claim as an incident-to service billed under a supervising physician's or psychologist's NPI — direct supervision, an employment or contract relationship, and an initiating visit from the billing provider, all required 4Ref 4Office of the Federal Register (2026).42 CFR 410.26 — Services and supplies incident to a physician's professional services.Supports the direct-supervision, employment, and initiating-service conditions that defined incident-to billing before and after 2024 enrollment opened.. Enrolled LMFTs and MHCs now bill under their own NPI instead, so that chain isn't mandatory for services they're personally qualified to furnish and bill.

Incident-to billing itself didn't disappear — it's still available where a practice chooses to structure services that way, and the same direct-supervision and employment conditions still apply when it's used 4Ref 4Office of the Federal Register (2026).42 CFR 410.26 — Services and supplies incident to a physician's professional services.Supports the direct-supervision, employment, and initiating-service conditions that defined incident-to billing before and after 2024 enrollment opened.. The practical shift is that it's now a choice rather than the only path, which is a different starting point than psychologists and medicare, where physician- or psychologist-level enrollment has applied for decades.

Collaborative Care and Behavioral Health Integration

Medicare pays for behavioral health integration and Collaborative Care Model services — codes like the BHI code and the CoCM family — and describes the required care-team elements and validated rating-scale use for each 5Ref 5Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.Supports that Medicare pays for BHI and Collaborative Care Model codes and describes the required care-team elements LMFTs and MHCs can now furnish directly.. LMFTs and MHCs can furnish the care-management work these codes cover as part of a primary-care-based team, not only as the treating behavioral health clinician on a standalone psychotherapy claim.

That matters for a solo practice that contracts with a primary care group: the newly enrolled license types can now be the named behavioral health professional in that arrangement, where before 2024 the role effectively required a psychologist or clinical social worker.

The payment rate: below the psychologist rate, above incident-to

LMFT and MHC services are paid at a set percentage of the Medicare physician fee schedule amount rather than the full rate psychologists and physicians receive for the same code — a distinction Medicare's mental-health guidance carries alongside the provider-type and coverage rules it lays out for the new billing types 1Ref 1Centers for Medicare & Medicaid Services (2025).Medicare and Mental Health Coverage.Supports that Medicare opened enrollment to LMFTs and mental health counselors in 2024, and describes their covered codes, telehealth rules, incident-to constraints, and payment percentage.. Run the exact rate for your codes through the Medicare Physician Fee Schedule lookup rather than assuming it matches a psychologist's allowed amount for the identical CPT code.

That rate still beats billing nothing at all, which was the only option before 2024 unless a practice routed the service through incident-to billing under someone else's NPI — and split the payment and the administrative burden that came with it.

Model the math before you decide how much of your caseload to shift toward Medicare. A lower per-session rate against a steady, predictable payer can still beat a higher commercial rate against a payer with heavier utilization review, and a solo practice's overhead — a biller-of-one's time chasing claims, appeals, and eligibility checks — often matters more to the bottom line than the headline percentage does.