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MFT Licensing

Medicare Enrollment for Marriage and Family Therapists

MFTs have been able to bill Medicare since January 1, 2024. Here is who qualifies, how enrollment works, and what the 75 percent payment rule means for your schedule.

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5 min read · by White Glove MFT
A therapist at a desk completing a Medicare enrollment application next to a laptop and a Medicare card.

Since January 1, 2024, licensed marriage and family therapists can enroll as Medicare providers. You need a qualifying master's or doctoral degree, at least two years or 3,000 hours of post-master's supervised clinical experience, and an MFT license in the state where services are furnished. Enroll through PECOS or form CMS-855I. Payment is 75 percent of the clinical psychologist rate.

For decades, older adults who wanted to see a marriage and family therapist and use their Medicare benefits were out of luck. Medicare simply did not list MFTs as a provider type. That changed on January 1, 2024, when the Consolidated Appropriations Act, 2023 took effect for this profession and MFTs became eligible to enroll as Medicare providers in their own right.

For a clinician who works with couples in later life, adult children caring for aging parents, grief after a spouse dies, or depression and anxiety in retirement, this opened a population that had been closed. It also brought a new set of paperwork, a payment rule that surprises people, and a licensing requirement that matters a great deal once you practice in more than one state.

Eligibility in plain terms

Medicare sets three requirements. First, you need a master's or doctoral degree that qualifies for licensure or certification as a marriage and family therapist under state law. Second, you need at least two years or 3,000 hours of post-master's supervised clinical experience. Third, you must be licensed or certified as an MFT in the state where you furnish the services.

Most fully licensed MFTs already meet the first two requirements, because states generally require supervised post-degree experience before granting an independent license. The third requirement is where people trip, and it gets its own section below. If you hold an associate or provisional license and are still accruing hours, read the requirements carefully against your own record before applying, and ask your Medicare Administrative Contractor if anything is unclear.

Getting your file ready before you apply

Enrollment goes more smoothly when the pieces are assembled first. You will need an individual National Provider Identifier, which you may already have if you bill commercial insurance. Check that the name, practice address, and taxonomy on your NPI record match what you will put on the Medicare application, because mismatches are a common reason applications come back.

Have your license numbers, issue dates, and expiration dates for each state at hand, along with your degree information and the practice locations where you will see beneficiaries. If you will bill through a group practice rather than under your own name, find out from the group how they handle reassignment of benefits, since that determines where Medicare sends payment.

Enrolling through PECOS or the CMS-855I

There are two ways in. PECOS, the Provider Enrollment, Chain, and Ownership System, is the online portal. Form CMS-855I is the paper application for individual practitioners. Both are processed by the Medicare Administrative Contractor that covers your area.

PECOS has practical advantages. You can see where your application stands, respond to requests for more information, and later update a practice location or add a reassignment without starting from paper. If your contractor sends a development request asking for a missing document or a correction, respond promptly and completely; an unanswered request can lead to the application being rejected, and then you start again.

Once enrolled, keep the record current. Moving your practice, adding a location, changing a group affiliation, or letting a state license lapse all affect your enrollment. Medicare also requires enrolled providers to revalidate periodically, and CMS posts revalidation due dates, so put a reminder on your calendar rather than relying on remembering.

How the 75 percent rate works

MFT services are paid at 75 percent of the amount Medicare pays clinical psychologists under the physician fee schedule. That is the same relationship that applies to some other master's-level mental health professions, and it is set in law rather than negotiated.

In practice, this means the rate for a given psychotherapy code will be lower for you than for a psychologist billing the same code in the same locality. The fee schedule also varies by geographic locality, so a colleague in another part of the country will see different numbers. Look up the codes you expect to bill most often on the CMS physician fee schedule lookup, apply the 75 percent relationship, and compare the result to your commercial and private-pay rates before deciding how much of your caseload to open to Medicare.

Also factor in the beneficiary side. Medicare has deductibles and coinsurance, and many beneficiaries carry supplemental coverage that picks up some or all of that share. Medicare Advantage plans are run by private insurers, so seeing those members usually requires credentialing with each plan separately, and their rates and rules may differ from traditional Medicare.

Deciding whether Medicare fits your practice

Enrollment is not an obligation. Some MFTs enroll because a meaningful share of their referrals come from primary care practices, hospital discharge planners, or senior living communities where Medicare is the default. Others stay private pay and accept that some older adults will look elsewhere. There are also rules about what you can and cannot charge a Medicare beneficiary if you are not enrolled, so do not assume you can simply see beneficiaries for cash. Read the CMS guidance on private contracting and opt-out, or ask your contractor, before setting that policy.

A reasonable way to decide is to count. Look at the last year of inquiries you turned away because the caller had Medicare, estimate the documentation and billing time per session, and compare the net rate against the rest of your caseload. If Medicare clients would fill hours that currently sit empty, the lower rate may still add up.

One enrollment, many licenses

Medicare licensure is state-specific. You must be licensed where the beneficiary receives services, which for telehealth means wherever the beneficiary is physically sitting during the session. Your Medicare enrollment does not carry across state lines on its own. If you hold licenses in two or three states and want to see Medicare clients in each, make sure each license is active, listed with Medicare where required, and renewed on time, because a lapse in one state ends your ability to bill Medicare for services furnished there.

Common questions

Who became eligible to bill Medicare in 2024?
Licensed marriage and family therapists became eligible to enroll as Medicare providers starting January 1, 2024, under the Consolidated Appropriations Act, 2023. Before that date, Medicare did not recognize MFTs as a provider type, so their services to beneficiaries could not be billed under their own enrollment.
Should I use PECOS or the paper CMS-855I?
Either route leads to enrollment. PECOS is the online system and lets you track the application and make later changes in one place. The paper CMS-855I is the equivalent form. Many clinicians find PECOS easier to correct and update, but both are accepted.
How much does Medicare pay an MFT?
MFT services are paid at 75 percent of the amount paid to clinical psychologists under the physician fee schedule. The actual dollar amount depends on the service code and your geographic locality, so check the current fee schedule on the CMS website or with your Medicare Administrative Contractor.
Does a Medicare enrollment cover every state I am licensed in?
No. Medicare requires that you be licensed as an MFT in the state where the beneficiary receives services. If you see Medicare clients located in two states, you need a valid license in each of those states.

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