Medicare Benefit Policy Manual (Pub. 100-02), Ch. 13 § 150
Clinical Psychologist (CP), Clinical Social Worker (CSW),
150 - Clinical Psychologist (CP), Clinical Social Worker (CSW),
Marriage and Family Therapist (MFT), and Mental Health Counselor
(MHC) Services
(Rev. 12832; Issued: 09-12-24; Effective:01-01-24; Implementation:10-14-24)
A CP is an individual who:
• Holds a doctoral degree in psychology, and
• Is licensed or certified, on the basis of the doctoral degree in psychology, by the
state in which he or she practices, at the independent practice level of psychology
to furnish diagnostic, assessment, preventive, and therapeutic services directly to
individuals.
For additional information on CP’s, see Pub. 100-02, Medicare Benefit Policy Manual,
chapter 15, section 160.
A CSW is an individual who:
• Possesses a master’s or doctor’s degree in social work;
• After obtaining the degree, has performed at least 2 years of supervised
clinical social work; and
• Is licensed or certified as a clinical social worker by the state in which the
services are performed; or, in the case of an individual in a state that does not
provide for licensure or certification, meets the requirements listed in
410.73(a)(3)(i) and (ii).
For additional information on CSW’s, see Pub. 100-02, Medicare Benefit Policy Manual,
chapter 15, section 170.
A MFT is an individual who:
• Possesses a master's or doctor's degree which qualifies for licensure or
certification as a marriage and family therapist pursuant to State law of the State
in which such individual furnishes the services defined as marriage and family
therapist services;
• After obtaining such degree, has performed at least 2 years or 3,000 hours of post
master’s degree clinical supervised experience in marriage and family therapy in
an appropriate setting such as a hospital, SNF, private practice, or clinic; and
• Is licensed or certified as a marriage and family therapist by the State in which the
services are performed.
A MHC is an individual who:
• Possesses a master's or doctor's degree which qualifies for licensure or
certification as a mental health counselor, clinical professional counselor,
professional counselor under the State law of the State in which such individual
furnishes the services defined as mental health counselor services;
• After obtaining such a degree, has performed at least 2 years or 3,000 hours of
post master’s degree clinical supervised experience in mental health counseling in
an appropriate setting such as a hospital, SNF, private practice, or clinic; and
• Is licensed or certified as a mental health counselor, clinical professional
counselor, professional counselor by the State in which the services are
performed.
For additional information on MFTs and MHCs, see Pub. 100-02, Medicare Benefit
Policy Manual, chapter 15, sections 330 and 340, respectively.
Services may include diagnosis, treatment, and consultation. The CP, CSW, MFT or
MHC must directly examine the patient, or directly review the patient’s medical
information. Except for services that meet the criteria for authorized care management or
virtual communication services, telephone or electronic communication between a CP,
CSW, MFT or MHC and a patient, or between such practitioner and someone on behalf
of a patient, are considered CP, CSW, MFT or MHC services and are included in an
otherwise billable visit. They do not constitute a separately billable visit. CSWs are
statutorily authorized (1861(hh)(2) of the Act) to furnish services for the diagnosis and
treatment of mental illnesses only. MFTs and MHCs are statutorily authorized (section
1861(lll)(1) and 1861(lll)(3) of the Act, respectively) to furnish services for the diagnosis
and treatment of mental illnesses only.
Services that are covered are those that are otherwise covered if furnished by a physician
or as incident to a physician’s professional service. Services that a hospital or SNF is
required to provide to an inpatient or outpatient as a requirement for participation are not
included.
Services performed by CPs, CSWs, MFTs and MHCs must be:
• Furnished in accordance with RHC or FQHC policies and any physician medical
orders for the care and treatment of a patient;
• A type of service which the CP, CSW, MFT or MHC who furnished the service is
legally permitted to furnish by the state in which the service is rendered; and
• Furnished in accordance with state restrictions as to setting and supervision,
including any physician supervision requirements.