Medicare enrollment for therapists is now open to four license groups: clinical social workers and clinical psychologists, who have enrolled for years, and since January 1, 2024, marriage and family therapists (MFTs) and mental health counselors (MHCs), including licensed professional counselors and qualifying addiction counselors. This page walks a therapist or a group practice through the enrollment itself: who qualifies, what to file in PECOS, how to prove supervised experience, how telehealth from home is reported, and what to expect after you submit.
Who can enroll as a therapist
| License group | Medicare provider type | Rule |
|---|---|---|
| Licensed clinical social worker | Clinical social worker (CSW) | 42 CFR 410.73 |
| Licensed psychologist | Clinical psychologist | 42 CFR 410.71 |
| Licensed marriage and family therapist | Marriage and family therapist (MFT) | 42 CFR 410.53 |
| Licensed professional counselor, clinical mental health counselor, addiction or alcohol and drug counselor | Mental health counselor (MHC) | 42 CFR 410.54 |
For MFTs and MHCs, the CMS MFT and MHC Provider Enrollment FAQs list three conditions: a master's or doctor's degree that qualifies for licensure in your state, at least 2 years or 3,000 hours of post-master's supervised clinical experience in an appropriate setting, and a current state license or certification. CMS says a counselor licensed under a different state title can still enroll as an MHC if they meet the federal definition. Addiction counselors and alcohol and drug counselors who meet every MHC requirement enroll as MHCs too.
Associate-level and pre-licensed clinicians cannot enroll. Their Medicare patients have to be seen by a licensed, enrolled clinician.
Before you open PECOS
- Your Type 1 NPI from NPPES. CMS is explicit that a practitioner has only one individual NPI; if you already have one from Medicaid, use it.
- Your state license number and expiry for every state where you will see Medicare patients. A separate enrollment is required in each state where services are rendered.
- Proof of supervised experience, if your state did not require it for the license (see below).
- Bank details for electronic funds transfer, unless you reassign all benefits to a group.
- The group's details, if you will bill through a group: its legal name, tax ID and Medicare enrollment status.
Filing the application
Enroll online in PECOS, which CMS recommends as faster than paper. The paper alternative is the CMS-855I. CMS notes that the paper form does not yet list the MFT and MHC specialties, so paper filers choose the undefined non-physician practitioner option in section 2H and write MFT or MHC. Some points that trip therapists up:
- Only you can sign. The enrolling practitioner is the only person allowed to sign the PECOS application or CMS-855I; it cannot be delegated to an office manager.
- Name a contact person who knows the file. The Medicare Administrative Contractor (MAC) will discuss the pending application with that person and nothing else.
- No application fee for MFTs and MHCs, and both are in the limited screening risk category, which means license verification and database checks rather than a site visit.
- Compact licenses count. Medicare accepts licenses obtained through an interstate compact as full licenses.
Proving the supervised experience
Where your state already required the supervised hours for licensure, the MAC validates the license and nothing more is needed. Where it did not, CMS asks for a statement from each setting where you completed the hours. The statement must be on that organization's letterhead (an email is not accepted) and signed by your supervisor, a department head, or the organization's authorized or delegated official. Collect these letters before you file; chasing a former employer for a signature is a common source of delay.
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If you bill under your own practice, you enroll on the CMS-855I and list your practice location. If a group bills for you, you reassign your benefits to the group, which lets it submit claims and receive payment for your services. Both you and the group must be enrolled, or enrolling, for the reassignment to take effect, and the group enrolls on the CMS-855B. You can do both: see patients in your own practice and reassign to a group for the hours you work there. An existing group that already bills Medicare for social workers keeps its group number; the MAC issues a new individual number to each MFT or MHC who joins.
Seeing Medicare patients by video from home
CMS's enrollment FAQs give three telehealth scenarios. A therapist in solo private practice who works from home can report the home as a "Home Office for Administrative/Telehealth Use Only" location, which keeps the home address off Care Compare. A therapist who reassigns to a group does not list the home address at all; the group's office is the enrolled location. A therapist living in a different state from the group enrolls in the group's state. Since January 1, 2024, Medicare telehealth claims use place of service 02 or 10.
After you submit
- Processing: CMS says clean web applications are generally processed within 15 calendar days and clean paper applications within 30 calendar days, longer if anything is missing.
- Development letters: if the MAC asks for more information, you have 30 calendar days to answer, or the application is rejected.
- Approval letter and PTAN: the approval gives you a Provider Transaction Access Number for the MAC's portal and phone line. Claims are still billed with your NPI.
- Effective date: set under 42 CFR 424.520(d). Retrospective billing is limited to 30 days before it, and only when circumstances prevented enrolling earlier (42 CFR 424.521). MFTs and MHCs cannot get an effective date earlier than January 1, 2024.
- Revalidation: every 5 years under 42 CFR 424.515. Put it on the calendar now.
Enrolling in Medicaid does not enroll you in Medicare, and the reverse is also true. If your clients include people with both, you need both enrollments, and Medicare is billed first.
How Sterling Global Solution LLC handles it
We prepare the PECOS application with you, collect the supervision letters, set up the group and the reassignment, and follow each development request until the approval letter arrives. The rest of the process is in our guides to Medicare credentialing, credentialing for therapists and the credentialing checklist for new practices. New billing clients get credentialing with 3 insurance payers at no cost.
Frequently asked questions
Can licensed professional counselors enroll in Medicare?
Which form does a therapist use to enroll in Medicare?
How do I prove 2 years of supervised experience to Medicare?
Is there a Medicare application fee for MFTs and MHCs?
How long does Medicare enrollment take for therapists?
Can I see Medicare patients by telehealth from my home?
Sources
Centers for Medicare & Medicaid Services, MFT and MHC Provider Enrollment FAQs (May 2024) and Marriage and Family Therapists & Mental Health Counselors.
Code of Federal Regulations, 42 CFR 410.53, 410.54, 410.71, 410.73, 424.520(d), 424.521 and 424.515.
CMS, PECOS and NPPES.
This summarizes official sources and is not legal advice. How we verify this guidance.
Related reading
- Medicare credentialing services. Forms, fees, effective dates and opt-out for every provider type.
- Credentialing services for therapists. Commercial plans and Medicaid for counselors and MFTs.
- Credentialing checklist for new practices. Every document and step, with a free PDF.
- Behavioral health billing. Billing once you are enrolled.
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