Can LMFTs and mental health counselors bill Medicare directly, and how?

Can LPCs, LMHCs and LMFTs bill Medicare on their own?

Yes. Since January 1, 2024, licensed marriage and family therapists and mental health counselors can enroll in Medicare Part B and bill under their own NPI. Section 4121 of the Consolidated Appropriations Act, 2023 created two new benefit categories, marriage and family therapist (MFT) and mental health counselor (MHC). Before 2024 these clinicians could only work incident to a physician or psychologist, and most Medicare patients had to be referred out.

So the answer to can LPC bill Medicare is the same as the answer for LMHCs, LCPCs and LMFTs. The MHC category covers every state title for a licensed counselor: mental health counselor, clinical professional counselor or professional counselor. CMS also allows addiction counselors and alcohol and drug counselors to enroll as MHCs if they meet every MHC requirement. What matters is the state license and the supervised hours, not the letters after your name.

Three rules shape everything that follows. Medicare pays 75% of the clinical psychologist fee schedule amount. You must accept assignment on every claim. And services are limited to the diagnosis and treatment of mental illness, outside a hospital inpatient stay.

Who qualifies as a Medicare marriage and family therapist or mental health counselor?

You qualify if you meet four tests in 42 CFR 410.53 (MFTs) or 410.54 (MHCs):

• A master’s or doctoral degree that qualifies for licensure as an MFT or counselor under state law.
• A current license or certification from the state where you practice.
• At least 2 years or 3,000 hours of post-master’s supervised clinical experience.
• That experience took place in an appropriate setting such as a hospital, skilled nursing facility, private practice or clinic.

The setting list is an example, not a closed list, and private practice is named in the rule. Most fully licensed clinicians already meet the hours test, because state licensure boards require a similar supervised period. Associates, interns and pre-licensed clinicians cannot enroll. They also cannot bill under a licensed colleague’s NPI, because Medicare pays for the clinician who performed the service.

How do you enroll in Medicare as an LMFT or LPC?

Enrollment is a six-step process, and most of the delay comes from errors, not from CMS.

1. Check your NPI record. Your NPPES taxonomy should read 106H00000X for an MFT or 101YM0800X for a mental health counselor. A mismatch between NPPES and your application is a common reason a MAC sends a development letter.
2. Apply in PECOS. File the CMS-855I online through PECOS, or on paper. Choose the MFT or MHC specialty. CMS created specialty codes E1 for MFTs and E2 for MHCs, and those codes are what your MAC uses to price your claims at 75%.
3. Add reassignment if you work for a group. If a group practice bills for you, you reassign your benefits to the group in PECOS. The group must already be enrolled or enrolling at the same time on the CMS-855B.
4. Set up payment. Solo clinicians add electronic funds transfer (CMS-588) and enroll with their MAC’s EDI department or a clearinghouse for 837P claims and 835 remittances.
5. Watch your effective date. Medicare sets it at the later of the filing date or the date you first saw Medicare patients at that location, and lets you bill services from as early as 30 days before that. Sessions older than 30 days before filing are not billable.
6. Credential with Medicare Advantage plans separately. Original Medicare enrollment does not put you in network with any Medicare Advantage plan.

There is no application fee for MFTs and MHCs. CMS says clean web applications are processed within 15 calendar days and clean paper applications within 30. Revalidation comes every 5 years. Our credentialing team tracks those dates, because a lapse stops payment fast: credentialing lapses delayed payment for 1 in 12 providers added in the prior year, and a lapsed re-credentialing held payments for a median of 47 days (Luxen billing reviews). For payer-by-payer timelines, see how long insurance credentialing takes.

A clean Medicare web application is processed in 15 days and a paper one in 30 days, while new clinicians waited a median 96 days to go in-network with commercial payers (Luxen billing reviews). Medicare is often the fastest payer a new counselor can add.

Enroll, opt out or stay non-participating?

You have two real choices. Enroll and bill Medicare on assignment, or opt out and sign private contracts with Medicare patients for 2 years, with renewal every 2 years unless you cancel. Non-participating status is not an option, because MFTs and MHCs must accept assignment. If you neither enroll nor opt out, you cannot charge a Medicare patient privately for a covered mental health service.

What can LMFTs and mental health counselors bill Medicare for?

MFTs and MHCs bill the psychotherapy and behavioral health codes that fit their state scope of practice:

• Diagnostic evaluation: 90791
• Individual psychotherapy: 90832, 90834, 90837, plus interactive complexity 90785
• Family and couples psychotherapy: 90846 and 90847, when the focus is the patient’s mental health condition
• Crisis psychotherapy: 90839 and 90840, paid at 150% of the fee schedule amount in non-facility settings
• Health behavior assessment and intervention: 96156, 96158, 96159, 96164, 96165, 96167, 96168
• Newer codes listed by CMS for these clinicians: G0323 general behavioral health integration, G0560 safety planning, and G0552 to G0554 digital mental health treatment

They cannot bill 90792, E/M visit codes or the psychotherapy add-ons 90833, 90836 and 90838, because those require a prescriber. Marriage counseling for relationship problems alone is not covered. Couples work is billable only when it treats a diagnosed mental illness of the Medicare patient, and the note has to show that.

Telehealth rules for 2026

MFTs and MHCs are on Medicare’s telehealth practitioner list, and mental health telehealth to a patient’s home has no geographic limit. The in-person visit requirement for tele-mental health is delayed until January 1, 2028. Use POS 10 when the patient is at home and POS 02 elsewhere. Audio-only is allowed for behavioral health when you can do video and the patient cannot or will not. Coding errors here are costly: telehealth place-of-service and modifier errors caused 15% of behavioral health telehealth denials (Luxen claim audit).

Incident-to still works, one way

An MFT or MHC can still provide services incident to a physician, psychologist, NP, PA, CNS or CNM, under general supervision, with the claim billed under the supervising clinician at that clinician’s rate. An MFT or MHC cannot be the supervising practitioner. Pre-licensed associates therefore cannot bill Medicare incident to a licensed counselor.

How much does Medicare pay LMFTs and LPCs in 2026?

Medicare pays MFTs and MHCs 75% of what it pays a clinical psychologist for the same code. For 2026 the non-APM conversion factor is $33.4009. A 60-minute 90837 carries 5.00 total RVUs in an office, so the national psychologist amount is $167.00 and the MFT or MHC amount is $125.25. Your MAC adjusts both for your locality, so urban rates run higher and many rural rates lower.

At national rates, an MFT or MHC receives $130.01 for 90791, $85.43 for 90834 and $125.25 for 90837, against $173.35, $113.90 and $167.00 for a psychologist. The allowed amount is split: Medicare pays 80% after the 2026 Part B deductible of $283, and the patient, a Medigap plan or Medicaid owes the other 20%.

Worked example: what a solo LMFT collects from Medicare in a year

Take a solo LMFT in private practice who adds 25 Medicare patients and sees 20 of them a week for 90837, 48 weeks a year. That is 960 sessions.

• Allowed amount: 960 × $125.25 = $120,240
• Part B deductibles, if no patient has met theirs elsewhere: 25 × $283 = $7,075
• Coinsurance on the rest: ($120,240 − $7,075) × 20% = $22,633
• Medicare pays: $113,165 × 80% = $90,532
• Owed by patients, Medigap or Medicaid: $7,075 + $22,633 = $29,708

Two risks sit inside that number. First, time. In our claim audit, 18% of 90837 claims had documented session time under 53 minutes, the floor for the code. If 18% of these 960 sessions (173) only support 90834, each one is overpaid by $125.25 − $85.43 = $39.82, or $6,889 a year that an audit would claw back. Second, the patient share. Dual-eligible patients enrolled in the QMB program cannot be billed for the 20% at all, so eligibility has to be checked before the first visit, not after the denial.

Which mistakes cause Medicare denials for counselors and therapists?

Most counselor denials come from eligibility, coding and enrollment, not from medical necessity. Across our claim audit, eligibility and coverage errors caused 24% of denials, coding and modifier errors caused 21% of denials, and missing or invalid prior authorization caused 17% of denials.

Those three causes, at 24%, 21% and 17%, together account for 62% of denials, and all three can be caught before the claim leaves.

• Billing the wrong plan. A patient in a Medicare Advantage plan is not billed to your MAC, and some plans send behavioral health to a separate vendor. Claims sent to the medical plan instead of the behavioral health carve-out caused 12% of behavioral health denials (Luxen claim audit). Our eligibility checks confirm the plan and the carve-out before the intake.
• Billing before the effective date. Sessions more than 30 days before your application date will deny and cannot be rebilled.
• Coding 90837 on short sessions. 53 minutes is the floor. Document start and stop times.
• Billing codes outside the benefit. 90792, E/M codes and add-ons deny for MFT and MHC specialty codes.
• Balance billing QMB patients. It is prohibited, even for the deductible.
• Letting denials sit. 19% of denied claims were never reworked or appealed in the practices we reviewed. Denial follow-up is where small practices lose the most.

Should a counseling practice bill Medicare in-house or outsource it?

For a solo clinician, the question is time more than money. Solo therapists carried a median 41 days in AR, against 29 for group practices (Luxen billing reviews), mostly because nobody works the claims between sessions. On the $120,240 example above, outsourced billing at 3% to 6% of collections costs about $3,607 to $7,214 a year. Fully loaded in-house billing cost 7.9% of collections for practices under $2M, across 96 practices that shared payroll data (Luxen billing reviews), which would be about $9,499 here.

Billing yourself works if you see a handful of Medicare patients and have time to post ERAs and chase denials each week. Outsourcing makes sense once Medicare, Medicare Advantage and commercial plans all sit in one caseload. If you outsource, pick a team that signs a BAA before touching your system and works inside your existing EHR. With full-service billing, median time from signed BAA to first claims worked was 9 business days (Luxen client data). If you want a second opinion on your Medicare setup, book a free billing review.

How do Medicare rules for LMFTs and LPCs compare with psychologists and LCSWs?

MFTs and MHCs sit at the same payment level as clinical social workers, below psychologists, and they share the same limits on prescriber codes. The main differences are payment rate, testing codes and who can supervise incident-to services.

Behavioral health group practices

Groups add each MFT or MHC to their Medicare enrollment by reassignment, and the claim goes out under the group’s billing NPI with the clinician as rendering provider. A wrong rendering NPI or a clinician billed before the reassignment is approved is the most common group-level denial. Our therapist billing page covers commercial and carve-out rules for the same practices.

Psychology practices

A psychology group that employs counselors must price their services at 75% and cannot let them bill testing codes 96130 to 96139. Psychologists can still supervise counselors incident to their own care under general supervision, billed at the psychologist rate. See psychology billing for testing and psychologist rate rules.

Addiction treatment programs

Addiction counselors and alcohol and drug counselors enroll as MHCs only if they meet the full MHC degree, license and hours test. Many state-certified addiction counselors without a master’s degree do not. Counselor services inside an IOP or PHP are billed by the facility, not the counselor. See substance abuse billing and addiction treatment revenue cycle management for program-level rules.

Primary care practices

A primary care practice can hire an LMFT or LPC to bill psychotherapy under their own enrollment at 75%, or bill the same work incident to the physician at the full rate under general supervision. The counselor can also bill G0323 general behavioral health integration. Medicare Advantage plans now count MFTs and MHCs in their outpatient behavioral health network adequacy category, so plans are adding them.

Rural health clinics and FQHCs

Since 2024, MFT and MHC visits count as billable RHC and FQHC visits, paid under the clinic’s all-inclusive rate or PPS rather than the 75% fee schedule. That makes a counselor one of the cheapest ways for a rural clinic to add mental health visits. Visits billed under the wrong rendering provider caused 8% of RHC and FQHC denials (Luxen claim audit).

Physical therapy and chronic pain programs

Counselors working with physical therapy or pain management patients can bill health behavior assessment and intervention codes 96156 to 96168 for coping and adherence work tied to a physical condition. A physical therapist cannot be the supervising practitioner for incident-to, so the counselor bills under their own MFT or MHC enrollment.