For decades, LMFTs and LMHCs watched psychologists and LCSWs bill Medicare while they legally couldn't. That ended January 1, 2024. If you hold one of these licenses, Medicare is now an open panel — one of the few that never closes to eligible providers — and it quietly gates the Medicare Advantage networks too. The real decision isn't whether you can enroll; it's which of three enrollment postures fits your practice.
Since January 1, 2024, LMFTs and mental health counselors can enroll in Medicare through PECOS and bill independently. Requirements: a qualifying graduate degree, state licensure, and two years or 3,000 hours of post-degree supervised experience. Payment is 75 percent of the psychologist fee — about $125.25 for a 90837 in 2026 — and enrollment is the doorway to Medicare Advantage panels.
Who qualifies, and what changed in 2024?
The Consolidated Appropriations Act of 2023 added marriage and family therapists and mental health counselors as Medicare Part B provider types, effective January 1, 2024. Per the CMS FAQ, an MFT or MHC needs a master's or doctoral degree that qualifies for licensure, a current license in the state where they practice, and at least two years or 3,000 hours of post-degree supervised clinical experience.
The "mental health counselor" category is broader than the label. CMS treats licensed professional counselors and licensed clinical professional counselors as MHCs — so LPCs qualify under their state title. Addiction counselors meeting the same education and supervision requirements also qualify as MHCs.
How do I actually enroll in PECOS?
Start at the Identity and Access Management (I&A) system, not PECOS itself. Your PECOS login is your I&A account — the same credentials tied to your NPI in NPPES. If you registered your own NPI, you likely have one; if a practice manager did it, recover access first, because password archaeology is the single slowest step of the whole enrollment.
Then, at pecos.cms.hhs.gov: log in, open My Associates, select your name, and choose New Application — enrollment as an individual practitioner, the online CMS-855I. PECOS lists marriage and family therapist and mental health counselor as selectable specialties; the paper CMS-855I still may not, which is one reason CMS itself points new MFT and MHC enrollees to the online route. (On paper, CMS instructs you to check "Undefined Non-Physician Practitioner" and write in your specialty.)
You'll attest your license details, upload documentation of the supervised experience, pick participating or non-participating status, set up EFT for payment, and e-sign. Your regional Medicare Administrative Contractor (MAC) — Noridian, Novitas, Palmetto, and peers — processes the file and mails a welcome letter with your PTAN. Watch for a MAC "development request" email; an unanswered one quietly closes the application.
Participating, non-participating, or opt out — what's the dollar math?
Participating is the default and the right answer for most enrollees. Using the 2026 national non-facility amounts — $167.00 for CPT 90837 and $113.90 for CPT 90834 — an MFT or MHC is paid 75 percent of those psychologist amounts. Here's how the three postures compare on a 90837:
| Posture | Your allowed amount (90837) | Who pays you | Catch |
|---|---|---|---|
| Participating | About $125.25 (75% of $167.00) | Medicare pays 80% ($100.20) directly; patient owes 20% ($25.05) | You accept assignment on every claim |
| Non-participating | About $118.99 allowed (95% of par); you may bill up to the $136.84 limiting charge (115%) | Often the patient pays you, then Medicare reimburses them | You chase patient balances; extra ~$11 per session rarely covers the admin |
| Opt out | Whatever your private-pay fee is | Patient pays 100% under a private contract | No Medicare or Medicare Advantage payment for two years, auto-renewing |
Every figure above is the national base; the Geographic Practice Cost Index moves your locality's numbers up or down. Look yours up in the CMS Physician Fee Schedule search before deciding — a San Francisco 90837 and a rural Kansas 90837 are meaningfully different sessions financially.
Why is opting out a trap for therapists?
Because the affidavit is total and it lingers. Opting out means filing a formal affidavit with your MAC agreeing to bill no Medicare claims for two years — for any Medicare patient, in any setting. It also cuts off Medicare Advantage: per APA Services, an opted-out provider cannot be paid by MA plans either. And since June 2015, opt-out affidavits renew automatically every two years unless you cancel in writing before the term ends.
An LMHC in Tampa opted out in February 2024, reasoning her private-pay rate beat $125. By fall, two group practices recruiting her were building Medicare Advantage panels — Florida's largest-growing referral stream — and she was contractually invisible to them until her two-year term expired in February 2026. The trap isn't the fee; it's the lockout you can't undo early.
If you simply never enroll, you're not "opted out" — but an unenrolled provider still can't bill Medicare, and Medicare patients can't get reimbursed for seeing you. For most LMFTs and LMHCs the ranking is: participate, or don't enroll yet; formally opt out only if you're certain you want a private-pay-only relationship with the 65-plus population for years.
Medicare has no closed panels and no network-capacity denials — if you meet the requirements, you enroll. That makes it a useful anchor while commercial panels waitlist you; see our guide to choosing which panels to join.
How does Medicare unlock Medicare Advantage panels?
Medicare Advantage plans are commercial products — UnitedHealthcare, Humana, Aetna, and the Blues run them — and their networks are credentialed separately from original Medicare. But MA plans expect network providers to be Medicare-eligible and not opted out, so PECOS enrollment comes first.
The sequence that works: enroll in original Medicare first, then apply to each MA network through the insurer's standard credentialing channel, naming your PTAN and Medicare specialty. Commercial credentialing timelines still apply — see how long credentialing takes — and enrollment sequencing is exactly the kind of ordering problem paneled.ai exists to manage. Medicare enrollment is also step one for Medicaid credentialing in many states, since state Medicaid rates and screening often reference Medicare's.
QUESTION 1 — Do you want Medicare (65+) or Medicare Advantage clients at all, now or in the next 2 years? NO, never, and my practice is full at private-pay rates -> Consider OPT OUT only if Medicare patients keep asking you to bill. Otherwise simply don't enroll (no affidavit, no 2-year lock). YES or MAYBE -> Question 2
QUESTION 2 — Is roughly $125 per 90837 / $85 per 90834 (2026 national, before locality adjustment) workable as one revenue stream among several? YES -> Question 3 NO -> Don't enroll yet. Recheck each year: rates and your caseload economics both move. Do NOT file an opt-out affidavit "just in case" — it locks you out of Medicare Advantage too.
QUESTION 3 — Will you tolerate collecting balances from patients directly? NO (I want Medicare to pay me directly, less admin) -> PARTICIPATING. Accept assignment; Medicare pays 80% to you, patient owes 20%. The default and right answer for most. YES, and I want the ~9% higher ceiling -> NON-PARTICIPATING. You may bill up to the limiting charge (115% of the reduced non-par amount, ~$136.84 on a 2026 90837), but you often collect from the patient and they get reimbursed. Run the math against your no-show and collections reality first.
BEFORE YOU FILE ANYTHING [ ] I&A account recovered/created (tied to your NPI) [ ] License + 2 years / 3,000 hours supervision documentation scanned [ ] Locality rate checked in the CMS PFS lookup tool [ ] Participation decision made (changeable during annual open enrollment, mid-year changes are restricted) [ ] Calendar note: respond to any MAC development request within days
Common questions
- Can LMFTs and LMHCs bill Medicare?
- Yes, since January 1, 2024. Marriage and family therapists and mental health counselors (which includes most LMHC and LPC licenses) can enroll in Medicare Part B and bill independently for diagnosis and treatment of mental illness. You need a qualifying master's or doctoral degree, a current state license, and at least two years or 3,000 hours of post-degree supervised clinical experience.
- How much does Medicare pay an LMFT or LMHC for a therapy session?
- MFTs and MHCs are paid at 75 percent of the clinical psychologist rate. In 2026 the national non-facility fee schedule amount for CPT 90837 is $167.00, so an enrolled LMFT is paid about $125.25 per 60-minute session as a participating provider — roughly $100.20 from Medicare and $25.05 from the patient's 20 percent coinsurance. Locality adjustments move this up or down.
- What is the difference between non-participating and opting out of Medicare?
- A non-participating provider is still enrolled: they can charge up to the limiting charge (115 percent of the reduced non-par fee amount) and Medicare still processes claims. Opting out is a formal affidavit to leave Medicare entirely for two years — you private-contract with Medicare patients at any fee, but no Medicare or Medicare Advantage plan will pay you at all during that period.
- Does Medicare enrollment help with Medicare Advantage panels?
- Yes. Medicare Advantage plans are run by commercial insurers like UnitedHealthcare, Humana, and Aetna, and their behavioral health networks expect providers to be Medicare-eligible and not opted out. Enrolling in original Medicare through PECOS is the practical prerequisite; once enrolled, you apply to each Medicare Advantage network separately through the insurer's normal credentialing process.
- How do I enroll in Medicare through PECOS?
- Create an Identity and Access Management (I&A) account tied to your NPI, then log in at pecos.cms.hhs.gov and start a new application as an individual practitioner — the online equivalent of the CMS-855I. PECOS now lists marriage and family therapist and mental health counselor as selectable specialties. You upload your license and supervised-experience documentation, e-sign, and your Medicare Administrative Contractor processes the file.
Sources
- CMS — MFT and MHC frequently asked questions (enrollment and payment)
- CMS — Marriage and family therapists & mental health counselors (PFS)
- Behave Health — 2026 behavioral health Medicare rates (90834/90837)
- APA Services — opting out of Medicare and private contracting
- Medicare Interactive — participating, non-participating, and opt-out providers
The paneled.ai team · Credentialing specialists. We file and track insurance credentialing applications for behavioral health providers every day — these guides come from what we see go wrong (and right) in real applications.