Guide for Washington clinicians
Medicare enrollment for mental health counselors and MFTs in Washington
Last reviewed: October 19, 2026
Since January 1, 2024, Medicare Part B covers services from licensed mental health counselors and marriage and family therapists. For the first time, LMHCs and LMFTs can enroll as Medicare providers and bill Medicare directly. If many of your clients are older adults, that's a big change. Here's what it means if you practice in Washington.
Who can enroll
Medicare's rules for counselors and MFTs have three requirements. You need:
- A master's or doctoral degree that qualifies for licensure as a mental health counselor or marriage and family therapist in your state.
- At least 2 years or 3,000 hours of post-master's supervised clinical experience in an appropriate setting, such as a clinic, hospital, or private practice.
- A current license in the state where you see clients. In Washington, that's an LMHC or LMFT license.
What about associates (LMHCA, LMFTA)?
Associates can't enroll in Medicare, because Medicare requires a full license. That means Medicare can't pay for an associate's sessions under the associate's own name.
You may hear about "incident to" billing, where a supervising practitioner bills Medicare for services provided by staff they supervise. It's narrow. Under Medicare's rules, the practitioner who supervises and bills has to be a physician or a practitioner such as a nurse practitioner or physician assistant. That practitioner must have seen the patient and stay actively involved in their care. A fully licensed counselor can't bill Medicare this way for an associate. If you're considering a setup like this, confirm it with Medicare or a Medicare billing expert first.
Once your full license is issued, you can enroll yourself. See our timeline for getting credentialed after full licensure.
How enrollment works
- NPI: you use your existing individual NPI. You don't need a new one when you become fully licensed. Just make sure the practice address is current.
- Application: you apply through Medicare's provider enrollment process. In Washington, Medicare claims and enrollment are handled by Noridian, the Medicare contractor for our region (Jurisdiction F).
- Assignment: enrolled counselors and MFTs must accept Medicare's approved amount as payment in full.
- Working in a group: if a group practice bills for you, the group's Medicare enrollment also needs to be linked to yours.
How Medicare pays
Medicare pays counselors and MFTs 75% of the amount it pays clinical psychologists for the same services under its physician fee schedule. Rates vary by service and location.
Medicare Advantage plans
Many older adults have a Medicare Advantage plan from a private insurer instead of Original Medicare. Each Medicare Advantage plan has its own network and its own credentialing application, separate from your Medicare enrollment. If your clients use several plans, you'll likely need to apply to each one.
Clients with both Medicare and Apple Health
Some older adults have both Medicare and Apple Health (Medicaid). Medicare is generally billed first, and Apple Health may cover what's left. To serve these clients fully, you'll usually want to be enrolled with both.
Common questions
Can I see Medicare clients privately before I'm enrolled?
Be careful here. Medicare has strict rules about charging Medicare patients privately for services Medicare covers. Generally, private arrangements are only allowed if you've formally opted out of Medicare. Opting out is a two-year commitment, and during that time neither you nor your client can bill Medicare for your services. Check with Noridian before seeing Medicare clients privately.
Do I need a new NPI?
No. Your individual NPI stays with you for your whole career. It only needs updating when details like your practice address change.
Is this the same as getting on commercial insurance panels?
No. Medicare enrollment is its own process, separate from CAQH and from commercial insurers like Premera or Regence. Many clinicians do both.
How we can help
Start with a free 15-minute readiness check. We'll look at your license, NPI, CAQH profile, and malpractice coverage, and talk through where Medicare fits with the rest of your plan. Medicare and Medicare Advantage enrollment is quoted separately from our standard packages.
Sources
- CMS: Marriage and family therapists and mental health counselors
- Noridian (Medicare contractor for Washington): MFT and MHC enrollment and billing
- CMS: "Incident to" services and supplies
This page is general information, not legal or billing advice. Medicare rules change, so check the sources above or ask Noridian about your situation.