Effective January 1, 2024
Beginning January 1, the Medicare program began covering services provided to Medicare beneficiaries by marriage and family therapists (MFT) and mental health counselors (MHC), and Intensive Outpatient Program (IOP) services authorized under Sections 4121 and 4124 of the Consolidated Appropriations Act of 2023. These provisions are implemented as part of two recently published final rules:
As of January 1, Medicare became the primary payer for Medicare-covered services furnished by MFTs and MHCs to individuals who are eligible for both Medicare and Medicaid. Additionally, Medicare became the primary payer for IOP services furnished to individuals eligible for Medicare and Medicaid by hospital outpatient departments, Medicare community mental health centers (CMHC), opioid treatment programs, rural health clinics (RHC), and federally qualified health centers (FQHC).
CMS recently provided guidance to states regarding coordination of benefits between Medicare and Medicaid and third-party liability under the Medicaid program. In accordance with this guidance, to allow providers time to complete the Medicare enrollment process:
- Ohio Department of Medicaid and MyCare Ohio plans will continue to pay claims for services to Medicaid enrollees with dual Medicare and Medicaid eligibility for impacted providers and services for claims submitted through June 30, 2024.
- Once practitioners are enrolled with Medicare, claims must be submitted to Medicare prior to seeking cost-sharing reimbursement from Medicaid, starting on the effective date of the provider’s enrollment with Medicare.
For any payments made by Medicaid (before or after June 30, 2024), including payments made by Medicaid managed care entities, if Medicare is later found to be the liable payor because the provider’s Medicare enrollment was active and the service was Medicare-covered, the Medicaid payment will be recouped as required by CMS.
To ensure secondary payments by Medicaid can be made, eligible practitioners that provide services to individuals who are eligible for Medicare and Medicaid should also be enrolled with Medicare. Eligible practitioners can apply to become Medicare providers through the Provider Enrollment Chain and Ownership System (PECOS) at Provider Enrollment Chain, and Ownership System (PECOS). The PECOS website offers tutorials regarding enrollment in Medicare.
Information on CMS’ coverage of these new Medicare providers is found below:
https://www.medicaid.gov/sites/default/files/2023-12/cib12142023.pdf
https://www.cms.gov/files/document/marriage-and-family-therapists-and-mental-health-counselors-faq-09052023.pdf
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