Behavioral health is one of the most complex areas of Medicare enrollment — not because the forms are different, but because covered services, independent practice authority, and supervision requirements vary significantly by credential. A clinical psychologist, an LCSW, an LMHC, and a psychiatrist all enroll via the same CMS-855I, but bill very different sets of codes with very different constraints.
This guide maps each behavioral health provider type to what Medicare actually covers — and what it doesn’t.
Provider types and Medicare status
| Provider | Medicare status | Independent billing | Requires referral | Supervision required |
|---|---|---|---|---|
| Psychiatrist (MD/DO) | Full physician | ✅ | No | No |
| Clinical Psychologist (PhD/PsyD) | Non-physician practitioner | ✅ | No | No |
| Licensed Clinical Social Worker (LCSW) | Non-physician practitioner | ✅ | No | No |
| Licensed Mental Health Counselor (LMHC) | Non-physician practitioner | ✅ | No | No |
| Marriage & Family Therapist (MFT/LMFT) | Non-physician practitioner | ✅ | No | No |
| Psychiatric NP | Non-physician practitioner | ✅ (as NP) | No | State-dependent |
| Licensed Professional Counselor (LPC) | Not covered | ❌ | — | — |
| Certified Counselors (non-licensed) | Not covered | ❌ | — | — |
⚠️ Important: LPCs, certified counselors, and other non-licensed or sub-clinical-license mental health workers are not Medicare-enrolled provider types. Services provided by these practitioners cannot be billed to Medicare, even incident-to a supervising physician, for mental health services. (Standard medical incident-to rules apply only to medical services in a physician’s office, not to mental health services.)
Covered services by provider type
All of the independently-billable behavioral health providers above can bill the core psychotherapy codes:
- 90791 — Psychiatric diagnostic evaluation (without medical services)
- 90832 — Individual psychotherapy, 16-37 min
- 90834 — Individual psychotherapy, 38-52 min
- 90837 — Individual psychotherapy, 53+ min
- 90846 — Family psychotherapy without patient
- 90847 — Family psychotherapy with patient
- 90853 — Group psychotherapy
- 90839/90840 — Crisis psychotherapy
Psychiatrists only additionally:
- 90792 — Psychiatric diagnostic evaluation with medical services
- E&M codes (99202-99215) for medication management
- Add-on codes (90833, 90836, 90838) for combined E&M + psychotherapy
Clinical psychologists only additionally:
- 96130-96139 — Psychological and neuropsychological testing
- 96156, 96158, 96159, 96164, 96165, 96167, 96168, 96170, 96171 — Health and behavior assessment/intervention
Medicare Advantage behavioral health: the carve-out problem
Many Medicare Advantage plans carve behavioral health to a separate managed behavioral health organization (MBHO):
- Beacon Health Options (now Carelon Behavioral Health) — manages behavioral health for several major MA plans
- Evernorth (Cigna) — separate credentialing and PA from the MA plan
- MHNet Behavioral Health — used by some regional and specialty plans
- Optum Behavioral (UHC) — manages UHC MA behavioral health for many plans
If your MA plan carves behavioral health, you may need to credential with the MBHO separately from the MA plan — effectively two credentialing processes, two prior authorization processes, and two fee schedules for the same patient.
⚠️ Risk flag: Verify whether your MA plans carve behavioral health before completing credentialing. Failing to credential with the MBHO means your claims will deny even after the MA plan accepts you.
Telehealth and behavioral health
Behavioral health was the primary beneficiary of Medicare’s telehealth expansion. Under current rules:
- Behavioral health telehealth services can be delivered to patients in their homes (not just healthcare facilities)
- Audio-only telehealth is permitted for behavioral health when the patient cannot or does not want to use video
- Mental health visits require an in-person visit within 6 months of the first telehealth service and annually thereafter
The in-person requirement is the most commonly missed compliance point in telehealth behavioral health billing.
Behavioral health and Medicare Advantage network adequacy
CMS’s 2024 network adequacy rules increased the minimum requirements for MA plans to maintain adequate behavioral health provider networks — including maximum time-and-distance standards for mental health specialists. In many markets, behavioral health networks remain inadequate under these standards.
For providers, this means: if an MA plan’s network is under-resourced in your specialty and geography, they may actively seek to credential you, giving you more negotiating leverage than you’d have with a well-staffed specialty.
Guides by behavioral health credential
- Clinical Psychology — full independent billing, testing codes, health and behavior codes
- Licensed Clinical Social Worker (LCSW) — independent billing, core psychotherapy codes
- LMHC Medicare Enrollment — recently approved, enrollment checklist
- Marriage & Family Therapist (MFT) — newly covered, enrollment requirements
- Psychiatry — physician billing, E&M + psychotherapy, combined codes
- Nurse Practitioners (behavioral health) — NPs in behavioral health practice
Ask Mae to identify your credential and walk you through your specific enrollment path and covered services.