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For decades, the list of clinicians who could bill Medicare for mental health services was short and stable: physicians, clinical psychologists, clinical social workers, and a handful of advanced practice clinicians. Congress redrew that list in late 2022, and since January 1, 2024, marriage and family therapists and mental health counselors have held their own billing privileges, a change that made an estimated 400,000 practitioners newly eligible to enroll. Payment tiers, supervision rules, and telehealth policy have all shifted since then. This guide covers who can enroll, what Medicare pays each discipline in 2026, which services carry restrictions, and where new billers most often stumble.

The eight provider types that can bill Medicare for mental health services

Medicare Part B recognizes eight practitioner categories for the diagnosis and treatment of mental illness. Each has its own federal definition, and the definitions matter, because a state license alone does not create Medicare billing rights.

Physicians. Any MD or DO can bill for psychiatric diagnostic evaluations, psychotherapy, and medication management, though psychiatrists furnish most physician-billed behavioral care. Physicians are the only category with no service-level restrictions.

Clinical psychologists. Medicare requires a doctoral degree in psychology plus a state license at the independent practice level. A master’s-level psychologist, or a school psychologist licensed only for educational settings, does not meet the definition regardless of clinical skill.

Clinical social workers. A CSW needs a master’s or doctoral degree in social work, at least two years of supervised clinical experience after the degree, and clinical-level state licensure. The word “clinical” is doing real work here; bachelor’s-level and macro-practice social workers cannot enroll.

Marriage and family therapists and mental health counselors. These are the two newest categories, billable since January 1, 2024, and covered in detail below. Medicare treats “mental health counselor” as an umbrella term. Licensed professional counselors, licensed clinical professional counselors, and licensed mental health counselors all enroll under it, and addiction counselors who satisfy the same education, licensure, and experience tests can enroll as MHCs too.

Nurse practitioners, clinical nurse specialists, and physician assistants. All three bill under their own National Provider Identifiers when state scope-of-practice law allows the service. Psychiatric specialty certification is not a federal condition for NPs or CNSs, although some states impose their own limits. (Certified nurse-midwives also hold Part B billing authority, which matters mainly for perinatal mental health care.)

What changed in January 2024, and why it matters

Section 4121 of the Consolidated Appropriations Act, 2023, signed into law on December 29, 2022, created the MFT and MHC benefit categories. CMS wrote the implementing rules into the calendar year 2024 physician fee schedule, and claims became payable for dates of service on or after January 1, 2024.

Eligibility rests on three requirements:

• a master’s or doctoral degree that qualifies the practitioner for licensure in the state where services are furnished
• a current license or certification from that state
• at least two years, or 3,000 hours, of supervised clinical experience completed after the degree

The 3,000-hour alternative exists because state boards count supervised experience differently. CMS added it during rulemaking so that clinicians licensed under hour-based systems would not be shut out by the two-year phrasing. Where the supervised hours are already built into licensure, the Medicare administrative contractor verifies them from the license itself; where they are not, the applicant submits separate documentation.

The statute reached facility billing as well. Rural health clinics and federally qualified health centers can bill visits furnished by MFTs and MHCs, paid under the all-inclusive rate and the prospective payment system respectively.

One consequence still surprises therapists who built cash-pay practices. Medicare’s mandatory claim submission rule now applies to these disciplines, so a licensed counselor treating a Medicare beneficiary must either enroll and bill the program or file a formal opt-out affidavit. Charging the patient out of pocket without doing either has been prohibited since January 1, 2024.

Who still cannot bill Medicare directly

No benefit category exists for peer support specialists, psychiatric technicians, pastoral counselors without a qualifying clinical license, life coaches, or board certified behavior analysts. Pre-licensed clinicians, meaning associates, registered interns, and anyone still accruing supervised hours, cannot enroll either, because full state licensure is a threshold requirement for every category above.

A partial workaround exists. Under incident-to billing, services performed by auxiliary personnel can be billed under a supervising physician’s or nonphysician practitioner’s number at 100 percent of the fee schedule rate, provided the billing clinician initiated the treatment plan and remains involved in the patient’s care. The supervision standard for behavioral health is looser than many billers assume. In the 2023 physician fee schedule final rule, CMS permitted general supervision (the supervising clinician reachable but not physically on site) for behavioral health services furnished incident to a practitioner’s services, an exception to the direct supervision rule that still governs most other incident-to arrangements.

How much Medicare pays each provider type

Payment amounts depend on the biller’s credential rather than on the service itself. Two clinicians can submit the same CPT code for the same session length and receive different amounts.

Dollar values flow from the conversion factor, and 2026 brought a structural change there. The final rule CMS released on October 31, 2025 set two conversion factors for the first time: $33.5675 for clinicians who are qualifying participants in advanced alternative payment models, and $33.4009 for everyone else, increases of 3.77 percent and 3.26 percent over 2025. Both figures include a one-year 2.5 percent increase Congress ordered in the July 2025 reconciliation law, so nothing guarantees the 2027 baseline will hold.

Beneficiary cost sharing follows the standard Part B pattern: Medicare pays 80 percent of the approved amount after the annual deductible, and the patient owes 20 percent. That parity is newer than most people realize. Outpatient psychotherapy carried 50 percent coinsurance until the Medicare Improvements for Patients and Providers Act of 2008 began phasing it down, and the rate did not reach 20 percent until 2014.

One inpatient rule from 1965 also survives. Medicare Part A covers a lifetime maximum of 190 days of care in a freestanding psychiatric hospital, a cap applied to no other hospital type. Psychiatric units inside general hospitals are exempt from it.

Enrollment, participation status, and the opt-out decision

Enrollment runs through three systems in sequence. The practitioner obtains a National Provider Identifier through NPPES, submits the CMS-855I application through PECOS or on paper, and works with the Medicare administrative contractor for the state where they hold a license and see patients. Practicing in states served by different MACs means filing separate enrollments with each one. Processing commonly takes several weeks to a few months, and enrolled providers revalidate every five years.

Enrollment then forces a choice among three statuses:

• Participating providers accept the Medicare approved amount as payment in full on every claim.
• Non-participating providers are paid 95 percent of the fee schedule amount and may balance bill patients up to the limiting charge, which is 115 percent of that reduced figure.
• Opt-out providers file an affidavit with their MAC, sign private contracts with Medicare patients, and forgo Medicare billing entirely for renewable two-year terms.

Opt-out behavior is where mental health diverges sharply from the rest of medicine. A KFF analysis of CMS data, published in 2025, found that 12,244 non-pediatric physicians, or 1.2 percent of the active total, had opted out of Medicare as of November 2024. Psychiatry led every specialty at 8.1 percent, and psychiatrists alone accounted for 39 percent of all physician opt-outs. The practical lesson for billers: once an opt-out affidavit is on file, nobody, including the patient, can submit a Medicare claim for that clinician’s services.

Codes and service restrictions by discipline

All eight eligible provider types may bill Medicare for psychiatric diagnostic evaluations (90791), individual psychotherapy services lasting 30, 45, or 60 minutes (90832, 90834, and 90837), crisis psychotherapy (90839 and 90840), family psychotherapy (90846 and 90847), and group psychotherapy (90853). The restrictions cluster in three areas:

• Evaluation and management. Office visit codes (99202 through 99215) and the diagnostic evaluation with medical services (90792) are payable only to physicians, NPs, CNSs, and PAs. Psychologists, CSWs, MFTs, and MHCs cannot bill E/M, which is why medication management stays with prescribers.
• Testing. Psychological and neuropsychological testing codes are payable to clinical psychologists and physicians, and to NPs, CNSs, and PAs where state scope allows, but never to CSWs, MFTs, or MHCs.
• Bundled settings. Clinical social worker services furnished to a skilled nursing facility resident during a covered Part A stay fall under SNF consolidated billing and cannot be billed separately.

The 2024 fee schedule also opened health behavior assessment and intervention codes (96156 through 96171) to CSWs, MFTs, and MHCs, which lets them bill for psychological care of patients whose primary diagnosis is a physical condition.

Telehealth billing rules through 2027

Telehealth policy spent late 2025 and early 2026 lurching between funding deadlines, so the current rules deserve a careful read. The Consolidated Appropriations Act for fiscal year 2026, signed on February 3, 2026, extended the major Medicare telehealth flexibilities through December 31, 2027 and applied the extension retroactively, keeping claims from the brief early-2026 lapse payable.

For mental health billing, the rules as of mid-2026 are:

• Beneficiaries can receive behavioral telehealth at home, anywhere in the country, with no geographic or originating-site limits through December 31, 2027.
• The statutory requirement for an in-person visit one within six months before the first home-based mental health telehealth service and then at least once every 12 months has been suspended through December 31, 2027. Under CMS guidance, patients who begin receiving telehealth services before that date are considered established patients and will only be subject to the annual in-person visit requirement after enforcement resumes. 
• Audio-only visits for mental health care at home are permanently allowed when the practitioner has audio-video capability but the patient cannot use video or does not consent to it.
• FQHCs and RHCs face no in-person requirement for behavioral telehealth until at least January 1, 2028.
• Prescribers face a separate clock: the DEA flexibility permitting controlled substance prescribing via telehealth without a prior in-person exam currently runs through December 31, 2026.

Use Place of Service (POS) code 10 when the patient receives care at home and POS 02 when the service is provided from any other telehealth location. Also, verify modifier requirements with your Medicare Administrative Contractor (MAC), as audio-only telehealth claims are subject to separate coding rules.

What to remember before submitting a first claim

Eight disciplines can bill Medicare for mental health services in 2026: physicians, clinical psychologists, clinical social workers, marriage and family therapists, mental health counselors, nurse practitioners, clinical nurse specialists, and physician assistants. Payment lands at 100, 85, or 75 percent of the fee schedule depending on the credential, calculated against conversion factors of $33.5675 or $33.4009. Enrollment requires an NPI, a CMS-855I application, and full state licensure, plus two years or 3,000 hours of supervised experience for the master’s-level therapy disciplines. Telehealth flexibilities hold through the end of 2027, with the in-person visit requirement suspended until then. Because enrollment processing takes weeks at minimum, clinicians planning to treat Medicare patients should file early and confirm their effective date with the MAC before booking the first appointment.