Several years ago under the National Defense Authorization Act, Congress directed the Secretary of Defense to conduct an independent study of the credentials, preparation, and training of individuals practicing as licensed Mental Health Counselors (MHC) and to make recommendations to allow those MHCs to practice independently under TRICARE. The Institute of Medicine (IOM) of the National Academies of Science subsequently conducted the study, and on July 17, 2014, the Department of Defense issued final regulations based on the IOM recommendations.
New Regulations – Following is a summary of the major provisions of the final DoD regulations:
1. As of January 1, 2017, certification criteria for the newly designated TRICARE Certified Mental Health Counselor (TCMHC) practicing independently include:
a. Master's or higher level degree in mental health or clinical mental health counseling from a Council for Accreditation of Counseling and Related Educational Programs (CACREP) accredited program;
b. State license in mental health counseling at the "clinical" or the higher or highest level in states with tiered licensing;
c. Passage of the National Clinical Mental Health Counseling Examination (NCMHCE).
2. Extension of transition period to December 31, 2016, for MHCs to meet requirements to practice independently.
a. If TCMHCs are authorized during the transition period, they do not have to be reauthorized under the new criteria after January 1, 2017.
b. Mental Health Counselors who meet the certification requirements as TCMHCs before the end of the transition period may apply at any time for TRICARE authorization after the transition period.
c. Providers who do not meet all certification requirements before the end of the transition period must meet the criteria listed in #1 above.
3. Prospective TCMHCs may now be supervised in their post-master's clinical practice experience not only by mental health counselors licensed for independent practice, but also by "multiple, licensed independent mental health professionals, including psychiatrists, clinical psychologists, certified clinical social workers, and certified psychiatric nurse specialists who are licensed for independent practice...and practicing within the scope of their licenses."
4. Beneficiaries will have the choice of services either of a TCMHC providing independent services or a Supervised Mental Health Counselor (SMHC) authorized to provide services pursuant to a physician's referral and ongoing supervision. This provider category originally was to be phased out; however, these regulations continue this category indefinitely. SMHCs generally meet the same criteria as TCMHCs; however, they are not licensed to practice independently and may only be reimbursed if the patient is referred by a physician who supervises the SMHC's provision of therapy and written certification is provided to the supervising physician of the results of treatment.
Implications for DMTs in Independent Practice:
1. CACREP-Accredited Programs: The rules make clear that anyone designated as a TCMHC, i.e., mental health counselor practicing independently, must have an advanced degree from a CACREP-accredited program. In other words, a master's or higher level degree in Dance/Movement Therapy does not suffice unless the program meets this criterion. Currently no DMT programs satisfy this criterion. Therefore, unless the practitioner has a separate counseling degree from an approved program, he/she would not be able to receive the TCMHC designation.
2. "Expressive Arts Therapists": When the proposed regulations were released for public comment, the Department received some requests that licensed professional counselors (LPCs) be allowed to practice independently under TRICARE, include "expressive arts therapists." In response, DoD cited the IOM report which noted most states do not require LPCs to graduate from a "mental health specialty counseling program" in order to be licensed. The Department concludes that "TCMHCs are required to have specified education and training in order to diagnose and treat mental health conditions as individual providers of care," and therefore disallows these 'specialty' practices as TCMHCs. However, they note the final regulations retain the SMHC category. Therefore, it appears that in order for services of an independent DMT to be reimbursed, he or she would have to meet the TCMHC criteria, including attending a CACREP-accredited program (or SMHC criteria, if the DMT agreed to physician supervision).
Dance/Movement Therapists and other community leaders were invited to hold a dance event as part of the National Children's Mental Health Awareness Day May 3, 2011. ADTA is proud to be a collaborating organization with SAMHSA, the Substance Abuse and Mental Health Services Administration, a federal agency. The theme of the 2011 Awareness Day concerned promoting resilience in children and teens. Click the icon to the left to visit the SAMHSA webpage for more resources and information. Also, view the Tipsheet: Promoting Resilience through Dance.
Read ADTA President Sherry Goodill's guest blog entry for the National Endowment for the Arts (NEA) on dance and dance/movement therapy in conjunction with SAMSHA's National Children's Mental Health Day!
The ADTA was proud to be a participant in Arts Advocacy Day, a public awareness project of the American for the Arts, on Monday and Tuesday, April 4th - 5th. This was a collaboration with the other creative arts therapy organizations, the Society for Arts in Healthcare, and many other national entities. Please click here for the DMT research articles referenced in the Advocacy Day 2011 document, "Field at a Glance."