Washington, DC – February 23, 2012 – Comments are due late on Monday, February 27, 2012, on interim TRICARE rules authorizing independent provider status for certified mental health counselors (CMHC). AMHCA has submitted its comments, and now we are urging all members to comment individually to reinforce mental health counselor concerns. Comments should be submitted on-line by 11:59 PM EST, February 27, 2012. Although AMHCA has submitted comments on behalf of the profession, it will strengthen the voice of mental health counseling if practitioners send individual comments. A summary of our comment letter and suggested talking points follow.
Express support for DoD/TRICARE's inclusion of a transition period for CACREP accreditation of clinical mental health counseling programs. Recognize that during the transition period, clinical mental health counselors with degrees from programs that were not CACREP-accredited may qualify for independent practice as a CMHC provided they pass a national exam (NCMHCE).
Emphasize that TRICARE's transition period to CACREP accreditation is too short (3 years authorized) and that a total of seven years is necessary to transition mental health counseling schools and their recent graduates.
Request that TRICARE verify qualified clinical mental health counselor degrees; the credentialing process should include verification that CMHCs have received adequate coursework in the diagnosis and treatment of mental disorders.
Urge that it is crucial for TRICARE to recognize supervised experience obtained from psychiatrists, clinical psychologists, clinical social workers, and licensed mental health therapists. Criteria for clinical supervision should be consistent with AMHCA's standards, which do not require that pre-licensure clinical supervision may only be provided by a mental health counselor.
Instructions for Submitting Comments
Go to this agency comment website and in the search box enter, "TRICARE certified mental health counselors." Then click "Search." The top result listed should be entitled "TRICARE: Certified Mental Health Counselors." You'll see a link for "Submit a Comment" on the right-hand side of the page. All submissions received must include the agency name and docket number or RIN for this Federal Register document. Be sure your comments provide the RIN docket number: RIN 0720-AB55. Comments become available for public viewing on the Internet as they are received without change, including any personal identifiers or contact information.
The DoD/TRICARE office is now writing administrative procedures that will interpret and implement recent certified mental health counselor (CMHC) rules for the TRICARE program. The TRICARE Intermediary cannot process new CMHC provider applications until these administrative procedures are issued, hopefully within the next few months. Public comments provide rule makers with an avenue to make improvements or clarifications in the interim rules.
The new rules will require CACREP accreditation standards for schools and passage of the National Clinical Mental Health Counseling Examination (NCMHCE) by qualified TRICARE practitioners. Both requirements are critical new national standards for the profession. These standards were taken directly from an Institute of Medicine (IOM) recommendation issued in 2010. The IOM report found that additional quality standards are necessary for clinical mental health counselors who wish to practice independently in the TRICARE program. IOM quality recommendations are very influential within the federal government and have already been adopted by the Veterans Administration and the Department of Defense. Thus the IOM quality standards have already become the de facto criteria for federal government employment or reimbursement. Despite AMHCA's prior efforts, it is now evident that national education accreditation and quality standards are obligatory.
AMHCA believes national standards will optimize opportunities for licensure portability among the states and strengthen the case for recognition under Medicare, the profession's last major remaining challenge. National accreditation standards are required for the other health professions that participate in federal programs including medicine, nursing, psychology, and social work. Each of these professions has long adhered to one national educational accreditation standard recognized by the federal government. AMHCA believes national accreditation of mental health counselor training programs is an essential step to advance national recognition of clinical mental health counseling. Our goal is to manage this transition with a practical and flexible grandfather so that all well-qualified current practitioners can participate fully within federal programs. AMHCA will provide further updates when we have new information.
Contact James K. Finley, AMHCA Director of Public Policy, at 800-326-2642, X-105, or via e-mail.