We have just become aware that the Centers for Medicare and Medicaid services (CMS) has drafted language into the SUPPORT Act implementation and are requesting comments from the public. The provision from the proposed rule which identifies Licensed Professional Counselors (LPC’s) as providers within Opioid Treatment Programs (OTP’s) is below:

“Under the SAMSHA certification standards at §?8.12(f)(5), OTPs must provide adequate substance abuse counseling to each patient as clinically necessary. We note that section 1861(jjj)(1)(C) of the Act, as added by section 2005(b) of the SUPPORT Act defines OUD treatment services as including “substance use counseling by a professional to the extent authorized under state law to furnish such services.” Therefore, professionals furnishing therapy or counseling services for OUD treatment must be operating within state law and scope of practice. These professionals could include licensed professional counselors, licensed clinical alcohol and drug counselors, and certified peer specialists that are permitted to furnish this type of therapy or counseling by state law and scope of practice. To the extent that the individuals furnishing therapy or counseling services are not authorized under state law to furnish such services, the therapy or counseling services would not be covered as OUD treatment services. “ 

This language specifically names licensed professional counselors as Medicare-eligible OTP providers and is clearly articulated. This would be a huge development, not only for those counselors involved in opioid treatment programs, but in our larger push for inclusion as Medicare-eligible providers.
The Iowa Mental Health Counselors Association (IMHCA) is asking that everyone submit comments. As a mental health care provider, you know the importance of being able to access mental and behavioral health services.  It is extremely important that your voices are heard!!
Please submit your comments online  by the deadline Friday September 27, 2019 by 5:00pm (EST).

Thank you for your attention to this! Let’s increase awareness for the services that Licensed Clinical Mental Health Counselors can provide! Happy advocating!