Grassroots Action Center


Medicare: Updated Information on Enrolling, Opting Out, or Not Participating
April 4, 2024 by NBCC Government Affairs

Important Note: If you have already opted out, you have 90 days from the date of your signed opt-out affidavit to reverse that decision and enroll in Medicare. 

The Medicare program is essential to the health of some of our country’s most vulnerable citizens. The addition of counselors to Medicare enables counselors to be powerful contributors to the systems of care serving these clients and helping keep communities healthy, well, and engaged instead of isolated. Counselors serving clients in the Medicare system expands access to mental health services and highlights the importance of mental health across the lifespan. 

Of course, this achievement marks a major change, and many counselors have questions about what this means for them. One of those questions is, “Am I required to either enroll or opt out of the Medicare program?”  

In March 2024 the Centers for Medicare & Medicaid Services (CMS) addressed this question in an FAQ document. Question #40 states: Physicians and non-physician practitioners who will not see Medicare patients, are not required to enroll or opt-out of Medicare.”  

Mental health counselors are considered non-physician practitioners and so are not required to take any action if they do not accept Medicare clients. However, counselors should consider the implications before deciding not to treat any Medicare beneficiaries.  

Implications for Neither Enrolling nor Opting Out of Medicare 

Who is your client base?  

Review your current client base to determine if any may age into the Medicare program soon. If you do not enroll or opt out, you will not be able to treat them, and they will need to make arrangements to see another mental health provider when they become Medicare eligible. 

If you do not enroll OR opt out, can you treat new Medicare beneficiaries? 

No, you will not be able to treat any new Medicare beneficiaries who reach out to you for care. You also cannot provide pro bono services to this population. 

How many people does the Medicare program serve?  

Projections show that by 2030, there will be approximately 72 million people in the Medicare program. Currently, over 20% of the Medicare population has a mental health condition. Opting in allows you to leverage your expertise to help these clients and their families and communities access resources critical for health and wellness. Not enrolling or opting out of the Medicare program could impact your practice and client base as more and more people transition into Medicare. 

Medicare often sets trends for other insurers.  

CMS will continue to move toward “Medicare value-based care systems,” such as accountable care organizations, prospective reimbursement systems, and like models of care delivery, in the traditional Medicare program. Many private sector health plans are following Medicare’s lead in implementing these new care delivery models. If you lock yourself out of the Medicare system, it may have ramifications for your practice in the long term, as other mental health providers could have a leg up and more experience working with these new systems.  

Implications for Opting Out 

What about my contracts with other health insurance companies, telehealth providers, hospitals, and employers?  

Contracts with health plans and health insurance companies, hospitals, clinics, employers (and other stakeholders) may require you to be a participating Medicare provider. Opting out of Medicare could therefore jeopardize or violate your contractual obligations with payers and put other aspects of your practice (e.g., credentialing) at risk. Please review your contracts to confirm that participation in Medicare is not required and, if it is, the consequences if you choose to opt out or not participate. 

Medicare sets an example.  

Many private health plans look to Medicare as the measuring stick for credentialing providers. For counselors, having Medicare credentialing status could elevate your practice in the community, in mental health service systems, and with public and private sector payers. 

What about Medicare Advantage plans?  

Providers who opt out can develop individual payment contracts with some Medicare clients but cannot treat Medicare Advantage beneficiaries. The Kaiser Family Foundation projects that 60% of the Medicare population (or about 43 million beneficiaries) will be enrolled in Medicare Advantage health plans by 2030. By opting out, you can only treat a limited number of Medicare beneficiaries and the others will miss out on the key expertise you bring to counseling.   

What is the reason to opt out?  

The reason to opt out of Medicare is to instead treat Medicare beneficiaries under private individual payment contract arrangements for covered Medicare services. 

Conclusion 

There are additional factors to consider when deciding to opt out, enroll, or not see any Medicare clients at all. For example, is opting out or not seeing any Medicare clients consistent with your practice philosophy? Will it increase or decrease your job satisfaction? How will it affect your practice’s reputation in the community? Will this decision affect the way you market your practice? 

The decision to opt out, enroll, or do neither has important long- and short-term ramifications for your practice. NBCC will continue to provide information on the implementation of Medicare Part B coverage of mental health counselors. 

Remember: If you have opted out, you have 90 days from the date of your signed opt-out affidavit to reverse that decision and enroll in Medicare. 

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