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TRICARE Rules Regarding Independent Practice:
Licensed Mental Health Counselors in Private Practice

Answer to Question: How does a licensed counselor qualify to provide counseling services for the health care program serving uniformed service members, retirees and their families--commonly known as TRICARE?

Rules regarding the independent practice of licensed counselors providing services to TRICARE beneficiaries (uniformed service members, retirees and their families worldwide).

TRICARE is the name of the health care system for service members and their dependents in the United States Department of Defense Military Health System. TRICARE was formerly known as the Civilian Health and Medical Program of the Uniformed Services (CHAMPUS).

1/04/12: The National Board for Certified Counselors, Inc. (NBCC) is providing the following important alert regarding recent changes released by the Department of Defense. The changes relate specifically to the provision of mental health services to TRICARE beneficiaries. TRICARE is the health care program serving uniformed service members, retirees and their families worldwide.

NCCs following this issue will recall that under previous TRICARE regulations, licensed counselors were required to obtain a physician's referral and supervision prior to providing mental health services to beneficiaries. (For more information about the history of this advocacy effort, please visit http://www.nbcc.org/About/AdvocacyUpdates.)

On December 27, 2011, the Department of Defense released the interim final rule regarding the independent practice of licensed counselors providing services to TRICARE beneficiaries. Briefly, this rule:

  1. Creates a new category of health professionals authorized to practice independently under TRICARE. These professionals will be known as certified mental health counselors (CMHCs). (NOTE: This is not NBCC's voluntary credential, the certified clinical mental health counselor (CCMHC).)
  2. Identifies criteria for the identification of CMHCs.
  3. Establishes a transition period from December 27, 2011, to December 31, 2014.

Additional Details: Licensed counselors who are recognized by the Department of Defense as CMHCs will be allowed to practice autonomously (i.e., without a physician's referral and supervision) and receive third-party reimbursement.

During the transition period from December 27, 2011, to December 31, 2014

  • Licensed counselors who do not meet the requirements for the newly established category of CMHC may continue to provide services to TRICARE beneficiaries under the previous requirement of physician referral and supervision. (However, beginning January 1, 2015, the Department of Defense will no longer recognize those counselors who do not meet the criteria of CMHC, even with the referral and supervision of a physician.) The criteria for the CMHC include the following:
  • Possession of a state license for independent practice in mental health counseling issued by the jurisdiction in which the individual is practicing. In jurisdictions with two or more licenses allowing for differing scopes of independent practice, the licensed mental health counselor may only practice within the scope of the license he or she possesses.
  • Possession of a master's degree or higher from a mental health counseling education and training program accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) and a passing score on the National Counselor Examination for Licensure and Certification (NCE) OR Possession of a master's degree or higher from a mental health counseling education and training program that is either CACREP accredited or from a regionally accredited institution, and a passing score on the National Clinical Mental Health Counseling Examination (NCMHCE).
  • A minimum of two (2) years of post-master's degree supervised mental health counseling practice that includes a minimum of 3,000 hours of supervised clinical practice and 100 hours of face-to-face supervision. Required supervision must be provided by a mental health counselor who is licensed for independent practice in mental health counseling in the jurisdiction in which he or she is practicing and must be conducted in a manner that is consistent with the American Mental Health Counselors Association (AMHCA) guidelines for supervision. (see webmaster note, below.)

Beginning January 1, 2015

  • Only those licensed counselors recognized as CMHCs will be authorized to provide services to TRICARE beneficiaries.
  • The criteria for the CMHC change to the following:
  • Possession of a state license for independent practice in mental health counseling issued by the jurisdiction in which the individual is practicing. In jurisdictions with two or more licenses allowing for differing scopes of independent practice, the licensed mental health counselor may only practice within the scope of the license he or she possesses. Possession of a master's degree or higher from a mental health counseling education and training program accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP).
  • A passing score on the National Clinical Mental Health Counseling Examination (NCMHCE) or its successor as determined by TRICARE.
  • A minimum of two (2) years of post-master's degree supervised mental health counseling practice that includes a minimum of 3,000 hours of supervised clinical practice and 100 hours of face-to-face supervision. Required supervision must be provided by a mental health counselor who is licensed for independent practice in mental health counseling in the jurisdiction in which he or she is practicing and must be conducted in a manner that is consistent with the American Mental Health Counselors Association guidelines for supervision. (see webmaster note, below.)

NBCC has created an expedited examination registration form for counselors wishing to take the NCMHCE for the purpose of serving the military. Interested counselors can download and submit the form posted on the NBCC Web site: http://www.nbcc.org/Assets/RegistrationForm/NCMHCERegistrationForm.pdf

NBCC is creating a similar examination registration process for those interested in taking the NCE during the transition period established by the Department of Defense. This application should be available within the month.

Questions regarding registering for an NBCC examination should be directed to examinations@nbcc.org.

NBCC, the American Counseling Association (ACA) and AMHCA have been advocating on behalf of the counseling profession for years. NBCC is pleased with this most recent accomplishment and will continue to advocate for the inclusion of qualified counselors.


Webmaster note RE: AMHCA Supervisor Standards

“AMHCA recommends at least 24 continuing education hours or equivalent graduate credit hours of training in the theory and practice of clinical supervision for those Clinical Mental Health Counselors who provide pre-degree or post degree clinical supervision to CMHC students or trainees. AMHCA Recommends that Clinical Supervisors obtain, on the average, at least 3 continuing education hours in supervision per year as part of their overall program of continuing education. Clinical supervisors should meet the following knowledge and skills criteria. Read complete supervisor requirements on pages 7 to 9, in a .pdf file titled, "STANDARDS for the Practice of Clinical Mental Health Counseling."

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