American Counseling Association of Missouri

The Department of Defense issued regulations at the end of 2011 (online at http://www.gpo.gov/fdsys/pkg/FR-2011-12-27/pdf/2011-33109.pdf) which would let licensed professional counselors practice independently within TRICARE, the health care program providing services for an estimated 9.6 million active duty service members, retirees, and their families.  For many years, all other master’s level mental health professionals have been allowed to practice independently, while TRICARE beneficiaries can only see licensed professional counselors under physician referral and supervision.

Current Referral and Supervision Requirements Still In Effect

Although the rule stated that it was “effective” on December 27, 2011, it now appears that counselors will not be able to see TRICARE beneficiaries independently for a few months.  According to staff with the TRICARE Management Activity (TMA, the agency charged with managing the program), the Department of Defense is maintaining existing requirements for physician referral and supervision of counselors’ services until it has reviewed comments on the regulation and made any final changes it deems necessary in light of the comments it receives.  DoD staff indicate that TMA expects to finish this process and begin implementing the regulations later this year.

ACA encourages counselors interested in this issue to submit comments.  Comments must be submitted by February 27th.  You can do this through the website http://www.regulations.gov.  In the drop-down box in the middle of the page entitled “Select Document Type”, select “Rule”, and in the box next to it entitled “Enter Keyword or ID” type in “certified mental health counselors”.  Click “Search”, and the top result listed on the page that comes up 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.

• An expression of strong support for DoD’s proposed transition period, during which counselors with degrees from programs that have not yet become CACREP-accredited can apply for certification as independently-practicing mental health counselors;
• A request that TRICARE recognize all relevant counseling master’s degree titles for practice as a mental health counselor;
• A request that TRICARE recognize all supervised experience obtained by counselors that meets the criteria used by the licensure board for the jurisdiction in which they practice;
• A request that TRICARE consider extending the transition period—during which the agency will certify counselors with degrees from regionally-accredited institutions who have passed the NCMHCE, and counselors with degrees from CACREP-accredited programs who have passed the NCE—through December 31, 2015.  This would be especially helpful if the DoD regulations aren’t implemented until the end of 2012. 

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