acaLogo3012The Department of Defense (DoD) has clarified aspects of its interim final rule (IFR) establishing certification criteria for licensed mental health counselors participating in the TRICARE program, in response to a request submitted by ACA. In a letter to ACA Executive Director Richard Yep, Assistant Deputy Director Mary Kaye Justis confirmed that counselors who meet the education, examination and supervision requirements in effect during the transition period – now through Dec. 31, 2014 – will continue to be recognized as independently practicing mental health counselors after the transition period ends. ACA asked DoD to clarify this issue because several members were being told that they would not be recognized after the transition period ended. DoD’s letter expressed appreciation to ACA for bringing this issue to their attention, and stated “We have discussed this issue with the TRICARE Regional Offices to ensure accurate implementation of the IFR by the Managed Care Support Contractors who interface with applicants.”

During the transition period, the IFR allows certification of counselors with a degree from a regionally (but not CACREP) accredited program, completion of 2 years/3,000 hours of post-master’s supervised experience, and passage of the National Clinical Mental Health Counseling Exam (NCMHCE). When the transition period ends, on Jan. 1, 2015, the certification criteria will require that counseling degrees be from CACREP accredited programs.

In its letter, DoD stated that counselors wishing to become certified as mental health counselors within TRICARE under the transition period requirements must complete those requirements before the transition period ends. However, “…while these certification requirements must be completed prior to Jan. 1, 2015, the IFR permits an applicant to become a CMHC [certified mental health counselor] after the transition period if all of the certification requirements were completed before the end of the transition period.” [emphasis in original]

ACA has confirmed with DoD staff that while completing the requirements must happen before January 1, 2015, counselors can become certified after that date. ACA has asked DoD to consider both extending the transition period and to allow counselors to complete the supervision and examination requirements after Jan. 1, 2015, as long as they have met the degree requirement (which does not require CACREP accreditation) during the transition period. The supervision and examination requirements in effect beginning in 2015 are the same as are required of counselors with regionally accredited degrees during the transition period.

According to DoD staff, the agency will issue a final rule on counselor certification, which may include changes to the requirements.  There is no word yet on when the final rule will be released.

In other news, TRICARE will be impacted by the sequestration taking place across most federal programs and agencies.  TRICARE staff and civilian personnel may be furloughed for one day a week, constituting a 20% pay cut.  Contracts, however, should not be affected.  It is unclear at this point if, or how, TRICARE reimbursement rates will be affected by sequestration.

For more information on TRICARE issues, contact Scott Barstow with ACA at


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