Research · Medicare · National · verified August 2026
Integrated care only works if the enrollment is right.
When a mental health clinician joins a medical practice, three questions come up quickly: who needs Medicare enrollment, what role is each person doing, and whose name goes on the claim?
Counselors and marriage and family therapists have been eligible to enroll in Medicare since January 2024. But billing independently, working in an incident-to arrangement, and working in Collaborative Care do not all work the same way.
The Cheat-Sheet starts with the enrollment path.
Complimentary from the Center
The Medicare Enrollment Cheat-Sheet
A plain-language starting point for counselors and MFTs who need Medicare enrollment, whether for independent practice or an integrated-care arrangement.
PECOS path · participation choice · specialty code · payment lookup · CMS sources
No form between you and the Cheat-Sheet. It is yours either way.
Figure 01
Same clinician. Three different billing arrangements.
The role, the enrollment, and the claim can change depending on the arrangement.
Billing independently
The counselor or MFT is the Medicare practitioner, providing and billing their own covered professional service.
Claim in the clinician’s own name
In an incident-to arrangement
A service may be billed through the medical provider, but only when Medicare’s specific incident-to requirements are met.
Claim billed under the applicable incident-to rules
In Collaborative Care
The clinician may serve as the care manager on the team, if the role and arrangement meet the model’s requirements. The medical billing practitioner bills the monthly Collaborative Care service.
Monthly team service, billed by the practice
Enrollment, billing, and the job being performed are related questions. They are not the same question.
Before you enroll
Separate three questions before you build the arrangement.
01
Who is doing the work?
A counselor, an MFT, a behavioral health care manager, the medical provider, the psychiatric consultant. The role has to be named before anything else can be answered.
02
Who needs Medicare enrollment?
That depends on the person’s role and on the service being billed. It is not the same answer in every arrangement.
03
Whose name is on the claim?
Independent therapy, incident-to services, and Collaborative Care follow different billing structures.
Do not answer question three by guessing from question one.
The guides explain the models. The Cheat-Sheet explains the enrollment starting point. Implementation tools go deeper when a practice is ready to build.
The federal front door
PECOS is where enrollment happens.
PECOS is the federal system where a clinician tells Medicare who they are, where they practise, and what kind of practitioner they are. That enrollment record affects what Medicare recognizes about the clinician, and can affect whether claims process correctly.
Two of its choices matter more than people expect at the time: the specialty code the clinician selects, and the participation decision described below.
Two reasons people are here
You may be enrolling because you want to bill Medicare independently. Or because you are joining a medical practice or an integrated-care arrangement.
The federal enrollment process begins in the same system either way. What happens afterward depends on the role and the billing model.
One decision, made early
Participating or non-participating?
Participating and non-participating are Medicare’s own terms. They affect assignment and the payment rules that follow.
They do not mean accepting Medicare versus refusing it. Both are ways an enrolled Medicare practitioner may furnish services; the payment and assignment rules differ. The choice is made during enrollment, often before anyone has explained the arithmetic.
The Cheat-Sheet explains the difference in plain arithmetic, before you have to make the choice.
What Medicare pays
There is no single national number.
Payment can vary by Medicare locality, so the amount for the same code may differ depending on where the service is furnished, and the schedule is updated. Anyone quoting one figure for the whole country is quoting an average, not your rate.
The Cheat-Sheet shows how to find your locality, find the current fee schedule, look up your code, and record the date you checked. That last step matters more than it sounds: a rate without a date is not evidence.
Where implementation gets harder
The federal path can be explained in a public guide. Your practice is more specific.
The Cheat-Sheet explains the federal path. The larger implementation tools help a practice work through the steps. What applies to one practice cannot be answered by any public document.
Kedge Marketplace is the separate platform for applying state, payer, license, contract, and staffing details to one practice.
The exchange
Five minutes, if the Cheat-Sheet earned them.
What gets in the way when clinicians and practices actually try to put these arrangements together?
The federal rules are published. What happens when clinicians and practices try to put them into operation is much harder to see. Did enrollment delay the arrangement? Was it clear who needed to enroll? Was the right enrollment type chosen? Did payer enrollment add another delay after Medicare? Did the uncertainty cause anyone to abandon the model?
The study is open to clinicians who enrolled or tried to, to the practice managers and credentialers who enrolled them, and to medical practices attempting to bring a clinician into an integrated arrangement. Findings go to respondents first.
About 5 minutes
Enrollment status · time to enrollment · role · who needed to enroll · payer enrollment · whether enrollment delayed or stopped the arrangement
The survey
The study is not collecting responses yet.
When it opens, your invitation will return you to this page. The Cheat-Sheet above is complete and available now.