Medicare Covers Two Additional Provider Types in the RHC Setting

Sarah Hohman, NARHC Director of Government Affairs


Congress released draft text this week for the Consolidated Appropriations Act of 2023, also known as the yearly “Omnibus” package which will fund the federal government for the remainder of Fiscal Year 2023.

Of exciting note for RHCs, Congress proposes to expand Medicare coverage to include Marriage and Family Therapists (MFTs) and Mental Health Counselors. These providers in the RHC setting can now generate a Medicare encounter, reimbursable at the RHC’s All-Inclusive Rate (AIR) beginning January 1, 2024.

“The past several years have seen historic changes to the Rural Health Clinic program. 2022 will close with a nice gift, which is better described as the fruit of our labor. For the first time in decades, Congress has expanded the definition of RHC-eligible providers. Mental Health Counselors and Marriage/Family Therapists are now eligible providers in RHCs and FQHCs” said Charles James, NARHC President. “It is a huge deal. I am deeply proud of the work RHCs provide to at-risk patient populations. This will allow us to provide urgently needed services to patients in crisis. NARHC and our allies in the Rural Health community worked hard to make this change.”

A Mental Health Counselor is recognized as an individual who -

‘‘(A) possesses a master’s or doctor’s degree which qualifies for licensure or certification as a mental health counselor, clinical professional counselor, or professional counselor under the State law of the State in which such individual furnishes the services described in paragraph (3);
‘‘(B) is licensed or certified as a mental health counselor, clinical professional counselor, or professional counselor by the State in which the services are furnished; “(C) after obtaining such a degree has performed at least 2 years of clinical supervised experience in mental health counseling;
‘‘(D) meets such other requirements as specified by the Secretary.’’

As we expand the range of covered behavioral health providers in the RHC setting, NARHC will continue to seek clarification and a solution to the primary care to behavioral health service ratio. Stay tuned for opportunities to engage in grassroots advocacy efforts early next Congress!

As CMS adds new provider types to the RHC benefit for the first time in decades, various guidance documents will be revised, and additional details shared. As always, NARHC will keep the RHC community informed of these details.

We encourage you to stay up to date on key RHC news on and contact Sarah Hohman, NARHC Director of Government Affairs,, or Nathan Baugh, NARHC Executive Director, with any questions or concerns.