By Barbara Griswold, LMFT

Author, Navigating the Insurance Maze

October 12, 2023

Hi everyone,

Today I'm writing about important Medicare changes that affect all MFTs and counselors -- and our clients. What should you be doing now if you want to work with Medicare clients -- or if you don't? What about psychologists and LCSWs who don't want to work with Medicare? Glad you asked. I'll be covering all these in today's article.

Enjoy LIVE learning opportunities? Join me at my upcoming live webinar "Couples Therapy Blunders: Common Mistakes when Billing, Documenting, and Handling Ethical Dilemmas," Sponsored by the Zur Institute Saturday, Oct. 21st. Or register and get the recording! For more details, click here, or see below.

As you may recall from my last newsletter, I'm collecting your stories about the funniest or wildest thing a client has done during a telehealth session. Write to me here and I'll anonymously share the best ones in a future edition.

Feel you could use a little feedback on your notes? Answers to billing questions? Support with the business side of your practice? Schedule your consultation -- click here.

Take care,



"Audits and Records Requests: What EVERY Therapist Should Know"

Saturday November 4, 2023

11 - 1pm PDT | 12- 2pm MDT | 1-3pm CDT | 2-4pm EDT

Can’t make it live? All registrants get the recording!

A request from an insurance plan for your notes would likely bring a wave of anxiety. Yet every day, clinicians nationwide — whether in or out-of-network — are facing these requests. While some audits are purely administrative, others can lead to costly claim denials or repayment requests (aka“clawbacks”). You (or your clients) can lose thousands of dollars in unreimbursed claims. In this webinar, we take a closer look at the reasons your notes might be requested by a health plan, how to respond if they are requested, and how to prevent any loss of income. For more info/to register, click here


Counselors and MFTs:

Are You Ready for Medicare?

As you may have heard, Counselors and Marriage and Family Therapists will become eligible to provide services to Medicare clients as of January 1, 2024. But even if you choose NOT to become a Medicare provider, you may have to take some action in the coming months. Read on...

Since I'm no Medicare enrollment expert, I'm interviewing Medicare expert and veteran mental health biller Susan Frager, of YourBillingBuddy.com. Frager has decades of experience working with Medicare, and consults with therapists nationwide to help them navigate the Medicare enrollment and billing maze. Here she answers our most frequently asked questions:

"Can therapists and counselors just start providing services to Medicare folks as of January 1st, 2024?" "Unfortunately, no," says Frager. "you will need to be enrolled as a Medicare provider to be paid by Medicare."

"When will enrollment be opening for MFTs and counselors?"  "It will likely be opening in the 2nd or 3rd week in November," says Frager. "However, the earliest you could see a Medicare client would still be January 1, 2024."

"How does enrollment work?" Frager explains that when you submit your application, you will be assigned a Medicare analyst, who will review your application and pronounce it "clean" or deficient. You have 30 days to fix any deficiencies. If you don't fix problems in 30 days, you'll have to start all over again. 

"If I'm interested in becoming a Medicare provider, what should I be doing now?"  Here's Frager's advice:

  • "Many clinicians register for their National Provider Identifier (NPI) and Employer Identification Number (EIN) and never update these official addresses," says Frager. "If these addresses don't match your Medicare enrollment address, this can delay your Medicare application." So, her advice? "Choose an address you want to use, and go back to be sure that's the one listed at NPPES (the website for the National Provider Identification). You might want to do the same for the address you have listed for your EIN -- "everything has to match." (Note: If you don't have an EIN, click here to get one, so you can use it in place of your Social Security Number on claims and superbills).

"While it is unlikely, remember that Medicare could visit your location to make sure it’s a legit business," Frager says. "They are required to do this to prevent fraud." Therefore, the use of a USPS or UPS address as your service location could lead to your disenrollment if Medicare researches your address. However, according to Noridian, one of the Medicare Administrators, as of 10/3/23, "current processing standards dictate that on-site reviews should not be ordered for locations that are identified to be solely used for telehealth." But, says Frager "If you are telehealth only, or your physical office isn’t clearly marked with your name/business information, I'd advise you to call Provider Enrollment after submitting your application and discuss any concerns about a potential site visit.” 

  • "If you have incorporated or have a LLC, you must have an EIN and a Type 2 NPI for that entity to enroll in Medicare," says Frager. "If you don't have a Type 2 NPI, get one now."
  • "If you are using an EIN, dig out IRS Form CP 575 now. This is the form the IRS sent you when they assigned you an EIN," says Frager. "If you can't find it, ask the IRS for a copy." You'll need this for enrollment.

"But keep in mind," Frager warns, "that changing your address or NPI type or moving from a SSN to EIN can mess up your private insurance claims. You may need to alert insurance plans and CAQH of these changes and your new official office location," and submit a W-9 form if you get an EIN. 

"What if I'm an MFT or counselor but I'm NOT interested in joining Medicare?" "Medicare isn't like private insurance," says Frager. "After January 1, 2024, counselors and MFTs will need to officially opt-out if you want to be able to see Medicare clients as self-pay clients in your practice. Once you opt-out, your Medicare clients will need to complete a Medicare Private Contract" -- click here to read more about these steps.

"What about us LCSWs and psychologists?"  "You need to either enroll to be a Medicare provider or officially opt-out and use a Private Contract if you want to see Medicare clients in your practice," says Frager. "You don't need to wait until January 1st." Again, click here to read more about these steps.

"How can I make the decision whether to become involved in Medicare, if I don't know anything about Medicare?" To help clinicians, Frager is offering several "non-threatening, informal" small-group workshops to help clinicians make this decision. "I'll be sharing my experience as a biller working with Medicare, and answering questions about enrollment, auditing, reimbursement rates, coverage, and addressing myths and horror stories," she says. She will also be facilitating several online workshops where she'll actually walk therapists through the Medicare enrollment process; at the end of the session, you would be ready to submit your enrollment. Find out more about her upcoming workshops -- click here

"Any other helpful resources?" This is complex stuff! So Frager helped me put together a graphic to help me better understand our choices involving Medicare. Check out my informative graphic that will have surprising answers to your questions. I call it, "When Can A Therapist or Client Be Reimbursed By Medicare?" You can download this handout now: click here

" I have more questions about working with Medicare!" Great! But PLEASE don't contact me, unless it has to do with Medicare documentation or audits! Schedule your consultation with Susan Frager at www.YourBillingBuddy.com or contact her at [email protected]



This pre-recorded webinar is for all therapists, since we all can have charts reviewed by insurance, disability, licensing boards, and courts. Includes 8 note examples, 3 downloadable templates, and telehealth note requirements. For info, click here 


Need forms for your practice? Get 20 essential forms including telehealth consent, couples consent, and Good Faith Estimates. Easy to customize. Designed to meet common legal, ethical, and insurance expectations. For info, click here


This pre-recorded course, applicable nationwide meets new California BBS requirement for 3-hour telehealth course before your next license renewal; counts as 2.5 Legal and Ethical Hours for CA BBS licensed therapists. For more info or to register, click here



Working with couples is not only clinically challenging, but it can be difficult to navigate the added complexities in the areas of billing, documentation, and ethical practice. This pre-recorded webinar answers all your questions such as when can you ethically bill insurance? Who really is your client? Do you need two charts and treatment plans? What does insurance expect? For more info, click here


This pre-recorded webinar is for all therapists, since even out-of-network therapists can have their notes requested by an insurance plan or other agency -- and can be asked to pay back monies already collected. Learn to prevent this. For info, click here


This pre-recorded webinar is for you if you hate writing treatment plans, worry about the ones you write, or don't write them at all. Learn how to write brief plans that satisfy legal, ethical, and insurance expectations, so you feel confident if you receive a records request, and won't have to pay money back if audited. For info, click here.


This pre-recorded webinar covers thorny issues and common mistakes made when working with couples. It will challenge myths, clarify areas of confusion, and invite you to think about your policies. Find out more -- click here


This pre-recorded webinar answers all your questions about fraud and contract violations, including whether it is ethical to bill two insurance plans for a couples session, ethical sliding fees, waiving copayments, and how to avoid common types of fraud. For info, click here 

WEBINAR: "THE FIRST SESSION: Juggling Clinical and Administrative Tasks"

This pre-recorded webinar gives tips on juggling intake tasks -- to build rapport and take a history, while handling paperwork, payment and insurance issues. For more info, click here

Order the NEW 9th edition of
Navigating the Insurance Maze:The Therapist's Complete Guide to Working With Insurance

Click here for info (buy from us - Amazon keeps 55% of profits!)


"Couples Therapy Blunders: Common Mistakes when Billing, Documenting, and Handling Ethical Dilemmas”

Saturday, October 21, 2023

9:30 am- 12:10 pm PDT | 10:30 am-1:10 pm MDT |

11:30-2:10 pm CDT | 12:30-3:10 pm EDT

Can't make it live? All registrants get the recording!

Sponsored by the Zur Institute

This training will focus on the practical challenges of couples work. When can you bill insurance? Who is your client? What common mistakes do couples therapists make, and how can you avoid them? We will cover the issues you deal with daily, challenge myths you may have about couples work, clarify areas of confusion, and invite you to rethink your policies. For more info or to register, click here

"Audits and Records Requests:

What EVERY Therapist Should Know"

Saturday November 4, 2023

11am-1pm PDT | 12- 2pm MDT | 1-3pm CDT | 2-4pm EDT

Can’t make it live? All registrants get the recording!

In this webinar, we take a closer look at the reasons your notes might be requested by a health plan, how to respond if they are requested, and how to prevent any loss of income. For information or to register, click here

"What Out-of-Network Therapists Should Know About Billing" FREE!!

Tuesday, November 14, 2023

12-1pm PDT | 1- 2pm MDT | 2-3pm CDT | 3-4pm EDT

Can’t make it live? All registrants get the recording!

Free training sponsored by SimplePractice. Open to all!

Do you think because you aren’t in-network with insurance plans that you don’t need to know about insurance stuff? Think again! Your lack of knowledge about how insurance works can cost you and your clients money. For more info or to registerclick here


  • Considering whether taking insurance is right for you?
  • Need help fighting a claim denial?
  • Need help dealing with a records request?
  • Want to build your practice, or discuss a case?

I CAN HELP. Schedule your consultation now-- click here

($150 for 50 min; $85 for 30 min.)


For other helpful articles, click here

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Barbara Griswold, LMFT
Author, Navigating the Insurance Maze: The Therapist's Complete Guide to Navigating Insurance -- And Whether You Should
408.985.0846 [email protected] (email is best)