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to bring reimbursement policies into congruency with licensure laws by affirming the right of these professions to practice independently and be reimbursed by third party payers. An interim policy that might address rural access needs would be to authorize direct reimbursement to these professions only in designated shortage areas. Aprecedent for such a policy can be found in the Federal Employees Health Benefits Program policy that “requires non-HMO FEHB plans to reimburse beneficiaries, subject to their contract terms, for covered services obtained from any licensed provider in [underserved areas] (our italics, United States Office of Personnel Management, 2001).

Another option for consideration by Medicare is a program currently authorized for CHAMPUS/Tricare beneficiaries as a two-year demonstration. Prior to this demonstration, Tricare has required a physician referral before they would reimburse a “licensed mental health counselor” for services to beneficiaries. The demonstration is allowing beneficiaries direct access to counselors without the referral. It proposes to assess whether extending independent practice to counselors will alter expenditures or utilization. (National Defense Authorization, Fiscal Year 2001, Appendix, 7 U.S.C. § 731, 2000). It should be noted that the effect of extending reimbursement to new mental health professions through vendorship laws has been studied, and findings consistently show that there is no significant increase in costs to insurance carriers (Frank, 1989, Lieberman, 1988). In fact, one study found that the increased competition resulted in a drop in psychiatrist’s fees (Frank, 1982).

  • 3.

    Several strategies could be employed to reduce professional competition over the right to practice and be reimbursed. New Hampshire has addressed this issue by allowing candidates for licensure to be supervised by almost any mental health profession, and by requiring providers to provide “…proof that they do not work in professional isolation…” by submitting evidence of participation in a minimum of 25 hours of specified collaborative activities with members of other professions (New Hampshire Board of Mental Health Practice, NH Rules 404.01, 1993). Several other states have begun to address this issue through combined boards or mental health professional practice acts. The professional associations that represent these professions must provide leadership by taking the lead at the state level in working toward mental health professional practice acts and consolidated regulatory functions

  • 4.

    New graduates of programs that train mental health professionals can begin to address rural needs soon after graduation, if arrangements can be made for them to receive supervision,


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