CMS Shares FAQ from November Forum on Hospice MFT and MHC Use

In November, the Centers for Medicare and Medicaid Services (CMS) held an open-door forum, which discussed the new provisions allowing Marriage and Family Therapists (MFT) and Mental Health Counselors (MHC) to be part of the interdisciplinary group. LeadingAge has received a new FAQ document that reviews the questions that were answered on the call.

LeadingAge contacted CMS regarding question 8, which is about completing the comprehensive assessment and developing a plan of care. CMS clarified that according to the requirement at 418.54(b), the interdisciplinary group (IDG) should complete the comprehensive assessment. Hospices can choose to place a Social Worker (SW) or MFT or MHC on the IDG. The SW, MFT or MHC can conduct a psychosocial assessment according to their state scope of practice. SW, MFTs, and MHCs have their own state scope of practice and licensure requirements. The services that the patient receives are determined by the assessed needs of the patient, regardless of whether they are assessed by an SW, MFT, or MHC. CMS encourages other disciplines providing care to the patient, if applicable, to participate in IDG meetings and provide their clinical perspective in the development and update of the comprehensive assessment. CMS provided two examples to explain this.

• If the MFT or MHC is the member of the IDG, the MFT or MHC is responsible to conduct the psychosocial portion of the assessment, if permissible by their state scope of practice and licensure. If the assessed needs of the patient fall into the scope of practice of the social work, then it is expected that the social worker would be providing services to the patient to meet the patient’s social work needs. This information would be documented and communicated (per the hospices policy) in the patient’s record and shared with the official IDG member, in this case the MFT or MHC.
• Similarly, if the social worker is the official member of the IDG, the SW would be responsible for the psychosocial section of the assessment. If the patient has an assessed need for therapy/counseling services, the hospice may choose to utilize an MFT or MHC to meet the therapy/counseling patient’s need. It is expected that the MFT or MHC would document and communicate the information (per hospice policy) in the medical record and share with the official IDG member, in this example the social worker.

CMS updated hospice cost report to include the addition of Marriage and Family Therapists and Mental Health Counselors as part of the interdisciplinary group. Specifically, CMS updated Line 36 – Counseling – Other. This cost center includes the cost of counseling services not already identified as spiritual, dietary or bereavement counseling. Effective for services on or after January 1, 2024, in accordance with the Consolidated Appropriations Act of 2023, §4121, also include the cost of marriage and family therapy services and mental health counseling services. Costs for non-reimbursable activities included in this cost center must be reclassified to the appropriate non-reimbursable cost center.