> Modification of TRICARE Independent Practice Standards Advanced

Contact: Jim Finley
Modification of TRICARE Independent Practice Standards Advanced

ALEXANDRIA, Va. – On May 15, 2015 the full House approved House Armed Services Committee legislation that included a provision sought by the American Counseling Association (ACA) to modify the TRICARE August 18, 2014 rule for Certified Mental Health Counselors. Under HR. 1735, “The National Defense Authorization Act for Fiscal Year 2016” (NDAA), the extension of full independent practitioners status for CMHCs under TRICARE would be temporarily broadened to include more practitioners from many different training programs. This new language is now part of the House version of the NDAA and will ultimately be considered by the Senate. The Senate version, S. 1118, currently does not include the House language, but they are expected to soon consider their own NDAA bill. The comprehensive annual funding bill sets the spending policy and rules for the nation’s armed forces.ACA sought the change without input from other stakeholders such as AMHCA, NBCC, CACREP, or the MFTs. Consequently, at this time these other stakeholders are unresolved about taking further action on the provision as it merely postpones the full implementation of the TRICARE 2014 rules until 2027, when the 2014 standards would be restored. As policy, it provides much more time for recent and future CMHC graduates from non-CACREP programs to participate independently under TRICARE. However, even with the delay, CMHC training programs will still need to transition quickly to CACREP to ensure graduates can participate in programs operated by the Department of Veterans Affairs and receive professional training funds administered by the Department of Health and Human Services. Nevertheless, HR. 1735 would provide much more time for nonconforming programs to continue operations while the profession continues its adoption of uniform CACREP training standards as called for by the Institute of Medicine in 2011.

Basic Requirements of the August 18th Rule

  1. Hold a master’s degree or doctoral degree in counseling from a mental health counseling program or clinical mental health counseling program accredited by CACREP.
  2. State licensed in mental health counseling at the highest clinical level.
  3. Has passed the National Clinical Mental Health Counseling Examination.
  4. Alternatively, for those that either did not or could not apply during the grandfather period, may participate under the old TRICARE rules as a supervised practitioner.
Proposed Grandfather under HR. 1735
  1. Adds independent status to those licensed for at least five years, and
  2. Expands recognized training programs to include:
    (A) The Accrediting Commission for Community and Junior Colleges Western Association of Schools and Colleges (ACCJC-WASC)
    (B) The Higher Learning Commission (HLC)
    (C) The Middle States Commission on Higher Education (MSCHE)
    (D) The New England Association of Schools and Colleges Commission on Institutions of Higher Education (NEASC-CIHE)
    (E) The Southern Association of Colleges and Schools (SACS) Commission on Colleges
    (F) The WASC Senior College and University Commission (WASC-SCUC)
    (G) The Accrediting Bureau of Health Education Schools (ABHES)
    (H) The Accrediting Commission of Career Schools and Colleges (ACCSC)
    (I) The Accrediting Council for Independent Colleges and Schools (ACICS)
    (J) The Distance Education Accreditation Commission (DEAC)
  3. Beginning in 2027, restores requirements of the August 2014 rule.
Member Comments Requested
AMCHA is interested in learning the views of its members on this new House provision. The change would enable more practitioners seeking independent practice status under TRICARE to avoid taking the NCMHCE exam and enable non-CACREP accredited programs to continue operations years into the future. Conversely, maintaining a wide diversity of training standards would also likely exacerbate ongoing portability and recognition barriers for the profession. In addition, postponing adoption of unified national training standards will keep the profession well behind other independent health professionals working in the VA and DOD and will limit the practice opportunities for yet another wave of non-CACREP grads throughout their careers. AMHCA invites member to submit their comments here on the proposed legislation. Comments will be read by AMCHA Board and Public Policy and Legislation Committee members.Background Resources
AMHCA Comments on TRICARE Final Rule, August 2014
TRICARE Final Rule August 18, 2014