Monthly Archives: July 2014

New Final TRICARE Regulations came out July, 17, 2014

News from Courtenay J. Culp, LCPC, Executive Director of LCPCM

July, 27, 2014

New Final TRICARE Regulations came out July, 17, 2014

Delineating the Requirements for LCPC Independent Practice under TRICARE

The US Department of Defense published in a final rule July 17, 2014 to implement the new TRICARE Certified Mental Health Counselor (TCMHC) provider type as a qualified mental health provider authorized to independently diagnose and treat TRICARE beneficiaries and receive payment for services.

The final rule goes into effect on August 18, 2014. The TRICARE rule includes at least three major wins which the Licensed Clinical Professional Counselors of Maryland (LCPCM) and our advocacy partners made. They include:

1)      An extended “transition period” (grand-parenting period) to January 1, 2017, providing extended time to prepare and take the NCMHC Exam.

2)      Expansion of the pool of qualified supervisors to include licensed psychologists, licensed social workers and psychiatrists so more LCPCs will be eligible.

3)      Keeping the current supervised TRICARE providers, now called Supervisor Mental Health Counselor (SMHC) intact with the ability to practice with physician referral indefinitely.

We are disappointed that TRICARE is requiring the NCMHC Exam instead of the NCE. However, at least there is a 2 ½ year extension to prepare and take the exam should you want to become an independent TRICARE provider.

Additionally, we are disappointed that TRICARE kept the CACREP-only policy for approval of graduate programs, but we intend to continue to lobby vigorously to have this aspect of the rule amended.

LCPC of Maryland and Massachusetts MHCA leaders are now working with TRICARE to make the TRICARE application easier to complete.

Again, if you want to be an independent provider for TRICARE, you will have to have passed the NCMHC Exam by January 1, 2017.

To read the Final Rules, go to

Final Rule Published for the TRICARE Certified Mental Health Counselors Designation

The final rule for the TRICARE Certified Mental Health Counselors designation came out in the Federal Register this morning:


We have the .pdf of the Rule available on our website here.


We need to analyze this carefully.  In the meantime it looks like providers without CACREP certification can still practice as before, under the supervision of a physician, and the timeframe to meet their certified criteria is extended another two years.

This is a strong win!  We’ll take a look and see what next steps are.


The Department of Defense is publishing this final rule to implement the TRICARE Certified Mental Health Counselor (TCMHC) provider type as a qualified mental health provider authorized to independently diagnose and treat TRICARE beneficiaries and receive reimbursement for services. Additionally, we are extending the time frame that was mentioned in the Interim Final Rule for meeting certain education, examination, and supervised clinical practice criteria to be considered for authorization as a TCMHC. The time frame has been changed from prior to January 1, 2015, to prior to January 1, 2017. One final set of criteria shall apply for the authorization of the TCMHC beginning January 1, 2017. The supervised mental health counselor (SMHC) provider type, while previously proposed to be terminated under TRICARE, is now continued indefinitely as an extramedical individual provider practicing mental health counseling under the supervision of a TRICARE authorized physician.


Effective Date: This rule is effective August 18, 2014.

Counseling Students Who Will Never Get to Help TRICARE Clients

Another piece of great reporting by Crystal Price at KFOX in El Paso, TX.  She interviews an intern/student therapist about how — after all her work — she is never going to be able to help military children on TRICARE if the new regulations stand.  Ms. Price also interviews a school official for his comments.

Transcript available at:

The CACREP Party line about current licensed counselors being able to grandfather into TRICARE if they take an exam is repeated in this story.  While that is true, its also the case that counselors must have received all of their supervision from a counselor or counselor educator (not a psychologist, a social worker, or other licensed mental health professional).  Most older counselors came up through school when supervisors from other professions were needed due to few fully trained counselors.  This renders the “grandfathering” options of TRICARE about useless for many of us.

This news segment does utilize a much more likely statistic for how many CACREP-trained counselors there actually are in this country.  Ms. Price AVOIDS using the following frankly embarrassing nugget that we are told is currently being passed around by CACREP in response to inquiries:

CACREP, which was formed in 1981, accredits the majority of post-graduate counseling programs in the country – over 650 graduate counseling programs at more than 290 institutions.  A random sample of licensed and non-licensed counselors used in the 2010 National Counseling Examination (NCE) job analysis study showed that 71% of counselors are CACREP graduates.  Of the remaining participants, 17% indicated that they graduated from a non-CACREP program and 12% reported to have earned their degree before CACREP was formed in 1981.

This quote is just so wrong in so many ways, most of them discussed here.

TRICARE Position Statement

Coalition of Concerned Counselors (CCC) &
Licensed Clinical Professional Counselors of Maryland (LCPCM)


Position Paper

July 15, 2014

Military families and veterans do not have access to the majority of the nation’s most experienced and highly trained licensed mental health counselors


The Problem:

1. Many military families and veterans who are currently in treatment with highly qualified licensed mental health counselors will have to terminate therapy before completion of their treatment due to new and limiting TRICARE regulations.

TRICARE, in an effort to expand mental health services for military families, unintentionally created regulations that only permit a small fraction of state licensed mental health counselors to provide much needed care.

2. TRICARE must create an alternate pathway to eligibility for licensed counselors that is equivalent to the current pathway in terms of standards, but results in the expansion services to veterans and military families, by including    the most talented and experienced licensed counselors to serve.

3. The Veteran’s Administration created a job classification for licensed counselors that excludes the nation’s most experienced and highly educated licensed counselors. The Veteran’s Administration must create an alternative employment pathway for licensed mental health counselors, to expand our veteran’s access to the most highly trained and experienced licensed counselors in the nation.


The Solution:

The federal government should implement standards for the participation and employment of mental health counselors in its agencies and programs. The stringently high standards that follow ensure the uniformity and quality of the counselor’s training and education, while broadening the pool of mental health providers in our communities. The current standards implemented at the Veteran’s Administration and at TRICARE insure uniformity at the expense of quality and experience. The following standards are equivalent or higher to the eligibility requirements of the VA and TRICARE:

  1. State licensure as a professional counselor or clinical mental health counselor
  2. State authorization to diagnose and treat mental and emotional disorders and conditions.
  3. A master’s degree from a regionally accredited graduate program that prepares students to meet the state licensure requirements for professional counseling or clinical mental health counseling.
  4. Documentation of 60 graduate course hours to include at a minimum the current eight common core curricular areas recommended by the Council of Accreditation of Counseling and Related Educational Programs (CACREP) for professionals who practice clinical mental health and professional counseling.
  5. A supervised clinical practicum and/or internship that meets the standards for state licensure.
  6. Two years of supervised post-graduate experience in clinical mental health counseling.
  7. Passed the National Certified Counselor Exam and/or the National Clinical Mental Health Counselor Exam in accordance with state licensure requirements.

The Background:

Unlike psychologists and clinical social workers, licensed clinical mental health counselors graduate from a variety of accredited masters and doctoral level programs leading to degrees in counseling, clinical community counseling, clinical mental health counseling, counseling education, counseling psychology, school psychology, pastoral counseling, among others. These graduates are eligible to apply for a license to practice clinical mental health counseling, but all licensees must meet the same requirements established legislatively by their respective states. To ensure the consistency and quality of the educational training of their mental health counselor licensees from the various accredited graduate programs, each state mandates the specific graduate program of study, including the number of graduate credits, specific coursework, training, internships, supervision, post-masters experience and national examination. Applicants must successfully complete the same specific criteria to be licensed to practice. This is what unifies and identifies our profession. Our field is different in this regard from the other comparable clinical professions whose national associations accredit graduate programs and determine the uniform standards for those programs. It cannot be assumed that, because professional counselors have a different method for standardizing the profession and thereby ensuring public safety, that the quality of service provided by the profession is superior or inferior to other methods.

A study by the Institute of Medicine recommended uniform graduate program accreditation to align the profession with the other mental health professions. The Council of Accreditation for Counseling and Related Educational Programs (CACREP) is a national accreditation body that can offer uniformity in programs from state to state. It must be emphasized, however, that the Institute of Medicine did not report any difference in the effectiveness of treatment or quality of services provided by licensed mental health counselors compared to services provided by social workers and psychologists who currently serve as eligible providers in federal government agencies and programs.

The new TRICARE and the Veterans Administration (VA) criteria for participation and employment now require the counselor to have graduated from a graduate program accredited by the Council of Accreditation for Counseling and Related Educational Programs (CACREP), disregarding the fact that CACREP accredits a very small number of clinical mental health counseling programs. This requirement alone excludes the vast majority of licensed counselors, some of whom attended the finest of our nation’s universities and colleges well before CACREP began to accredit clinical mental health counseling programs. It also discounts the well-established laws and regulations in each state carefully designed to protect its citizens. This is happening at the same time that services to veterans and military families are sorely needed.

Summary and Conclusion

The unintentional consequences of new regulations for licensed mental health counselors participation and hiring in the federal government has disrupted treatment of veterans and military families, has excluded access to the most experienced and qualified mental health counselors in the country, and has inadvertently reduced the pool of qualified mental health providers.

The solution is to establish an additional pathway to eligibility that provides military families and veterans access to the most experienced and qualified mental health counselors in the nation. The requirements presented in this paper provide uniformity and quality for the mental health counseling profession while incorporating the majority of established state licensure laws and CACREP standards.


We invite counselors and the public to take a closer look at the issues at .


About The Coalition of Concerned Counselors (CCC): CCC is a growing confederation of individual counselors, client rights advocacy organizations, counseling associations, and professional graduate programs created in order to educate counselors and the public on the growing threat of CACREP-only restrictions on counseling practice.


About Licensed Clinical Professional Counselors of Maryland (LCPCM): LCPCM is a 501c6 advocacy organization for the rights of clients and the development and equity of professional counselors.


Congressman Beto O’Rourke: Impact “Could Not Be More Grave” of TRICARE Rules on Military Mental Health

Yet another strong article out of the El Paso Inc. newspaper.  This is starting to get interesting.

O’Rourke: Impact ‘could not be more grave’: Proposed changes to military benefits could reduce care

Representative O’Rourke is on the Veterans Affairs and Homeland Security committees, so he may be in a position to do something.

The article also mentions the part of the IOM recommendations that so frequently does not get mentioned by CACREP-only advocates — the part where IOM recommended that CACREP unaffiliated counselors be allowed to continue practicing in TRICARE in order to “maintain the continuity of care” and that TRICARE should continue supervising CACREP unaffiliated counselors “using a scheme that provides for successively greater levels of independent practice.”

This would be a very good time to start writing Congressional delegations to put greater pressure on TRICARE to amend the rules and to support Rep. Beto O’Rourke.

Killeen Texas Daily Herald Story on TRICARE Counselors

A sincere thank you to military editor Rose Thayer for running the following piece in the Killeen Daily Herald today:

Off-post counselors await Tricare policy decision

There are so few news segments on the impending TRICARE disaster, so I appreciate her interest and efforts to warn the public.

I think I begin to see why there is so little interest in this big news story…  A causal reader who browses the above article could be forgiven for walking away thinking that this is no big deal.  After all, the Defense Health Agency is just trying to balance quality with accessibility, and only 29% of counselors are ineligible for the new TRICARE rules anyway, and even those 29% have an open-ended opportunity to grandfather into the new rules…

**NO**    **LETS TRY AGAIN**

If DHA and CACREP gave Ms. Thayer the statistics as stated knowing that they were for an article on TRICARE counseling, then they were extraordinarily misleading. Perhaps this is not how it came about.

We speculate — if these are the sorts of factoids given to reporters when they inquire on this topic, no wonder there is so little alarm over this issue.

How’s a well-meaning reporter to know that they have to take all the “facts” given to them with such a large dose of skepticism?

The DHA quote in the article talks about balancing quality versus accessibility.  This indirectly implies a lack of quality amongst CACREP unaffiliated counselors.  There have been no creditable studies showing that CACREP graduates perform better counseling.  Many quality schools – some of them ivy league – are not CACREP accredited .  In the northeast these non-CACREP programs include Harvard, Columbia, George Mason, Seton Hall, and (until recently) Johns Hopkins.

CACREP’s oft-repeated factoid about 640/650 programs being CACREP accredited is incredibly misleading.  This number includes school counseling and other counseling programs that **DO NOT QUALIFY FOR TRICARE**.  There are only 120 or 121 Clinical Mental Health Counseling Programs in the country that are CACREP-accredited.  These are the ONLY ones whose graduates will be qualified to serve Tricare beneficiaries.  Most accredited mental health programs are located in the South or North Central regions of the country.  All of New England has only EIGHT such programs.  The regulation will create “therapy deserts” where Tricare patients simply cannot find a qualifying mental health counselor.  Now it is the case that other similar professions (psychologists, social workers) can partially fill these service gaps, but this remains a ridiculous obstacle to veterans and their families getting the mental health care that they need.

There is a quote in this story that “the policy does allow for providers to be grandfathered in if they didn’t graduate from an accredited program.”  This is true as far as it goes…  If a counselor is lucky, he/she can take the NCMHCE exam before the end of the year to be grandfathered in.  However, this is problematic…  Some counselors have been told that they have to meet CACREP-like standards before they can sit for the NCMHCE exam (I’m told NBCC has very recently changed this).  Some regions are requiring counselors to sign a statement that they completed all of their hours of supervised practice prior to licensure under the supervision of a professional counselor or counselor educator (as opposed to a psychologist, social worker, or other licensed mental health professional).  Almost NO counselors who have been in the field more than a few years conducted their internships under another counselor – when the profession was new almost everyone had a psychologist or social worker as a supervisor.  So – hard as it is to believe – there is no grandfathering redress available for many counselors despite the show of such.  No, it does not make sense.  A psychologist makes for a fine training supervisor.

We are simply stunned by the following quote:

“According to CACREP, a random sample of licensed and nonlicensed counselors used in the 2010 National Counseling Examination job analysis study showed that 71 percent of counselors are CACREP graduates. Of the remaining participants, 17 percent indicated they graduated from a nonCACREP program and 12 percent reported they earned a degree before CACREP was formed in 1981.”

Please tell us that this material was not really given by CACREP as an answer to how the supply of counselors would be effected for TRICARE counseling?

Our best conservative estimates are that approaching 70% of counselors ARE NOT from CACREP programs:

~ In Mass there are roughly 5200 LMHCs (their version of professional counselors), estimated +/- 4% being from CACREP programs. Only two of 19 programs in Mass are CACREP accredited.

~ CACREP itself says over 640 approved programs exist.  Only 121 (about a fifth) are Clinical Mental Health Counseling programs that would meet the proposed regulations of TRICARE.

~ ACA did a study citing that only 13% of New York counselors would meet TRICARE requirements.  They cited this in a letter to Jonathan Woodson.

There is no way that 71% of counselors are CACREP graduates.  Not even including school counselors, who would not be paneled for TRICARE anyway.

KFOX TV El Paso Top Story – TRICARE CACREP-Only Rules Will Drastically Cut Military and Veteran Mental Health Services

Leah Miller

Leah Miller

Crystal Price with KFOX TV in El Paso has put together a wonderful segment exploring the impending loss of up to 70% of licensed professional counselors from the TRICARE system.  Hats off to Leah Miller for opening up her counseling center and providing a great interview and real faces to put with the impact of the cuts.

Congressman Beto O'Rourke

Congressman Beto O’Rourke

We are also thrilled that Congressman O’Rourke is interested in finding ways to amend, waiver, or delay the TRICARE rules set to take effect in January!

You can read or watch the story at the following links below:

Link to written KFOX article:

KFOX News Segment:

We were highly amused by the play action figure illustration of exactly how many counselors would be lost to TRICARE by the new regulations.  While we certainly would not have picked the kings and queens to represent the CACREP counselors, we do agree that at times CACREP seems to be lording it over the rest of us.

CACREP-only rules leave CACREP lording it over TRICARE client needs.

Unjustly crowned. CACREP accreditation is not more important than insuring access to care for our service members in great need.

The rest of us rabble fighting to be able to still help our clients.

The rest of us rabble fighting to help our clients.

The entire field of battle.

The entire field of battle.

El Paso Newspaper Understands the Problems TRICARE Rules Cause Local Community

El Paso is home to Fort Bliss and quite a number of veterans, service members, and their families.  The El Paso Inc. newspaper ran a story this past Sunday entitled New rules could limit mental health care for soldiers.

In this story reporter Robert Gray interviews a few local clinic owners expecting huge changes as a result of the TRICARE “proposed” rule changes which will only allow CACREP counselors to join the panel as of January 2015.  (As of this time the “proposed” rules are rather imminent and the switch-over is well under way, pending last minute reversals.)  One clinic has 11 therapists scrambling to test into the grandfathering period this Fall.  Another estimates that 40% of their clients will lose services at their clinic.

Mr. Gray also asked the smart question of how many service members and their families were being referred off base to community supports.  The military was unable to comment, making it difficult to know the full extent of the difficulties faced.  He followed up by starting to address the related scandal of the Veteran’s Administration CACREP-only policies.

As one of our staff members interviewed in the article put it, “with the current bright spotlight on veterans’ lack of mental health care and VA wait times, we are amazed that tens of thousands of qualified professional counselors being cut out by CACREP-only policies is not a national scandal.”

We hope this is the first of many stories focusing on how TRICARE and VA CACREP-only policies damage communities nation-wide.