On Friday, February 12, 2010, the Institutes of Medicine (IOM) released its final report titled Provision of Mental Health Counseling Services under Tricare. The IOM made the following recommendations, with the first one being to eliminate the supervision and referral requirement currently defining LMHCs’ practice under TRICARE, and the second one being directed to all cadres of licensed mental health professionals currently practicing under TRICARE.
Below are the recommendations and attached is an IOM report brief summary. The report itself is not yet law. However, recommendations arising from IOM panels commissioned by Congress and the Department of Defense usually receive deference by Congress and the Department of Defense, thus inspiring changes to existing laws which will parallel the IOM studies’ recommendations to Congress and the Department of Defense. To link to the full report, click on the following link: http://www.nap.edu/catalog.php?record_id=12813#toc
Recommendations
1) Independent practice of LMHCs in TRICARE in the circumstances in which their education, licensure, and clinical experience have helped prepare them to diagnose, and where appropriate, treat conditions in the beneficiary population. These circumstances include:
-A master’s or higher level degree in counseling from a program in mental health counseling or clinical mental health counseling that is accredited by the Council for Accreditation of Counseling and Related Educational Programs.
-A state license in mental health counseling at the "clinical" or the higher or highest level available in states that have tiered licensing schemes (community counseling programs won’t suffice)
-Passage of the National Clinical Mental Health Counseling Examination (passage of the NCE alone won’t suffice)
-A well-defined scope of practice for practitioners.
*The Committee found that LMHCs who do not meet these proposed requirements may still practice within the system of TRICARE but will be supervised with the opportunity to acquire greater levels of independent practice as their experience and demonstrated competence increase.
2. A comprehensive quality management system for all mental health professionals, with this system including:
-Well-defined scopes of practice and clinical privileging of all TRICARE mental health providers consistent with their professional education, training, and experience.
-Promotion of evidence-based practices for treatment of conditions and monitoring of results.
-Focused training in the particular mental and related general medical conditions that are present in the TRICARE beneficiary population, and in military cultural competence.
-A systematic process for continued professional education and training to ensure continuing improvement in the clinical evidence base and accommodation of the changing needs of the TRICARE population.
-Development and application of quality measures to assess the performance of providers.
-Systematic monitoring of the process and outcomes of care at all levels of the health care system and application of effective quality improvement strategies.
*The IOM panel determined that the coursework required by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) helps prepare counselors to serve as independent practitioners. It also found the National Clinical Mental Health Counselor Examination (the NCMHCE) best tests the experiences and competencies of mental health counselors to practice independently.
*The TRICARE IOM panel could not find any evidence distinguishing LMHCs from other cadres of licensed mental health professionals in their ability to serve in an independent capacity or provide high quality care. The panel’s research pointed to the need for a quality management system to ensure that all mental health professionals serving TRICARE beneficiaries provide care so TRICARE beneficiaries receive the “proper diagnosis and treatment for disorders.”
***Please call AMHCA Director of Legislative Affairs, Julie A. Clements, J.D. (Phone: 800-326-2642 x 105), if you have any particular questions about the report’s content and applicability. The above brief is meant to provide you with some of the nuances in the IOM recommendations.***