Download OCAcomments Medicaid rule

August 26, 2015
Common Sense Initiative
77 South High Street, 30th Floor
Columbus, OH 43215
RE: Draft Rule 5160-08-05
On behalf of the Ohio Counseling Association (OCA), I would like to take this opportunity to provide
comments on the proposed new rule OAC 5160-08-05 Mental Health Services.
The Ohio Counseling Association is the professional organization representing licensed professional counselors,
licensed professional clinical counselors and school counselors in Ohio.
Licensed Professional Clinical Counselors (LPCC) can independently diagnose and treat mental and emotional
disorders. These services facilitate care with individuals, families, and groups to address and treat emotional and
mental disorders and to promote mental health. A licensed professional clinical counselor holds a minimum of a
master's degree in counseling. After obtaining a master's degree, mental health counselors complete two to three
years of clinical work under the supervision of a licensed or certified mental health professional before they are
permitted to practice independently. Similarly, Licensed Professional Counselors can diagnose and treat mental
and emotional disorders under appropriate supervision and have rigorous education and training requirements in
these areas.
The Ohio Counseling Association has concerns with the current billable codes available to counselors. OCA
would like to ensure that all consumers of Ohio are able to receive the counseling services that they need to live
a healthy and productive life.
The Ohio Counseling Association encourages you to reconsider the proposal to set the rate of reimbursement
for “independent practitioners” and “supervised practitioners” at 85%. By limiting the reimbursement of 85% of
the rate set for other comparable providers like psychologists, counselors would be limited in their ability to
provide services to the Medicaid population, a population with a strong need for these services. This would
limit professional job opportunities, deter skilled professionals from contracting with Ohio Medicaid, and create
barriers for employers in attracting and retaining highly skilled staff to serve the Medicaid population all of
which contribute to service access challenges Ohioans seeking treatment and recovery experience.
The State of Ohio has made mental health and addiction services a top priority for all Ohioans but particularly,
the Medicaid population. We applaud the Department of Medicaid for their efforts to expand access to mental
health services by expanding the definition of eligible licensed providers that may directly contract with Ohio
Medicaid and be reimbursed for the provision of mental health services.
We recommend reimbursing all licensed professionals eligible to receive payment under this rule at one
hundred percent of the fee schedule as defined in 5160-1-60, Appendix DD. This would ensure all Ohioans,
including the Medicaid population, would have the opportunity to seek mental health and addition care and
eventually be removed from government support.
Thank you for taking into consideration the concerns of the Ohio Counseling Association. We appreciate the
opportunity to share our concerns and comments. We look forward to working with you on this rule moving
forward. If you have questions regarding this issue, please contact OCA representatives Amanda Sines or
Mikayla Pollitt at 614-221-7157.