Clemens, Elysia V.
Helm, Heather M.
Murdock, Jennifer L.
Applied Psychology and Counselor Education
University of Northern Colorado
Type of Resources
Place of Publication
University of Northern Colorado
Advocacy for the counseling profession necessitates a thorough understanding of the factors influencing the hiring and reimbursement of licensed professional counselors. The Patient Protection and Affordable Care Act (ACA) enacted several health care reforms that may influence the utilization of mental health services and the employment of mental health professionals. These reforms included the option for states to expand their Medicaid population (effective January 1, 2014), mental health parity requirements for most insurance plans including Medicaid plans, and increased funding for Federally Qualified Health Centers (FQHCs or health centers). FQHCs, created by Congress in 1989, provide primary care services, including mental health services, to approximately 24 million Americans annually and function as a vital safety net for medically underserved communities and populations. The largest source of revenue for FQHCs is Medicaid, and FQHCs receive enhanced reimbursement for services provided to Medicaid patients, known as the Medicaid Prospective Payment System (PPS) rate. Federal law, however, explicitly approves only certain health care professions as billable PPS providers. Licensed clinical social workers (LCSWs), along with psychologists and psychiatrists, are included as billable PPS providers under federal law, but not licensed professional counselors (LPCs). Some states have expanded the list of health care professions able to generate billable PPS encounters at FQHCs to include licensed professional counselors. It is vital for the counseling profession to understand the impact of these reforms and the interplay of federal and state policies related to reimbursement upon the mental health industry. The optional Medicaid expansion provision of the ACA created an opportunity for a natural experiment to compare mental health service utilization and employment at FQHCs in Medicaid expansion states versus non-Medicaid expansion states. This quasiexperimental study first tested the causal impact of Medicaid expansion on the number of mental health visits and full-time equivalent (FTE) mental health staff at FQHCs, using state-level data gathered from FQHC reports submitted annually to the Uniform Data System. A count model difference-in-differences analysis strategy compared utilization and employment numbers in 2012-2013 (pre-Medicaid expansion) and 2014-2015 (post- Medicaid expansion) between Medicaid expansion states and non-Medicaid expansion states. Then, a two-sample test of proportions utilizing data from a research-developed employment survey examined the relationship between states approving counselors and states not approving counselors as billable FQHC mental health providers under the enhanced PPS reimbursement and the proportion of LPCs at FQHCs (of the total number of LPCs and LCSWs). In both groups of states (Medicaid expansion states and non-Medicaid expansion states), it was evident that there was a substantial increase in the number of mental health visits and FTE mental health staff at FQHCs from 2012 to 2015. Contrary to prediction, the first count model difference-in-differences analysis indicated that non-Medicaid expansion states had a significantly higher rate of change in the number of mental health visits from pre-Medicaid expansion (2012-2013) to post-Medicaid expansion (2014- 2015), as compared to Medicaid expansion states (α = .05, p = .01). Then, contrary to prediction, the second count model difference-in-differences analysis indicated that there was not a significant difference in the rate of change for the number of FTE mental health staff between Medicaid expansion states and non-Medicaid expansion states from pre- Medicaid expansion (2012-2013) to post-Medicaid expansion (2014-2015; α = .05, p = .13). As predicted, the two-sample test of proportions resulting from the survey responses of 138 FQHCs (60% response rate) indicated that there was a significantly higher proportion of LPCs employed at FQHCs in states approving LPCs as billable FQHC mental health providers under PPS as compared to states not approving LPCs (𝑍 = 4.24, p < .001, Cohen’s h = .76). Thus, counselor employment at FQHCs was significantly improved in those states approving counselors as billable PPS providers. It is essential for counselors to understand the impact of federal and state health care policies, such as Medicaid expansion, increased funding of FQHCs, and various Medicaid reimbursement methodologies, to successfully advocate for the profession in the dynamic health care landscape. Counselor educators have a responsibility to convey information to students related to the potential repercussions of billable mental health provider status on their employment opportunities following graduation.
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