Starting January 1, 2024, the Centers for Medicare & Medicaid Services (CMS), Medicare began covering certain services for dually eligible beneficiaries (those enrolled in both Medicare and NC Medicaid Direct) who receive NC Medicaid coverage. This includes services furnished by the following providers: Marriage and Family Therapists (MFT) or Mental Health Counselors (MHC), as well as Intensive Outpatient Program (IOP) services furnished by Hospital Outpatient Departments, Community Mental Health Centers (CMHC), Rural Health Clinics (RHC), Federally Qualified Health Centers (FQHC), or Opioid Treatment Programs (OTP).

CMS noted in the informational bulletin regarding this update that not all providers of these services will be enrolled with Medicare as of January 1, 2024. To prevent any disruption in services for dually eligible beneficiaries, CMS provided options to State Medicaid Agencies to facilitate a smooth transition. As a result, NC Medicaid adheres to the following expectations:

All providers enrolled in Medicare should start billing Medicare for these services immediately. While NC Medicaid will continue to pay for these services as though Medicaid is the primary payer for a period of time as described below, it will be more efficient for all parties if providers bill Medicare as soon as possible.

Providers not enrolled with Medicare may, but are not required to, hold claims for the provision of these services until becoming enrolled with Medicare. Providers newly enrolled in Medicare may request a retrospective billing date for up to 30 days prior to the effective date of their Medicare enrollment, but no earlier than January 1, 2024.

Regardless of a provider’s Medicare participation status when provider submits claims to NCTracks, NC Medicaid will:

  • Continue to reimburse for these services through May 31, 2024, as primary payer.
  • Deny claims for these services beginning June 1, 2024, if billed as the primary payer.
  • Adjudicate claims beginning June 1, 2024, as the secondary payer for these services.

Information about how to enroll with Medicare is available on the CME Become a Medicare Provider or Supplier webpage and MFT and MHC Provider Enrollment Frequently Asked Questions.

For question, contact NCTracks Call Center: 800-688-6696