You need a license or compact privilege in each state where Medicare beneficiaries are located, and CMS requires a separate CMS-855I enrollment for each state where services are rendered. Telehealth-only counselors should also plan for the in-person visit requirement for mental health telehealth that applies after December 31, 2027.
Counselors who build a telehealth caseload across several states usually discover Medicare's structure one beneficiary at a time. It is easier to learn it once. There are three layers, and each one is per state or per client.
Layer one: a license where the beneficiary is
CMS requires the practitioner to be licensed in each state where services are rendered, and the license goes on the application. For telehealth, the state where services are rendered is the state where the beneficiary is located. Nothing about Medicare changes the ordinary licensure rule; it just adds a payer that checks.
The Counseling Compact helps here. CMS's MFT and MHC FAQ says Medicare "recognizes licenses obtained through the interstate license compact pathway as valid, full licenses for the purposes of meeting federal license requirements," citing its guidance in SE20008. A counselor with a privilege to practice in a member state that is issuing privileges can rely on it for Medicare. See the Counseling Compact hub for which states are live.
Layer two: an enrollment for each state
This is the part people do not expect. CMS states that "a separate CMS-855I enrollment is required in each state where services are rendered." Enrolling in Georgia does not let you bill for a beneficiary in Tennessee, even if the same Medicare Administrative Contractor handles both states. Each enrollment produces its own PTAN.
If you bill through a group, CMS's own telehealth example is instructive: a practitioner working from home in Florida who reassigns benefits to a group in Maryland enrolls in Maryland, where the group submits the claims. The enrollment follows the billing entity's arrangement. The license still has to follow the beneficiary. Those can be two different states, so check both.
Every additional enrollment also means another record to keep current and another revalidation date. White Glove Credentialing manages multistate enrollments; we hold up the licensing end.
Layer three: the in-person rule after 2027
Medicare's broad telehealth flexibilities run through December 31, 2027 under current law. Mental health telehealth to a beneficiary's home is permanent in statute, but it comes with an in-person requirement that has been delayed several times and now applies after December 31, 2027. CMS's telehealth FAQ (updated February 2026) explains how it will work:
- For a new patient, an in-person, non-telehealth visit is required within the 6 months before the first mental health telehealth service.
- After that, there must be an in-person visit within 12 months of each mental health telehealth service, with limited exceptions.
- A beneficiary who began receiving mental health telehealth at home on or before December 31, 2027 is treated as established. CMS does not apply the 6-month rule to them, but they need at least one in-person visit every 12 months after that date.
- The in-person visit can be done by a practitioner of the same specialty in the same group practice if you are not available.
For a counselor whose Medicare clients live in a state you have never set foot in, this is a planning problem with a deadline. Your options are to travel for annual visits, partner with a same-specialty colleague in your group who practices near the client, or accept that some clients will need a local clinician. Congress has moved this date before. Plan as if it will hold, and watch for changes.
Through 2027, CMS also permits audio-only telehealth in the home. From January 1, 2028, audio-only for behavioral health remains available when you can use video and the beneficiary cannot or does not consent to it.
Seasonal clients
Snowbirds are the classic Medicare multistate case, and White Glove MFT has a good treatment of the pattern in Medicare clients in more than one state. The counselor-specific difference is the compact. MFTs have none; counselors can add a privilege for a member state that is issuing, which is often quicker than a full license. If your winter state is California, Texas, New York or another non-member, you are looking at a full license; our temporary practice table shows whether that state offers anything shorter for existing clients.
A per-state checklist
- License or compact privilege active in the beneficiary's state.
- A CMS-855I enrollment for that state, or a reassignment to a group enrolled there.
- A revalidation date and a license renewal date on your calendar for each.
- For telehealth-only clients, a plan for the in-person visit rule after 2027.
For the enrollments, our sister company White Glove Credentialing does the filing. For the licenses and privileges, see our pricing or the state pages under counselor licensing by state.
Common questions
- Does Medicare accept a Counseling Compact privilege instead of a full license?
- Yes. CMS says it recognizes licenses obtained through an interstate compact pathway as valid, full licenses for federal license requirements. The privilege must be active in the state where the beneficiary is located.
- If I'm enrolled in Medicare in one state, can I see Medicare clients in another?
- Not on that enrollment. CMS requires a separate CMS-855I for each state where services are rendered, plus a license or privilege in each. You will receive a separate PTAN for each state.
- Will I have to see my Medicare telehealth clients in person?
- Under current law, after December 31, 2027. Established clients need an in-person visit at least every 12 months; new clients need one within 6 months before the first telehealth service. A same-specialty colleague in your group can do the visit.
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