Congress should adequately fund Department of Defense (DOD) behavioral healthcare, and should prod DOD to improve access to mental health services provided by licensed Marriage and Family Therapists (MFTs) at DOD facilities by eliminating specific bureaucratic obstacles.
MFTs are licensed in every State and D.C. to provide a full range of behavioral-health diagnostic and treatment services. They hold a minimum of a Master’s degree and are the only behavioral-health profession required to obtain training in relational aspects of behavioral problems, such as how a Servicemember family, fellow Servicemembers, and friends may affect that Servicemember’s problems. A growing number of MFTs have training in clinical areas of special interest to the military, such as family-separation issues and Post Traumatic Stress Disorder.
In 2004, Congress enacted PL 108-375, Section 717, which clarified prior law at 10 USC § 1091 (for DOD contractor staff) and § 1094 (for DOD civilian employees), explicitly providing that the Department may hire MFTs for clinical positions. MFTs serve in all Service Branches in military hospitals and clinics (Military Treatment Facilities), Family Advocacy programs, and the Chaplain Corps. MFTs in private practice are eligible to be TRICARE providers.
It appears MFTs’ most frequent military roles are as: 1) TRICARE providers, and 2) DOD contractor healthcare staff. Historically, the Navy/Marines has been the Branch using MFTs most widely, but in recent years, the Army has added about 150 MFTs as contractor hospital/clinic staff and also added a number as Army Substance Abuse Program (ASAP) civilian employees.
Because MFTs serve in a wide variety of military settings and job types, specific situations pose different challenges:
- TRICARE providers: No known problems at this time. But provider payments under the TRICARE Fee Schedule are tied to the Medicare Part B Physician Fee Schedule, which by law will be cut across-board by about 30% on 1 January 2013, unless Congress acts to prevent this.
- Contractor healthcare staff: As these positions generally are for short terms (e.g. 2 years), promotional and "career" opportunities are rare. Also, there are reports of MFTs whom contractors have hired away from existing jobs, only to find that DOD has then cancelled or early-terminated its contractor agreements, leaving these MFTs without jobs or apparent legal recourse.
- DOD civilian employees: The key problem here is the lack of a Government-wide (or DOD- wide) MFT-specific Job Classification system. Thus, MFTs are hired under one of the following Job Series: 0101, Social Science (not elsewhere classified); 0180, Psychology (generally as Counseling Psychologist), or 0185, Social Work. None of those Series fully describe the skills, experience, or State Licensure status of MFTs, thus impeding MFT hirings, promotions, and lateral transfers.
Only the Office of Personnel Management (OPM) may promulgate a new Job Series, and only upon petition of an Agency. In response to Congress’s 2006 enactment of PL 109-461 establishing 38 USC § 7401(3) to permit the Department of Veterans Affairs (VA) to hire MFTs, VA petitioned OPM for an MFT-specific Series, but when that did not occur, VA established an Agency-specific Series. Discussions between staffs of OPM and the American Association for Marriage and Family Therapy (AAMFT) indicate that OPM may establish an MFT-specific Job Series as part of its current review of multiple behavioral-health Series, but that such action would not occur until at least mid-2013.
In addition to this DOD-wide job classification problem, AAMFT is aware of recent problems in the Army Substance Abuse Program (ASAP). On 26 July 2011, Army Secretary McHugh issued a memo regarding another behavioral-health profession, Counseling, permitting ASAP to hire Counselors, but only if they hold degrees from academic programs accredited by the Council for Accreditation of Counseling and Related Educational Programs. It appears this change, coupled with the functional transfer of ASAP from Army MEDCOM to INCOM, has created uncertainty about the ASAP job criteria applicable to MFTs. This has reportedly resulted in a freeze in MFT hirings and promotions within ASAP, at a time when the rate of substance-use disorders among Soldiers is growing.
A further concern is uncertain funding for the Family Advocacy programs (known as Family Support in Navy/Marines). Military family life entails stresses ranging from a Servicemember’s deployment and familial separation, to his or her potential death or injury, to readjustment challenges upon return. Yet the Family Advocacy programs are sometimes funded through makeshift sources such as Global War on Terror (GWOT) monies.
Pending Sequestration of DOD Funding
The 2011 Budget Control Act (PL 112-25) provides that, absent Congressional action by 2 January 2013, DOD will incur an aggregate funding cut of approximately 10%. As DOD naturally would subsequently minimize cuts to Forward Operations, sequestration could well cause disproportionate cuts in civilian and contractor healthcare staffing.
- Reach agreement to avoid any Budget Sequestration funding cuts.
- Urge DOD to either petition OPM for a Government-wide MFT Job Series, or establish an analogous DOD-specific Series.
- Prevent TRICARE Fee Schedule pay-rate cuts (either as a result of fixing the Medicare Fee Schedule, or by de-coupling TRICARE from that Schedule).
- Press DOD to expedite correction of the cited bureaucratic impediments to hiring MFTs as civilian and as contractor staff.
If you have any questions or need additional information, please contact:
Brian Rasmussen, PhD
AAMFT Government Affairs Manager
112 S. Alfred St.
Alexandria, VA 22314
Direct Phone: (703) 253-0463