A Comprehensive Look at Music Therapy Licensure

However, while board-certification is overseen at the national level (by the American Music Therapy Association for accrediting music therapy college degree programs, and by the Certification Board for Music Therapists for awarding the credential and approving CMTEs), state-level licensure adds another layer of complication.

Some states require state licensure. Others don’t. Some require what are known as registries, while other states require no further designation beyond the MT-BC to practice. In states without this additional layer of regulation, “music therapist” becomes less of a professional title and more of a catch-all term for anyone who wants to use it. And that complicates things very quickly.

But here’s the catch: If a state has no regulatory requirement, it also provides no title protection. And that means anyone - regardless of training, experience, or competence - can call themself a music therapist.

As we’ve stated before, the problem for music therapists isn’t getting people to want music therapy - it’s getting them to pay for it. And many claim licensure is a stepping stone to obtaining access to major payers like Medicaid. More on this later.

As it stands, this review appears to suggest that regulation may not create the effect the field hopes it might have on reimbursement pathways - at least not on its own. There are, however, other considerations that must be made as we continue the discussion on music therapy licensure.

Additionally, licensure could open doors for further opportunities outside of reimbursement. As policies vary per state, each has their own requirements for whom may be allowed to serve in certain settings. Working in schools, for example, can be limited to only licensed professionals. For music therapists looking to expand their reach to new populations and settings, licensure could potentially help to increase access to services.

It would be interesting to analyze - not only the states with regulation (and their respective funding opportunities and rates) - but the sequences each state took to pass licensure requirements and secure funding. If a state has licensure in place when reimbursement opportunity is created, licensure may provide the backing for better rates as part of an elevated sense of legitimacy.

Once legislation is passed, there are considerable costs - of time and money - for obtaining and maintaining licensure. In regulated states, music therapists must complete applications and pay fees to comply with these requirements. Some of these states require modest payment amounts, but for others, the initial fee alone exceeds hundreds of dollars. There are also fees associated with renewal. While these costs may sound nominal to some, those additional payments would be falling on practitioners who already cite low compensation as a chief contributor of burnout and attrition. If licensure then offers little to no return on investment by way of increased reimbursement opportunities or higher rates, it would seem reasonable to question whether or not these additional costs are in the best interests of practitioners.

Furthermore, some of the states regulating music therapy offer additional requirements for continuing education. So, while CBMT may mandate that music therapists complete 100 CMTEs in a 5-year period, certain states impose a more specific criterion, such as 40 hours of continuing education over two years. While feasible, the consequences for non-compliance are also more severe in a state where loss of licensure will result in being unable to practice entirely, as well as incurring additional fees, and having to complete more steps to have one’s license reinstated.

Finally, even states that offer something as simple as title protection can see complications arise from regulation. Once the scope of practice is determined and use of terms like “music therapist” are put into place, non-credentialed music therapists or providers of alternative approaches to music therapy are forced to devise a new name for their form of practice. While it can be debated that this form of title protection protects the public as it understands music therapy, it also creates confusion for what isn’t (but may look and sound like music therapy). These alternative approaches, as outlined in The Case For Licensure above, can serve to dilute the field and impose a need for music therapists to further differentiate ourselves and justify the additional costs of our services.

Rates appear to vary by waiver design, billing unit structure, state Medicaid policy, and budget allocation. Many regulated states have no reimbursement. Many non-regulated have reimbursement - some at viable or even high rates. The majority of reimbursement occurs through Medicaid waivers, Autism waivers, DD waivers, IDD programs, and specialized managed care programs. Based on this data, reimbursement appears to be more closely tied to waiver category, individual Medicaid agencies, state budgets, and politics.

Even if a state passes a licensure requirement, that isn't necessarily a path to reimbursement. It may, however, serve as a starting point. Following such legislation, it is incumbent upon those communities to advocate for Medicaid expansion, contract with commercial payers (whom will require evidence of cost savings and effectiveness), negotiate for viable rates, and advocate to develop opportunities in the field.

To be clear: I’m actually in favor of licensure, but only as a prerequisite. Even with title protection, regulation must be paired with music therapy-specific CPT codes, Medicaid expansion, and advocacy for higher rates. Without these, licensure designation risks increasing costs and administrative burdens for music therapists (and the community), with little to no return.

And while title protection can be beneficial to both therapists and the public, the current evidence on harm caused from a lack of music therapy regulation is limited. Furthermore, title protection may prevent non-credentialed professionals from calling themselves music therapists, but it will also mean that these providers will then begin to use new names for quasi-music therapy services that will cause further confusion for the public and dilute the identity of our evidence-based work.

The field could do well to not only emphasize licensure as the requirement for practice, but also devote efforts to illustrating how it is a superior modality to these other methods - not by mentioning education alone - but through evidence of improved clinical outcomes and patient experience of care.