ACTION 2 (NYS) CRC’s and Health Care Reform

CRC’s Help support inclusion of Habilitative and Rehabilitative Services in NYS Essential Health Benefits (EHBs)

Inclusion of rehabilitation counseling services as an Essential Health Benefit (EHB) is critical as EHBs will set the minimum benefits required of all health plans purchased through state health insurance exchanges, as well as individual and small employer plans purchased outside of the exchanges.  And while the 2010 Patient Protection and Affordable Care Act (PPACA) specifically requires EHBs to include rehabilitative and habilitative services and devices, there is no clear definition of those services in the act.

If states do not mandate provisions for rehabilitative services in their EHBs, then rehabilitation counseling services will not be required of insurance companies who are developing and providing plans to be made available on state health benefit exchanges and thus covered within state health exchange insurance plans. Put simply, there will be no provision for rehabilitation counseling services and thus no insurance coverage for rehabilitation counseling services nor for CRCs as providers of such services.

It is critical that New York State be alerted as to the vital importance of rehabilitative services and rehabilitation counseling so they give due consideration to its inclusion in their determination of Essential Health Benefits.

In March 2012, the Commission on Rehabilitation Counselor Certification (CRCC) issued communications to each state’s insurance commissioner and health reform implementation official to:

  • comment on state deliberations of what constitutes an Essential Health Benefit;
  • ensure state officials understand rehabilitation counseling and its vital role in assisting Americans with disabilities;
  • ensure state officials recognize that rehabilitation counseling is a necessary part of both rehabilitation and habilitation services;
  • urge that state health benefit exchanges cover both rehabilitation and habilitation services, as well as Mental Health and Substance Use Disorder Services from all qualified providers, including rehabilitation counselors and Certified Rehabilitation Counselors; and,
  • reinforce the monetary savings resulting from rehabilitation counselors providing cost effective coordination of care for Americans with disabilities including specialized training that allows rehabilitation counselors to fill a variety of service-provision roles efficiently. Such roles include disability and case management as well as career, vocational, mental health, and substance abuse/addictions counseling.

While the actions of CRCC are vital to states’ consideration and inclusion of rehabilitation services in establishing their EHBs, they alone are not enough. It is critical for CRC voices to also be heard at the state level.

Letters should be mailed as soon as possible to ensure state legislatures read and discuss within state departments, commissions, etc. before key decisions are made.

This is a critical juncture for the profession of rehabilitation counseling:
»  Advocate for your profession!

»  Advocate for your CRC credential!
»  Advocate for your future!

AVRASA is in full support of inclusion of Rehabilitation Counseling as an essential health benefit.  If you would like to help advocate for inclusion, please copy and paste the attached letter in an email to the following NYS Legislators (PLEASE MAKE SURE YOU REVISE THE FIELDS IN RED BEFORE SENDING OUT): 

Use State Health Care Reform Authority/Insurance Commissioner Addresses’s:

Judith Arnold

Director, Department of Health

Office of Health Insurance Programs

NYS Department of Health

Corning Tower, Room 1619

Albany, NY 12237

[email protected]

Benjamin M. Lawsky


Department of Financial Services

25 Beaver Street

New York, New York 10004

[email protected]

CRCC Letter Template for Essential Health Benefits (EHB) Inclusion

[Your Return Address]


[State Health Care Reform Authority/Insurance Commissioner

Addresses’s from above] 

Re:  Essential Health Benefits for Americans with Disabilities

Dear [State Official Last Name from above]:

In March, you should have received correspondence from the Commission on Rehabilitation Counselor Certification (CRCC) concerning health care reform and Essential Health Benefits.  I am writing to you as a Certified Rehabilitation Counselor (CRC) working, residing and providing services to people with disabilities in NEW YORK STATE.

[In this paragraph, please describe how you practice rehabilitation counseling, or your role as an educator.  In addition, you may wish to indicate your education, licensure (if any), certifications, and how long you have been serving people with disabilities.  Please describe what services you, or your students, provide.  State officials need to know what kinds of services you are providing, and to whom.  As a person living or working in their state, state officials need to know how their constituents consume health care services and who provides those services.]

As CRCC mentioned in its correspondence, rehabilitation counselors are uniquely trained to assist individuals with physical, mental, developmental, cognitive, sensorineuro, and emotional disabilities to achieve their personal, social, psychological and vocational goals.  They counsel people with disabilities resulting from birth defects, illness or disease, accidents, or other causes.  Graduate programs in rehabilitation counselor education provide training on the medical, psychosocial, and cultural aspects of disability; assistive technologies; assessment; and disability legislation.  No other graduate programs require such specific disability training, all of which is focused on achieving employment and independent living for Americans with disabilities.

[Accordingly, please mention how you may provide any of the following:

  • Assessment and appraisal;
  • Diagnosis and treatment planning;
  • Career (vocational) counseling and determination of the need for job retraining;
  • Individual and group counseling treatment interventions focused on facilitating adjustments to the medical and psychosocial impact of disability;
  • Case management, referral, and service coordination;
  • Program evaluation and research;
  • Interventions to remove environmental, employment, and attitudinal barriers;
  • Consultation services among multiple parties and regulatory systems;
  • Job analysis, job development, and placement services, including assistance with employment and job accommodations; and
  • Consultation about and access to rehabilitation technology.]

I am writing to support CRCC’s request that you consider the role of rehabilitation counseling as you review federal guidance on Essential Health benefits to determine how your health plans will best cover the unique needs of Americans with disabilities.  Rehabilitation counseling is an essential part of both rehabilitation and habilitation services – I urge you to give it due consideration.


[Your name]

Certified Rehabilitation Counselor (CRC)


From: Michele Buoninfante, CRC, President [mailto:[email protected]]

Advocacy Leader: Obie Nichols, PhD, CRC, Board [mailto: [email protected]]