September 11, 2024
Dear CSWA Members,
A notice about new Mental Health Parity rules to implement the long-standing Mental Health Parity and Equity Act (2008), which has been languishing since it was first enacted, was put out this week. The recent articles from ProPublica may have influenced the release of these rules at this time.
A review of the history of the MHPAEA can be found at https://www.cms.gov/marketplace/private-health-insurance/mental-health-parity-addiction-equity. The basic premise is that mental health treatment and substance use treatment be covered as fully as medical/surgical treatment. The primary areas where this applies include inpatient in-network; inpatient out-of-network; outpatient in-network; outpatient out-of-network; emergency; and prescription drugs. The problems in applying these reasonable standards is that there is no formula for what they should actually be, and reimbursement is not included in the areas that must be at parity for mental health treatment.
While any attempt to get insurers to cover mental health and substance use is worthwhile, until real enforcement is built into the rules – which is still not the case in the new rules – there will likely be little change to the ways that insurers currently limit coverage of mental health treatment.
Note that these new rules will go into effect in phases, with some being enacted in 2025 and some in 2026.
Please let me know if you have any questions.
Laura Groshong, LICSW, CSWA Director of Policy and Practice lwgroshong@clinicalsocialworkassociation.org
White Paper from ProPublica on State Mental Health Regulations
September 3, 2024
ProPublica has released an additional white paper on mental health. This companion piece to the article sent last week (see previous announcement) reviews the ways that states do or do not have regulations about coverage for mental health treatment. This is based on the same problems identified in the paper titled “Why I Left the Network.”
To read the entirety of the additional paper, written in collaboration with NPR, please visit https://www.propublica.org/article/mental-health-wiltn-states. To read the NPR summary, go to https://www.npr.org/sections/shots-health-news/2024/08/23/nx-s1-5084256/insurance-mental-health-care-coverage-legal-protection?utm_source=pocket-newtab-en-us.
White Paper from ProPublica: “Why I Left the Network”
August 2024
ProPublica is one of the most respected investigative journalism groups in the country. For the past year they have been looking at various ways in which insurers do not provide mental health services and/or payment, either before or after they are needed/provided. I spoke with them for about two hours on the problems LCSWs and others have been struggling with in regard to insurance coverage and payment over the past six months. They have published an excellent white paper on this topic, documenting much of what LCSWs and other clinicians in private practice have known for decades.
The continued lack of payment, harassment by reviewers, clawbacks, inadequate networks, refusal to explain denials of care, rejection of payment because claims are deemed faulty without specific requests for more information, and refusal to abide by federal and state laws about mental health parity are discussed in detail. The result has been continued decisions by clinicians to leave insurance networks.
No one wants to see patients go without care, end treatment prematurely, or have income slashed so much that we cannot make a living. It is articles like “Why I Left the Network” that may finally bring the scope of the problem to legislators and the public so that something can be done about the abysmal ways that LCSWs are treated unfairly by many insurers.
To read the complete white paper, go to https://projects.propublica.org/why-i-left-the-network/. To see a summary put together by NPR, please visit https://www.npr.org/sections/shots-health-news/2024/08/24/nx-s1-5028551/insurance-therapy-therapist-mental-health-coverage. CSWA will offer some suggestions shortly about how to inform legislators about the scope of these problems.
Introduction to Clinical Social Work Core Competencies
CSWA is pleased to let members know about this 50+ page white paper, “Core Competencies for Licensed Clinical Social Workers”. For the past two years, an ad hoc committee has been working on this summary of the ways that clinical social workers develop their knowledge, skills, and expertise. These competencies are divided into 4 different levels of understanding: Novice, Intermediate, Advanced/Independent, and Expert. This document is intended to be a definitive statement on what clinical social workers should strive towards throughout their practice. Additional information about the purposes and intentions of the white paper are in its introduction.
There are 25 areas of clinical social work practice that are discussed in this paper: Ethics, Laws, and Regulations; Confidentiality; Informed Consent; Self-Determination; Supervision and Consultation; Documentation; Continuing Education; Independently Treats Individuals, Couples, Families, and Groups Using Generally Accepted Methods of Psychotherapy; Therapeutic Alliance in Psychotherapy; Assessment in Psychotherapy Practice; Risk Assessment in Psychotherapy Practice; Delivery of Psychotherapy Services; Diagnostic and Statistical Manual; Goal Setting; Self-Disclosure and Boundaries; Transference and Countertransference; Evidence-Based and Evidence-Informed Modalities; Trauma; Evaluating Treatment Outcomes; Termination of Psychotherapy; Social Justice; Discrimination and Bias; Diversity; Interdisciplinary Relationships Within Mental Health Care; and Therapist Self-Care.
CSWA hopes you find this document helpful in understanding the complexity of the clinical social work profession.
Download the white paper to review it today.
Biden-Harris Administration Proposes $2.5 Million in Support of Social Work Compact
July 22, 2024
The Department of Health and Human Services, through the Health Resources and Services Administration (HRSA), announced the first-ever Licensure Portability Grant Program, which is an investment in the multi-state social worker licensure compact. This grant will provide $2.5 million in support of the Social Work Compact. This welcome support will make the implementation of the Compact easier and may be less of a financial burden for LCSWs who live in states that have passed the Compact and choose to join as individuals. Please visit the U.S. Department of Health and Human Services website for more information.
More details about the Compact will be forthcoming after the September 17 meeting to establish the Commission that will be running the Compact, which I will be running as Interim Chair. CSWA will continue to provide information about the Compact as it develops.
Laura Groshong, LICSW, Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
As of July 9, there are 22 states that have passed the Social Work Compact! This is the fastest level of passage that any of the 14 compacts have achieved. The Council of State Governments (CSG) was very impressed with the speed by which our Compact has gotten passed.
As you know, the next phase of Compact development now goes into effect. The Compact will be run by a Commission, which will be created on September 17, 2024. Each Compact state will appoint a representative to be part of the Commission, and the Commission Chair and other leadership positions will be filled at the September meeting.
We are pleased to inform members that CSWA's Director of Policy and Practice, Laura Groshong, LICSW, has been asked to be the Interim Chair to facilitate electing the Commission’s permanent leadership. CSWA and other major social work organizations (NASW, ASWB, and CSWE) will have ex officio members on the Commission, if the Commission rules allow for this provision.
The Compact will officially go into effect in 12-18 months. The rules will be made available by the Commission as they are developed.
To see the list of states which have passed the Compact to date, go to the CSWA Home Page at https://www.clinicalsocialworkassociation.org/. More reports will be forthcoming as they are available.
World Health Organization Limits Mental Health Treatment Methods
PsiAN Petition
This month, the World Health Organization (WHO) issued recommendations for the types of mental health treatment that would redefine the psychotherapeutic treatment methods which should be regarded as “evidence-based”. It is called the “Psychological Interventions Implementation Manual”. To view the manual, please visit https://www.issup.net/files/2024-03/psychological%20interventions%20implementation%20manual.pdf.
CSWA is concerned about the way that these revisions would limit the types of mental health treatment that are considered “evidence-based”, many of which have been long-established as valid treatment methods by the American Psychiatric Association, the American Psychological Association, the Substance Abuse and Mental Health Services Administration, Medicare, the Mayo Clinic, and many other leading mental health organizations.
The primary changes affect longer term forms of treatment such as psychodynamic methods. According to the Psychotherapy Advocacy Network (PsiAN), the “recommendations…predominantly endorse behavior therapy (BT) and cognitive-behavior therapy (CBT). This overlooks the significant evidence supporting other therapeutic approaches, including but not limited to psychodynamic therapy. It's likely that these guidelines will restrict access to those approaches by giving insurers, clinics, and policy makers a justification for denying coverage for all but the mostly short-term, structured and symptom-focused treatments.”
Additionally, PsiAN notes that “Behavior therapy (BT) and cognitive-behavior therapy (CBT) should not be represented as the sole effective treatments for mental health disorders. While they unquestionably are effective for some patients, a number of independent analyses and meta-analyses of BT/CBT studies have raised significant questions about the strength of the evidence for these approaches which argue against their being represented as a ‘gold standard’”. Some points that support this position are:
CSWA encourages all members to consider signing the PsiAN Petition to WHO, objecting to these arbitrary changes which will harm patients who benefit from psychodynamic treatment. To view and sign the petition, please visit https://docs.google.com/forms/d/e/1FAIpQLSeV5toz31ab2v-feDPgnLYfmg6OidsI7FRaHc5EKi-sPtlIcQ/viewform.
Clinical social workers should be able to use all mental health treatment methods that have established successful standards of practice, including psychodynamic treatment.
As always, please let me know if you have signed this petition.
Update on Social Work Compact
May 7, 2024
by Laura Groshong, LICSW, Director of Policy and Practice
CSWA is delighted to let members know that the Social Work Compact is about to become a reality! There are now 12 states that have passed the Compact which means that the Commission that oversees the Compact will be created starting this fall. See the summary of the process this will involve below. If you live in a state that has joined the Compact, you may request that your Social Work Board consider you as a representative to the Commission. CSWA and other major social work stakeholders will have ex officio members if the Commission approves this option. Keep in mind that the process for joining the Compact will go through your home state; however, complaints may be filed in any state in which the LCSW is able to work through the Compact.
Social Work Compact Implementation Timeline
On April 12th, 2024, the Social Work Licensure compact officially became enacted in seven states: Missouri, South Dakota, Washington, Utah, Kentucky, Virginia, and Kansas [in the past three weeks Vermont, Nebraska, Iowa, Georgia and Maine have also passed the Compact bill]. This marks a significant milestone in the development process as the compact specifies that it will come into effect upon enactment of the seventh member state. The social work compact allows eligible social workers to practice in all states that join the compact.
While the social work compact legislation specifies that the compact needs seven member states to become active, social workers cannot yet practice in other member states. The implementation process for the compact will take approximately 18-24 months before social workers can begin applying for multistate licenses. A timeline of this process can be found below:
State Commissioner Nominations – Summer 2024
Each new member state must appoint a commissioner to serve on the compact commission. The commissioner is selected by the state’s social work board and can be the current administrator of the social work board or their designee, a board member who is a social worker, or a public member of the board. Once all commissioners have been elected, the Social Work Compact Commission will convene for its first inaugural meeting.
Inaugural Commission Meeting – Fall 2024
At the inaugural meeting, the Commission will elect an executive committee, appoint officers, establish a subcommittee structure and approve the initial bylaws and rulemaking processes that will govern the compact. All compact commission meetings will be open to the public. The Council of State Governments (CSG) expects this inaugural meeting to happen early in the fall of 2024.
Establishing the Compact Data System - Ongoing throughout 2025
After the inaugural meeting, the compact commission will continue to work on operationalizing the compact, including acquiring a data system. The data system is a foundational piece of compact operations where member states communicate licensure information with each other and with the compact commission. CSG expects development of the data system to take approximately 10-12 months.
Once the data system is fully developed, states will be onboarded to the new system. It is expected that states will have varying timelines to onboard and will be largely dependent on the state’s current licensure infrastructure.
Additional Compact Commission Meetings – Ongoing throughout 2025
The compact commission will hold subsequent commission meetings throughout 2025 for additional rulemaking to establish a fee structure and application process, and further define compact participation requirements. The commission will also hire staff, select a secretariat organization, and take additional steps for the compact to move towards being fully operational.
Multistate License Applications Open – Target Date of Fall 2025
Once the data system is operational in states and the commission has finalized all necessary rulemaking, applications will be made available for social workers to apply for a multistate license. Once eligibility is confirmed by the home state, all fees are paid, and a social worker is granted a multistate license, they will be able to practice in all other member states of the compact without any further steps necessary. The Home State Licensing Authority shall issue a Multistate License that authorizes the applicant or Regulated Social Worker to practice in all Member States under a Multistate Authorization to Practice.
ProPublica is preparing a series on the difficulties with getting access to mental health treatment. They have asked for CSWA’s help in gathering information about this topic.
If you are open to being a source for them, whether you have had direct experience with denials of care or not, visit their newly published form at this link: https://www.propublica.org/getinvolved/tell-us-about-mental-health-care-access. It should not take more than 2 minutes to fill out. If you are interested, please complete the form by March 10th.
Also, please let me know if and when you have sent your information.
The Social Work Workforce Coalition (a group comprised of various social work leaders across North America) will launch a social work census in March 2024.
To ensure our demographics and broad range of services and specialties are fully captured, everyone is encouraged to participate.
Please visit https://swcensus.org/ now to sign up for the census. You will then receive an email when the census opens.
Please view our Privacy Policy, Cookie Policy, Terms of Use and Refund/Cancellation Policy.
PO Box 105Granville, Ohio 43023
