clinical social work association

Implications of the End of the Public Health Emergency For LCSWs providing Telemental Health and Our Patients

February 1, 2022

Laura Groshong, LICSW, Director of Policy and Practice

As you have no doubt heard, the Public Health Emergency (PHE) will end on May 11, 2023. Continued coverage for telemental health treatment may depend on the insurance your patient holds when the PHE ends. Here is what we know currently.

Federal Government

CMS, which oversees Medicare and Medicare Advantage, has already announced that these programs will cover telemental health through December 31, 2024. CMS is reviewing the use of telemental health treatment and will make a decision, along with DHHS, about the future of expanded telemental health coverage after the end of 2024.

Some members of Congress are wanting to end the PHE immediately. The Senate and the President will not agree to this, so it is extremely unlikely that this will happen. Regardless, it will not affect the coverage of telemental health by Medicare and Medicare Advantage at this time.

Medicaid

All 50 states and DC expanded coverage and/or access to telehealth services in Medicaid during the PHE. When the PHE ends, coverage for telehealth services may be tied to federal and/or state PHEs. Most states have made, or plan to make, some Medicaid telehealth flexibilities permanent. 

Commercial Insurers

It is likely that some commercial insurers will no longer cover telemental health after May 11, 2023. I have heard that LCSWs have been told that telemental health will no longer be covered by commercial insurers NOW. Those companies should be reported to your Insurance Commissioner. As long as the PHE is in effect, telemental health should be covered.

Communication about commercial insurance has been spotty, so have patients check with their insurers. Some states, but not all, are putting laws into effect that will require commercial insurers to cover telemental health treatment.

Free Vaccines and COVID-19 Tests

Separate from the coverage of telemental health, the end of the PHE creates changes about who may receive free vaccines and COVID-19 test kits. A good summary of the changes that are coming has been put together by Kaiser Family Foundation at https://www.kff.org/coronavirus-covid-19/issue-brief/what-happens-when-covid-19-emergency-declarations-end-implications-for-coverage-costs-and-access/#coverage-costs-and-payment .

The Possible Impact on LCSWs

Many of us have converted our practices to exclusively provide telemental health and some us no longer have physical offices. The end of the PHE may require us to reconsider these decisions if telemental health does not continue in the way that we have been using it.

There is a lot of uncertainty at the moment, and CSWA will do our best to give you timely and accurate information about the situation.