clinical social work association

There have been many questions about the status of the telemental health expansion of Medicare and private insurers as the COVID-19 crisis itself has rapidly expanded.  Here is what CSWA knows so far.

The emergency bill signed on March 6 allows for an expansion of Medicare telehealth services of all kinds, once guidance from CMS and HHS is made available.  There is no definite date when this will happen, but we hope to have it within two weeks. 

CSWA, NASW, and the American Psychological Association will be sending a letter to CMS and HHS tomorrow encouraging them to allow a temporary expansion for patients that we have been seeing within the past three years.  The option that is currently being discussed per the March 6 bill is videoconferencing only, not telephonic sessions.  Of course CSWA hopes that telephone sessions will be allowed as well, but it is unlikely that it will be as soon as videoconferencing is covered.  It is a possibility that when videoconferencing is expanded by CMS, it will be retroactive to February, 2020.

As for private insurers, there is confusion about what they are willing to cover through videoconferencing and telephonically at this time.  Most companies that offer coverage are doing it for in-network providers only, who must use a specific telemental health platform and accept the fee offered.  This is generally less than LCSWs are used to being paid by these insurers for in-person sessions.  Out-of-network providers may or may not have the option of being covered for videoconferencing or telephonic sessions.  It is VERY important to check with any private insurers you have been reimbursed by, if you want to know the facts about their policies at this time.  Having patients call to find out what their policies are and request videoconferencing and/or telephonic coverage if necessary, is a good idea as well.

Another question is coverage for patients who live in a jurisdiction in which you are not licensed, for example, a patient has previously come to your office in Washington, DC, but lives in Maryland. You are licensed in Washington, DC, not Maryland, so would be practicing without a ;license if you treat the patient through videoconferencing while they are in Maryland.  I recommend calling the Social Work Board in any state in which a patient resides in which you are not licensed, to ask what their policy is on videoconferencing with patients (or telephonic sessions) who reside there. Again, there may not be good solutions here if the state insists that you be licensed in the state in which the patient resides.  Have patients call the Social Work Board in their state and ask for an exemption. 

Finally, there is the question of what to do if you have already moved to videoconferencing or telephonic sessions to protect you and your patients from becoming infected by COVID-19; it is problematic if you want to continue getting reimbursed by third party payers who currently do not cover videoconferencing.  You can continue to provide sessions through videoconferencing with the hope that they will be covered eventually; take a break while this is sorted out; or make arrangements with patients to pay privately.  None are ideal. 

I hope we will have some clarity on telemental health expansion soon and will keep you posted.  This is a unique and troubling time for LCSWs, all mental health professionals, and our patients. CSWA will do everything possible to give us the ability to continue providing our needed services.

Laura Groshong, LICSW, Director, Policy and Practice, Government Relations Chair
Clinical Social Work Association
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