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.
Laura Groshong, LICSW, Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
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.
Here is an article in which I was quoted about the Social Work Compact extensively. The article is about the Social Work Compact, not a “single social work license”, but the text is very well done. Please find the article at this link:
https://news.bloomberglaw.com/health-law-and-business/states-pursue-single-social-work-license-to-boost-labor-supply
Licensed Clinical Social Workers (LCSWs) are the largest group of licensed mental health clinicians in the country, working in the public and private sector, providing psychotherapy and counseling on an individual, family and group basis in every state and jurisdiction. The acronyms below are the titles used in each state/ jurisdiction to designate independent clinical social work practice in that state. Here is a list of the number of LCSWs in each state with the exact title used in that state. This data was collected from state social work Boards and administrators in November, 2023. All LCSWs have requirements of two-three years post-graduate supervised experience and have taken a national exam. Most LCSWs are licensed to diagnose all mental health disorders in the Diagnostic and Statistical Manual-5-TR and future editions and to treat these disorders through psychotherapy when appropriate.
November 15, 2023
The recent communication about Medicare Advantage led to several questions. Please see answers below:
Will Medicare Advantage reimburse traditional Medicare paneled LCSWs? Since Medicare Advantage is a separate program from traditional Medicare, it does not reimburse claims for traditional Medicare.
Why does Medicare Advantage often pay less than traditional Medicare? Because Medicare Advantage plans are run by commercial insurers, some reimburse at less than traditional Medicare and some at a higher rate. Remember that traditional Medicare rates vary from region to region as well.
Should LCSWs accept Medicare Advantage, even if rates are lower, because it is all that some people can afford? Some people think of Medicare Advantage as a midway point between Medicare and Medicaid and want to accept these plans to offer services to lower income patients.
How can we make Medicare Advantage have reimbursement parity with traditional Medicare? Medicare Advantage is a completely different system from traditional Medicare with different reimbursement. Medicare Advantage reimbursement has reimbursement governed by commercial insurers; traditional Medicare has reimbursement governed by CMS. While CSWA has advocated for reimbursement parity in traditional Medicare (with medical/surgical reimbursement) and in commercial plans (with medical/surgical), there is no way to create parity between Medicare Advantage and traditional Medicare.
How can we improve access to mental health treatment in general? There is no one way to accomplish this but the new mental health parity rules and integration of primary care and mental health should help.
Do LCSWs have to be credentialed with Medicare to be eligible for Medicare Advantage? No. The reverse is true as well, i.e., LCSWs can be credentialed with Medicare without accepting Medicare Advantage patients.
Do LCSWs have to be credentialed with the commercial insurer sponsoring the Medicare Advantage plan? This varies, but in general it is not necessary to be credentialed with a commercial insurer to be reimbursed for a Medicare Advantage plan. Check with each plan.
How much will Medicare Advantage plans affect Medicare beneficiaries going forward? Many analysts have said that the Medicare Advantage plans will continue to grow to cover 50-60% of Medicare beneficiaries by 2030.
Please continue to send questions on Medicare Advantage as they occur.
Medicare Advantage (MA) plans have been heavily marketed for the past year or so. LCSWs have had many questions about what the difference is between MA plans and traditional Medicare. This summary of those differences may be helpful in understanding what mental health coverage patients have in these plans and how MA plans may affect coverage overall.
MA plans, known as Part C plans, are overseen by commercial insurers, i.e., United, Aetna, Cigna, BCBS, etc. The general goal of these plans is to improve profits; this is not different from the other plans that commercial insurers offer. Traditional Medicare, a public plan with Federal oversight, has an interest in keeping costs down balanced with an interest in giving the elderly and disabled reasonable health care.
Some Medicare Advantage plans inappropriately delay and deny critical care; have low premiums but then charge exorbitant copays that prevent people from getting care; have limited networks and few providers available; and may have networks with poor quality providers. Additionally, MA plans do not have the Medigap component that traditional Medicare offers to cover the “gap” that Medicare does not allow for certain conditions, including mental health treatment.
There is little doubt that the for-profit MA plans will put the needs of their shareholders first. Most Medicare-eligible beneficiaries are drawn to the low premiums and do not read the fine print about the limitations of MA plans. This may happen when there is a health crisis and the limitations on what care is covered by which paneled clinicians becomes suddenly clear.
According to the Psychotherapy Action Network, “Medicare Advantage (Part C) plans have been demonstrably disadvantageous to people who are sicker. If you have Part C and wait until you are sick to shift over to a Traditional Medicare plan, you may not be able to get a Medigap policy to cover copays and coinsurance, or that premium may be much higher.”
How do the MA plans affect mental health treatment coverage? For acute or short-term treatment, the lower premiums may be an advantage. The advantage will disappear in an MA plan if a beneficiary needs long-term psychotherapy. The cost of copays may be so high that the total cost of treatment may be much more expensive. Further, beneficiaries cannot purchase a Medigap policy (which covers co-pays) if MA is their primary insurance.
There are many articles on what can be done to prevent the “bait-and-switch” approach of MA plans, from lawsuits against commercial insurers to advocating for a single payer health care plan. For now, the best option in the view of CSWA, is to think carefully about the pros and cons of MA plans and traditional Medicare before choosing MA plans. Please contact me if you have any other questions about MA plans.
Please see the below link for an editorial written by our Director of Policy and Practice and Board President:
https://jswve.org/volume-20/issue-1/item-03/
For the past year, I have been working on a document with NASW on Clinical Social Work Standards. A draft of this document has been released for public comment. I hope all CSWA members will take a look at it and offer your comments. You can find it at https://www.socialworkers.org/Practice/Clinical-Social-Work/Practice/clinical-social-work-standards-draft-forum2. The comment period is open until September 15, 2023.
This is kind of a condensed version of the Private Practice in Clinical Social Work: A Reference Manual, which I also participated in developing with NASW, released in 2021.
Please send me your thoughts as well.
Laura Groshong, LICSW, CSWA Director of Policy and Practice lwgroshong@clinicalsocialworkassociation.org
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