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Legislative Alerts

CSWA Director of Legislation and Policy, Laura Groshong regularly provides Legislative/Regulatory Alerts to the membership to keep them informed about important legislation or regulations that have been introduced at the national level.  In addition to keeping members informed, the CSWA also monitors all current national legislation that affects clinical social workers and the need for action to members of Congress. The list of Legislative Alerts listed below allows members to review the history of CSWA action on national bills in Congress that affect clinical social workers and the outcomes of our actions.

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  • 14 Jun 2022 1:03 AM | CSWA Administrator (Administrator)


    [The Aware Advocate is an occasional newsletter sent to members with information that is relevant to Licensed Clinical Social Workers ~LWG]

    This episode of The Aware Advocate will focus on POS Codes for Medicare; Public Health Emergency extension; and the Social Work Compact development.

    POS Codes for Medicare

    There remains a lot of confusion about which POS codes should be used for Medicare.  Here is a reminder of what Medicare and other insurers are requiring for claims:

    • POS “11” should be used until the end of the Public Health Emergency, timing of which is currently the end of 2022, even though this POS “11” is for office visits.
    • POS “10” was made “available” for LCSWs for telemental health treatment as of April 4; however, there is a rate cut for those who have used POS “10” so using POS “11” is a better option.
    • POS “10” will be required for telemental health when the Public Health Emergency ends, currently the end of 2022.
    • Check with YOUR Medicare Administrative Contractor to clarify which POS code is being accepted currently if the patient is being seen through telemental health in their home.
    • You can find your MAC contact information at the CSWA website under “Clinical Practice”.
    • If a patient is seen in their car, the POS code should be “02”, but POS “11” is also acceptable. 
    • The Medicare Modifier for all POS codes is still 95. This may seem counterintuitive as 95 is supposed to be for telemental health, but it is the only combination that currently works.

    Be sure to check with EACH private insurer for a patient to find out what combination of POS and Modifier are being requested so that claims will not be denied.

    Public Health Emergency

    The Public Health Emergency is predicted to be in effect until the end of 2022, possibly longer.  I will be keeping you informed on any changes that take place which may affect Medicare coverage and commercial insurance.

    Social Work Compact

    As you know, CSWA began working as part of the Technical Assistance Group (TAG) in October of 2021, along with representatives from ASWB, NASW, CSWE, and Department of Defense and the Council of State Governments to create a Social Work Compact.  The latter two groups listed are funding the effort to create a compact for clinical social workers that would allow us to work in any state that has joined the Compact.  The process for creating the Compact is as follows:

    • States will join the Compact by passing legislation through the state legislatures after the draft legislation is approved by DoD and CSG
    • The draft legislation will be open for public comment some time this summer. I will let you know how to access the draft and send in your comments when it is available
    • The draft will likely go out to states in late 2022 or early 2023

    Once the process is moving forward, we will need to have a legislative campaign to pass the Compact in as many states as possible.  I will be sending materials to help you make the case for the Compact in your state.

    Let me know if you have any questions about any of these issues.

    Laura Groshong, LICSW, Director, Policy and Practice

  • 17 May 2022 6:20 PM | CSWA Administrator (Administrator)


    The Improving Access to Mental Health Act (S.870), which CSWA has been supporting since 2012, has provisionally been included in the omnibus mental health legislation package being developed by the Senate Finance Committee.  The request from the Committee is that we find more Republican cosponsors for the bill.  This needs to happen by Friday, May 20, 2022 COB.

    To review the high points of this bill, they are:

    • Increase reimbursement rates for clinical social workers from 75% to 85% of the psychotherapy rates for other mental health clinicians in the Physicians Fee Schedule;
    • Allow LCSWs to be reimbursed independently for providing psychotherapy in Skilled Nursing Facilities; and
    • Allow LCSWs to use Health and Behavior Assessment and Intervention (HBAI) codes to be reimbursed for mental health disorders in the context of medical conditions

    The Committee members/Legislative aides that are most important to this effort are:

    Sen. Mike Crapo (R-ID): Rebecca Alcorn, Senior Policy Advisor, rebecca_alcorn@crapo.senate.gov

    Sen. Chuck Grassley (R-IA): Nic Pottebaum, Health Policy Advisor, nic_pottebaum@grassley.senate.gov

    Sen. John Cornyn (R-TX): Alaura Ervin, Legislative Assistant, alaura_ervin@cornyn.senate.gov

    Sen. John Thune (R-SD): Danielle Janowski, Health Policy Director, danielle_janowski@thune.senate.gov

    Sen. Richard Burr (R-NC): Angela Wiles, Health Policy Director (HELP Committee), angela_wiles@help.senate.gov

    Sen. Rob Portman (R-OH): Jack Boyd, Health LC, jack_boyd@portman.senate.gov

    Sen. Pat Toomey (R-PA): Mike Weiss, Health LA, mike_weiss@toomey.senate.gov

    Sen. Tim Scott (R-SC): Brianna Wood, Legislative Correspondent, brianna_wood@scott.senate.gov

    Sen. Bill Cassidy (R-LA): Mary Moody, Health Policy Advisor, mary_moody@cassidy.senate.gov

    Sen. James Lankford (R-OK): Cambridge Neal, Legislative Assistant, cambridge_neal@lankford.senate.gov

    Sen. Steve Daines (R-MT): Rachel Green, Health Policy Advisor, rachel_green@daines.senate.gov

    Sen. Todd Young (R-IN): Beth Nelson, Health Policy Director, beth_nelson@young.senate.gov

    Sen. Ben Sasse (R-NE): Shannon Hossinger, Policy Advisor, shannon_hossinger@sasse.senate.gov

    Sending the following message to the LAs is a good way to make contact with the senators. You can send your message even if you are not a constituent.

    The suggested message is as follows (feel free to use your own language):

    “I am [a constituent and] a member of the Clinical Social Work Association. Please consider becoming a cosponsor for S.870 which will provide greater access to mental health and substance use treatment, desperately needed in these difficult times. S. 870 will increase the number of LCSWs who become Medicare providers. Thank you for your consideration.”

    As always, please let me know when you have sent your messages.

    Laura Groshong. LICSW, Director, Policy and Practice  
    Clinical Social Work Association  
    lwgroshong@clinicalsocialworkassociation.org


  • 26 Jan 2022 6:49 PM | CSWA Administrator (Administrator)


    I hope everyone is feeling well informed about the Good Faith Estimate rule, part of the No Surprises Act, which went into effect on January 1.  There have been several webinars on this topic and one can be found at the CSWA website in the Members Only Section.

    CSWA is working on two fronts to get LCSWs exempted from the GFE. One is a letter we co-wrote with the Psychotherapy Action Network (attached). The other is a campaign to let members of Congress know about the fact that LCSWs in private practice do not need to be part of the GFE; we already do everything that it requires and there are vanishingly low numbers of LCSWs who have had actionable complaints filed against them for surprise billing.

    Please send your members of Congress at www.Congress.gov the following message: “I am a constituent and a member of the Clinical Social Work Association. The No Surprises Act requires me as a Licensed Clinical Social Worker to give my patients a Good Faith Estimate.  I am in private practice and have patients pay me directly.  The GFE interferes with the mental health treatment process (detailed in the attached letter). Please exempt LCSWs from the Good Faith Estimate requirements.”

    NSA Letter to CMS (fin.) - 1-25-22.pdf

    As always let me know when you have sent your messages.

    Laura Groshong, LICSW, Director, Policy and Practice   
    Clinical Social Work Association    
    lwgroshong@clinicalsocialworkassociation.org

  • 06 Dec 2021 9:23 PM | CSWA Administrator (Administrator)


    There have been several requests for language to send members of Congress regarding the Medicare requirement that all patients be seen in-person at least once every 12 months.   This would put patients and LCSWs at risk and CSWA is strongly opposed to this requirement.

    There is a possibility that this requirement would only go into effect after the public health emergency ends.  CSWA still opposes any in-person requirement, as it could have a disorienting effect on the treatment.  There is no medical necessity for seeing a patient in person occasionally unless the treatment would be better served by in-person clinical work; seeing a patient once a year in-person would hardly be beneficial to the patient.

    With these concerns in mind, CSWA offers the following suggested language for members to send their members of Congress (at www.congress.gov)  to explain the problems with this requirement:

    I am a constituent and a member of the Clinical Social Work Association. The over 270,000 licensed clinical social workers (LCSWs) are the largest group of mental health providers in the country and provide mental health services to Medicare beneficiaries. 

    I am writing because Section 123 of the 2022 Physician Fee Schedule has a requirement that LCSWs must see patients at least once a year in-person.  The only way I can safely see my patients currently is virtually, as I have been since the pandemic began in March 2020.  This has worked well for most of my patients.  It would be a hardship for me to maintain an office for a once-a-year meeting, and an intrusion into the virtual treatment for my patients. 

    This requirement should be eliminated so that I can continue to provide services to the over 50% of our citizens suffering from emotional distress.  Please oppose this requirement so that I can continue to help all those suffering from PTSD, anxiety, depression, and other difficulties in these perilous times.”

    Feel free to use your own words.  As always, let me know when you have sent your messages.

    Laura Groshong, LICSW, Director Policy and Practice 
    Clinical Social Work Association   lwgroshong@clinicalsocialworkassociation.org

  • 30 Nov 2021 5:28 PM | CSWA Administrator (Administrator)


    As we continue our pandemic journey, changes to the use of telemental health continue to develop.  Two significant ones from CMS have come out this month, one on Place of Service (POS) codes and one on in-person visits required for telemental health treatment.

    Place of Service Codes

    POS codes are being divided by 1. telemental health provided outside the patient’s home and 2. telemental health provided in the patient’s home.  POS 02, which previously covered both categories, should only be used as of January 1, 2022, for telemental health psychotherapy provided outside the patient’s home.  POS 10, a new code, should be used as of January 1, 2022, for telemental health psychotherapy provided in the patient’s home.  The complete descriptions are as follows:

    1. POS 02: Telehealth Provided Other than in Patient’s Home Descriptor: The location where health services and health-related services are provided or received through telecommunication technology. The patient is not located in their home when receiving health services or health-related services through telecommunication technology. 

    2. POS 10: Telehealth Provided in Patient’s Home Descriptor: The location where health services and health-related services are provided or received through telecommunication technology. The patient is located in their home when receiving health services or health-related services through telecommunication technology. 

    Links for more information can be found at https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set .  These changes may be adopted bycommercial insurance; check with each carrier directly.

    Required In-Person Visits with Medicare Patients

    I have been tracking this difficult rule for the past year for the Clinical Social Work Association. It is unclear to me how it is going to be enforced. The most recent iteration came out earlier this month. 

    The rule was amended in the recent 2022 Physician Fee Schedule as follows: 

    “Section 123 of the CAA removed the geographic restrictions and added the home of the beneficiary as a permissible originating site for telehealth services furnished for the purposes of diagnosis, evaluation, or treatment of a mental health disorder. Section 123 requires for these services that there must be an in-person, non-telehealth service with the physician or practitioner within six months prior to the initial telehealth service and requires the Secretary to establish a frequency for subsequent in-person visits. We are implementing these statutory amendments, and finalizing that an in-person, non-telehealth visit must be furnished at least every 12 months for these services, that exceptions to the in-person visit requirement may be made based on beneficiary circumstances (with the reason documented in the patient’s medical record), and that more frequent visits are also allowed under our policy, as driven by clinical needs on a case-by-case basis.” 

    The whole rule can be found at https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-medicare-physician-fee-schedule-final-rule

    The "beneficiary circumstances" seem to offer a way to avoid seeing patients in person but this will need to be clarified by HHS. In any case, the time period has been extended from 6 months to 12 months for in-person meetings. 

    As for how to fight this rule, CSWA is working on a two-pronged approach. We encourage all mental health associations to oppose it through letters to HHS and CMS. All individual clinicians can oppose it by writing to our senators and representative about the chilling effect this rule will have on telemental health treatment, especially in this pandemic when emotional distress is high and meeting in person may be dangerous. 

    This will be a long-term fight in my view and there is no alternative to holding the government's feet to the fire.  

    Laura W. Groshong, LICSW, Director, Policy and Practice

    Clinical Social Work Association 
    lwgroshong@clinicalsocialworkassociation.org 
    CSWA - "The National Voice for Clinical Social Work"

    Strengthening IDENTITY, Preserving INTEGRITY, Advocating PARITY

  • 05 Nov 2021 10:53 AM | CSWA Administrator (Administrator)


    The announcement from CMS on rules for telemental health raised some questions which I will answer below:

    1. Does the new rule mean that LCSWs are able to freely use telemental health to see patients in states where we are not licensed? No. That is what CSWA is working on through the Compact.  All state restrictions about licensure still apply.  Check with the state social work Board if you wish to see a patient who resides in a state in which you are not licensed.  A few states still have relaxed reciprocity standards, but others are ending their willingness to extend the ability to practice without licensure.

    2. Does this mean that private insurers will also agree to coverage of telemental health and audio only psychotherapy? No. Private insurers often follow Medicare rules, but there is no guarantee.  There appeared to be some changes in the way that private insurers were going to cover telemental health before the rule was announced.  The rule may affect those changes and others going forward.  Check with individual insurers or have patients check.

    3. Does the state in which the patient resides in general still dictate the necessity of being licensed in their state to treat the patient? In general, yes.  Check with the state social work Board where the patient resides as noted in #1.

    4. Do you think the change in the CMS administration led to this positive outcome? There is no way of knowing for sure, but it is possible.

    5. Will this rule cover Medicaid as well as Medicare? All Medicaid decisions will be made by states, though this may encourage some states to cover telemental health in Medicaid.

    6. Will LCSWs still be required to see patients in person every six months as previously required? No, this requirement has now been changed to every 12 months.  CSWA will be working to eliminate this requirement as we did to eliminate the six month rule.
    One correction: the coverage of telemental health and audio only treatment will now be allowed until the end of 2023.  Another decision will be made about further coverage at that time.

    Laura W. Groshong, LICSW, Director, Policy and Practice

    Clinical Social Work Association 
    lwgroshong@clinicalsocialworkassociation.org

    CSWA - "The National Voice for Clinical Social Work"

    Strengthening IDENTITY, Preserving INTEGRITY, Advocating PARITY

    ============================================

    Good news from CMS.  Yesterday CMS announced the first group of many rules regarding the Physician Fee Schedule, which CSWA, and many of you, our members, commented on in August.  Our voices made a difference.  CMS will extend coverage of telemental health and audio only psychotherapy until the end of 2023.  This was a major goal of ours and CSWA is delighted.

    Now we need more clarity on eliminating the need to see patients in person every six months and the payment schedule for LCSWs in 2022.  CSWA will continue to provide information on these issues as it is available.

    Here is the statement issued by CMS (key statements in yellow outline).  For the original document, go to https://www.federalregister.gov/public-inspection/2021-23972/medicare-program-cy-2022-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

    Expanding Use of Telehealth and Other Telecommunications Technologies for Behavioral Health Care

    The final rule makes significant strides in expanding access to behavioral health care – especially for traditionally underserved communities – by harnessing telehealth and other telecommunications technologies. In line with legislation enacted last year, CMS is eliminating geographic barriers and allowing patients in their homes to access telehealth services for diagnosis, evaluation, and treatment of mental health disorders.

    “The COVID-19 pandemic has highlighted the gaps in our current health care system and the need for new solutions to bring treatments to patients, wherever they are,” said Brooks-LaSure. “This is especially true for people who need behavioral health services, and the improvements we are enacting will give people greater access to telehealth and other care delivery options.”

    CMS is bringing care directly into patients’ homes by providing certain mental and behavioral health services via audio-only telephone calls. This means counseling and therapy services, including treatment of substance use disorders and services provided through Opioid Treatment Programs, will be more readily available to individuals, especially in areas with poor broadband infrastructure.

    In addition, for the first time outside of the COVID-19 public health emergency (PHE), Medicare will pay for mental health visits furnished by Rural Health Clinics and Federally Qualified Health Centers via telecommunications technology, including audio-only telephone calls, expanding access for rural and other vulnerable populations.

    Thanks again to everyone who contributed to this effort. Let me know if you have any questions.

     

    Laura W. Groshong, LICSW, Director, Policy and Practice

    Clinical Social Work Association
    lwgroshong@clinicalsocialworkassociation.org


  • 03 Nov 2021 5:26 PM | CSWA Administrator (Administrator)


    Good news from CMS.  Yesterday CMS announced the first group of many rules regarding the Physician Fee Schedule, which CSWA, and many of you, our members, commented on in August.  Our voices made a difference.  CMS will extend coverage of telemental health and audio only psychotherapy indefinitely.  This was a major goal of ours and CSWA is delighted.

    Now we need more clarity on eliminating the need to see patients in person every six months and the payment schedule for LCSWs in 2022.  CSWA will continue to provide information on these issues as it is available.

    Here is the statement issued by CMS (key statements in yellow outline).  For the original document, go to cmslists@subscriptions.cms.hhs.gov :

    Expanding Use of Telehealth and Other Telecommunications Technologies for Behavioral Health Care

    The final rule makes significant strides in expanding access to behavioral health care – especially for traditionally underserved communities – by harnessing telehealth and other telecommunications technologies. In line with legislation enacted last year, CMS is eliminating geographic barriers and allowing patients in their homes to access telehealth services for diagnosis, evaluation, and treatment of mental health disorders.

    “The COVID-19 pandemic has highlighted the gaps in our current health care system and the need for new solutions to bring treatments to patients, wherever they are,” said Brooks-LaSure. “This is especially true for people who need behavioral health services, and the improvements we are enacting will give people greater access to telehealth and other care delivery options.”

    CMS is bringing care directly into patients’ homes by providing certain mental and behavioral health services via audio-only telephone calls. This means counseling and therapy services, including treatment of substance use disorders and services provided through Opioid Treatment Programs, will be more readily available to individuals, especially in areas with poor broadband infrastructure.

    In addition, for the first time outside of the COVID-19 public health emergency (PHE), Medicare will pay for mental health visits furnished by Rural Health Clinics and Federally Qualified Health Centers via telecommunications technology, including audio-only telephone calls, expanding access for rural and other vulnerable populations.

    Thanks again to everyone who contributed to this effort. Let me know if you have any questions.

    Laura W. Groshong, LICSW, Director, Policy and Practice    
    Clinical Social Work Association  
    lwgroshong@clinicalsocialworkassociation.org


  • 30 Aug 2021 10:58 AM | CSWA Administrator (Administrator)


    As you know, each August CMS puts out changes to the rules that govern the Physician Fee Schedule (PFS).  These changes affect our practices and CSWA sends comments on the rules, which go into effect the following year.

    Below please find the comments which CSWA has sent on the PFS 2022, a 1747-page document.  CSWA chose three areas for comment, Mental Health Disparities, Telemental Health Coverage, and Telemental Health Parity in reimbursement.  CSWA encourages all members to send their individual comments on any or all of these areas.  CMS is asking that members not send a standard message.  Use any of the language in the CSWA comments for your own comments.  Send them by September 13, 2021, to https://www.federalregister.gov/documents/2021/07/23/2021-14973/medicare-program-cy-2022-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part .

    As always, let me know when you have sent your comments and send a copy.  Thanks for your help.

    Laura W. Groshong, LICSW, Director, Policy and Practice  
    Clinical Social Work Association  
    lwgroshong@clinicalsocialworkassociation.org


    August 27, 2021

    Centers for Medicare and Medicaid Services
    Department of Health and Human Services
    RE: Comment on Physician Fee Schedule 2022
    https://www.federalregister.gov/documents/2021/07/23/2021-14973/medicare-program-cy-2022-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

    The Clinical Social Work Association (CSWA) is pleased to have the opportunity to submit comments on the proposed Physician Fee Schedule for 2022 (PFS2022).  We also want to take this opportunity to thank CMS for covering mental health treatment provided through videoconferencing and audio-only delivery during this Public Health Emergency (PHE).

    We will be commenting on three major areas of the bill which are of particular interest to Licensed Clinical Social Workers (LCSWs). These areas are 1) addressing mental health disparities; 2) telemental health continuation after the Public Health Emergency; and 3) reimbursement parity between in-person mental health treatment and telemental health treatment.

    Mental Health Disparities

    The disparities between mental health access, treatment, and outcomes for white populations as compared to Black, Indigenous, and People of Color (BIPOC), have been well-documented and it is past time to address the root causes.  CSWA is pleased to see the request in the PFS2022 for comment on p. 434: “Solicit comments on addressing health disparities and promoting health equity.” 

    Health disparities are costly:  approximately 30% of direct medical costs for African Americans, Hispanics and Asian Americans are excess costs due to these health inequities, and the economy loses an estimated $309 billion per year due to the direct and indirect costs of disparities. (Nov. 2012, Henry J Kaiser Family Foundation)

    A major root cause driving these inequities lies in Social Determinants of Health (SDOH).  According to the peer reviewed journal,

    Health Affairs, disparities may be rooted in differences in insurance coverage, inequalities in access to good providers, or discrimination by health professionals in the clinical encounter.  Disparities may be the result of years of institutional racism, lack of trust due to years of broken promises, cultural traditions, and more.” (Health Affairs, 2008, https://www.healthaffairs.org/doi/full/10.1377/hlthaff.27.2.393)

    When it comes to mental health treatment, whites are more likely to receive psychotherapy and medication on an out-patient basis, whereas BIPOC citizens are more likely to be referred to in-patient treatment for the same conditions

    (Health Affairs, 2015, https://www.healthaffairs.org/doi/full/10.1377/hlthaff.27.2.393
    Yet, the rates of depression are lower in Blacks (24.6%) and Hispanics (19.6%) than in whites (34.7%). Correspondingly, depression in African Americans and Hispanics tends to be more persistent, likely due at least in part to difficulties accessing effective and affordable out-patient care.

    Further, since untreated mental health issues tend to exacerbate physical health issues, treatment costs related to physical health tend to rise as well.  Simultaneously, outcomes become less hopeful, and may come to include disability, addiction, homelessness, and incarceration - again disproportionately affecting BIPOC communities.

    Indeed, the prison population has become the largest group of people with diagnosable mental health disorders, between 45-60% (When Did Prisons Become Acceptable Mental Health Facilities?, Stanford Law School, 2017.)   Lack of critical mental health care during incarceration has been persistent, as are the difficulties accessing mental health care through Medicaid upon release. Here, then, is another example of the SDOH role in exacerbating disparities, especially given the excessively high numbers of brown and Black people incarcerated in the US.

    CSWA would be happy to provide additional data on how SDOH factors are connected to mental health disparities and need to be addressed.

    Telemental Health Coverage

    When the Public Health Emergency was implemented in March, 2020, most LCSWs began providing psychotherapy through virtual telemental health (videoconferencing) and audio-only (telephone).  The decision by CMS to cover these new delivery systems during the PHE has been crucial to the wellbeing of Medicare beneficiaries living in areas without local mental health services or accessible transportation to more remote care.  Previously unable to obtain in-person psychotherapy, they finally have the needed treatment because of the new delivery systems.  It is unrealistic to expect them to begin treatment in person when the PHE ends unless SDOH transportation and other barriers to access are addressed.

    CSWA therefore recommends that all three forms of treatment delivery be approved and reimbursed at the rate being paid for in-person treatment.   LCSWs who provide services through videoconferencing and audio-only are working as hard, if not harder, than when they see patients in person.  Further, even the requirement that patients being treated via videoconferencing and audio-only must be seen in person every six months is highly problematic; certainly it would be a huge barrier to seeing patients who can ONLY access treatment through virtual means.

    The elderly - the main group of Medicare beneficiaries - are chronically underserved when it comes to mental health treatment.  Not all Medicare beneficiaries have access to Rural Health Centers and Federally Qualified Health Centers; many had the opportunity to establish virtual  psychotherapy relationships with independent LCSWs as a result of the PHE.  However, the biannual in-person requirement has created a barrier to virtual treatment.  If it is not eliminated, these beneficiaries may well find themselves back among the “chronically underserved”.

    Telemental Health Parity

    As noted in the Proposed Rule, “the estimated cost impact of this proposal is unclear, the proposed requirement that a modifier be appended to the claim to identify that the service was furnished via audio-only communication technology would allow us to closely monitor utilization and address any potential concerns regarding overutilization through future rulemaking” (p.1198).  This comment applies to videoconferencing as well.

     In fact, LCSWs and other mental health clinicians have been involved in an in vivo application of these two delivery systems throughout the pandemic.  We ask that this data be collected and analyzed to see how much these services are being utilized and how their use affects cost offsets of medical conditions before CMS moves forward on plans to limit or eliminate them.

    CSWA recommends that all three forms of treatment delivery be approved until CMS completes such a study, and that all three be reimbursed at the rate being paid for in-person treatment.   LCSWs providing mental health treatment through videoconferencing and audio-only means are working just as hard, if not harder, providing professional clinical treatment virtually as when they provide services in person.

    LCSWs have been long been called the backbone of psychotherapy services, and with more than 250,000 licensees, LCSWs are the largest mental health provider group in the country.  However, as you know, LCSWs are reimbursed by Medicare at 25% less than psychologists for providing the same services, with the exact same CPT psychotherapy codes.  LCSWs have equivalent clinical training, experience, client overall satisfaction, and provide long-term relief of emotional problems.  The reimbursement disparity for LCSWs has not gone unnoticed and the number of LCSW Medicare providers has continually dropped. Lowering reimbursement for telemental health services would likely result in even fewer LCSW Medicare providers.

    CSWA hopes that these comments are helpful developing the Proposed Rule and would be happy to discuss them with you further.

    Sincerely,

    Kendra C. Roberson, PhD, LCSW, President  
    Clinical Social Work Association  
    kroberson@clinicalsocialworkassociation.org

    Laura Groshong, LICSW, Director, Policy and Practice  
    Clinical Social Work Association  
    lwgroshong@clinicalsocialworkassociation.org 


  • 29 Apr 2021 1:04 PM | CSWA Administrator (Administrator)


    Many members have been asking questions about the Medicare coverage of telemental health.  This is an important topic because most commercial insurers follow Medicare policies regarding coverage of telemental health, as well as other coverage issues.

    Medicare has covered telemental health videoconferencing for our usual and customary psychotherapy codes since March, 2020, a major expansion of telehealth coverage.  Medicare also agreed to cover audio only psychotherapy in April of 2020.  Both were tied to the Public Health Emergency (PHE) being in effect.  The PHE was extended in three month increments until April of 2021 when CMS announced that telemental health videoconferencing would be extended until the end of 2021.  Audio only treatment would be covered as long as the PHE was in effect.  See https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes for more information.

    In other words, separation of telemental health videoconferencing and audio only coverage have been part of the expansion of psychotherapy coverage since the pandemic began.  The current intention from the current administration is that the PHE continue through 2021, which would make the difference between the two delivery systems moot.

    At this point, I believe that LCSWs can reasonably expect coverage of telemental health and audio only treatment to last through 2021.  There are several bills in Congress which would make this policy permanent.  Our Government Relations Committee is working hard to see one of these bills pass.  Stay tuned.

    Laura W. Groshong, LICSW, Director, Policy and Practice

    Clinical Social Work Association
    lwgroshong@clinicalsocialworkassociation.org
    CSWA - "The National Voice for Clinical Social Work"

    Strengthening IDENTITY, Preserving INTEGRITY, Advocating PARITY


  • 19 Apr 2021 10:58 PM | CSWA Administrator (Administrator)


    Good news on the Medicare fee-for-service sequestration front!  The 2% cut which was scheduled for April 14, 2021, has been suspended until December 31, 2021.  See the announcement from CMS below:

    The Coronavirus Aid, Relief, and Economic Security (CARES) Act suspended the sequestration payment adjustment percentage of 2% applied to all Medicare Fee-for-Service (FFS) claims from May 1 through December 31, 2020.  The Consolidated Appropriations Act, 2021, extended the suspension period to March 31, 2021. An Act to Prevent Across-the-Board Direct Spending Cuts, and for Other Purposes, signed into law on April 14, 2021, extends the suspension period to December 31, 2021.

    Medicare Administrative Contractors will:

    • Release any previously held claims with dates of service on or after April 1
    • Reprocess any claims paid with the reduction applied

    For more information, go to https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2021-04-16-mlnc#_Toc69394754

    Let me know if you have any questions.

    Laura Groshong, LICSW, Director, Policy and Practice
    Clinical Social Work Association 
    lwgroshong@clinicalsocialworkassociation.org

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Garrisonville, Virginia  22463

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