December 8, 2015

Dear CSWA Affiliated Society Members,

Here is some good news for LCSWs in dealing with PQRS in 2016.  There are no changes from the reporting necessary to be PQRS compliant from 2015!

There are still seven PQRS measures that apply to LCSWs and have QDCs that we report on the CMS-1500.  That means LCSWs still do not meet the Medicare requirement of nine measures and three domains.  Simply apply as many of the measures as you can to 50% of all Medicare patients and you will be compliant with PQRS through the MAV process.

Please review carefully the instructions on how to document PQRS measures which can be found at http://www.clinicalsocialworkassociation.org/Resources/Documents/CSWA%20-%202015%20PQRS%20Requirements%20for%20LCSWs%20%20%28FINAL2%29%20-%202-15.pdf to refresh your memory about how to submit QDCs.  The date will be changed from 2015vto 2016 shortly.

A 2015 summary chart (soon to be changed to 2016) is also available at http://www.clinicalsocialworkassociation.org/Resources/Documents/CSWA%20-%20PQRS%202015-A%20glossary%20and%20chart--4.12.15%20%281%29.pdf which has the seven measures and domains listed out.

Failure to comply with all the instructions listed the above documents may result in PQRS non-compliance in 2016 and a 3% reimbursement cut for Medicare payments in 2018. It appears that the vast majority of CSWA members who chose to become PQRS compliant were successful in doing so.  Most of the few members who were found to be non-compliant in 2015 understand what needs to be changed to avoid non-compliance in 2016.

Remember that you still can request an informal review if you have been told that you were non-compliant until December 16, 2015. Here are the links and phone numbers to use: Information about how to request an informal review is available 1) on the 2014 QRUR website; 2) through the QRUR Help Desk at pvhelpdesk@cms.hhs.gov ; or 3) at 888-734-6433 (select option 3).

If you chose not to be compliant until now in 2015, it is too late to become compliant, but you can start doing so in 2016.

I wish you all happy holidays. 

Laura Groshong, LICSW, CSWA Director, Policy and Practice

Clinical Social Work Association
The National Voice of Clinical Social Work
Strengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

Dear CSWA Affiliated Society Members,

It is time to start supporting the Improving Access to Mental Health Act of 2015, the bills that have recently been created by Sen. Debbie Stabenow and Rep. Barbara Lee.  These bills are being sponsored by CSWA, though the Medicare reimbursement increase requested – 10% – is less than the 25% that CSWA had hoped for.  This is a first step toward the goal of 100% parity with other mental health providers that CSWA still supports.  An improvement in the 75% of other providers is what the Association sees as feasible at this time.

Please send this message to your members of Congress by October 31, 2015.  You can find their email addresses at http://www.contactingthecongress.org/ :

Dear (Sen./Rep.) ________________:

 I am a member of the __________ Society [if you are] and the Clinical Social Work Association [if you are] and a constituent. [If you are in Michigan - Sen. Stabenow's state - or California's 13th District - Rep. Lee's district - please thank them for supporting the bill here.]

 I am [calling/writing] to ask for your support of S. 2173/H.R. 3712, the Improving Access to Mental Health Act of 2015 that will improve access to mental health treatment by increasing the number of licensed clinical social workers who choose to be participating Medicare providers.  The changes that the bills propose are:

• Increase Medicare reimbursement for LCSW services from 75% to 85% of the physician fee schedule rate.
  
• Eliminate restrictions on the delivery of LCSW services for Medicare beneficiaries in skilled nursing facilities and hospitals.
  
• Expand the statutory definition of LCSW services to include all psychotherapy services (including Health and Behavior Assessment and Intervention services)
  

Anticipated cost offsets from lower medical costs should make this fiscal change revenue neutral.  A cost assessment is currently in process. I hope you will consider sponsoring this bill.

Sincerely,

[Name, degree, license]

The CSWA Government Relations Committee is working hard to get sponsors as well but we need your help!  As always, please let me know when you have sent your messages to your members of Congress.

Laura Groshong, LICSW, CSWA Director of Policy and Practice

Clinical Social Work Association Members and State Affiliate Members:

It is with great pleasure that we write you to inform you of the recent introduction of S. 2173 & H.R. 3712, the Improving Access to Mental Health Act of 2015 on October 8, 2015 by Senators Debbie Stabenow (D-MI) and Barbara Mikulski (D-MD) in the Senate and Rep. Barbara Lee (D-CA) in the House.  NASW and Clinical Social Work Association (CSWA) have been working on achieving this together on your behalf.

We are actively working with Senator Stabenow, Senator Mikulski and Representative Lee to build bipartisan support for the bill in both the U.S. Senate and the House of Representatives. Given Senator Stabenow’s background as a social worker and her position on the influential Senate Finance Committee, she will be a strong champion for advancing our mutual Medicare agenda. Sen. Mikulski, also a social worker, Dean of the Women in the Senate as well as the longest serving woman in the history of the United States Congress is working collaboratively with Sen. Stabenow on this legislation and they are each committed to advancing the bill through the legislative process. Rep. Lee is also a social worker, serves on the House Appropriations Committee and leads the Congressional Social Work Caucus.

The two main goals of the Improving Access to Mental Health Act of 2015 are to increase beneficiary access to services provided by licensed clinical social workers (LCSW) and to advance a credible and achievable Medicare agenda for LCSWs.  The Improving Access to Mental Health Act of 2015 achieves these goals in several ways. 

• First, S. 2173 & H.R. 3712 increases Medicare reimbursement for LCSW services from 75% to 85% of the physician fee schedule rate. (This is the first step to 100%!)
• Second, this bill eliminates restrictions on the delivery of LCSW services for  Medicare beneficiaries in skilled nursing facilities.
• Finally,  These Senate and House Bills expand the statutory definition of LCSW services to include all services (including Health and Behavior Assessment and Intervention services) that LCSWs are authorized to perform under their respective state licensure states and regulations.

The Improving Access to Mental Health Act of 2015 recognizes the critical shortage in resources for clinical social work services and the limitations it places on beneficiary access.  This bill would help alleviate those shortages by increasing CSWs reimbursement rate from 75% to 85%. By raising this rate, payment parity would be established between CSWs and other non-physician professionals, including physician assistants, nurse practitioners, and clinical nurse specialists. Although passing any legislation through Congress is difficult, especially proposals that require increased spending in uncertain economic times, we believe increasing the Medicare reimbursement rate to 85% of the physician fee schedule is a credible and politically viable proposal.

NASW and CSWA are very grateful to Sens. Stabenow and Mikulski and Rep. Lee for their leadership on this bill and encourage all their constituents who are members to let them know.  Under separate cover, an alert will go out to the NASW Advocacy Listserv and CSWA listserv that will let you know how to contact your elected officials about this legislation. To join the Advocacy Listserv, click here.

Sincerely,

Susanna Ward, PhD, LCSW
President & CEO, CSWA

Angelo McClain, PhD, LICSW                                            
Chief Executive Officer, NASW                                          

*Legislative

DHHS Office of Evaluation and Planning

• CSWA provided better understanding of clinical social work practice
  
• DHHS wants to know why LCSWs opting out of Medicare
  
• DHHS suggested that CSWA encourage LCSWs to see Medicaid as well as Medicare patients
  
• Supportive and enlightening exchange
  

Meeting at Senator Stabenow’s Office

• Bill being proposed.  Senator wanted CSWA’s input
  
• Major disagreement over increasing reimbursement rates from 85% instead of 100%.  The Senator and her staff believe that asking for 100% reimbursement will kill the Bill at this point.
  
• Looking for a Republican Sponsor (especially from the Finance Committee)
  
• Wants CSWA support for the Bill which includes 10% reimbursement increase for LCSWs, return to independent practice in Medicare Part A as well as inclusion of E & M codes.
  
• CSWA supporting Bill as “first step” effort
  

White House Domestic Economic Policy Council

• Rescheduled due to Pres. Obama’s requiring all Council Secretaries’ presence at WH meeting
  
• This meeting will take place in the near future
  

*CSWA Board Meeting

• Very productive all day meeting with presentations from each Board  and Staff member as well as Clinical Dialog Editor, Gail Nagle; CSWA Newsletter Editor, Eric Huffman; Board Liaison to CSWE, Liz Alvarado; and CSWA Accountant, Debbie Sabean
  
• Efforts towards a stronger presence in DC are in the making!  More to come.
  

*CSWA State Affiliate Summit

• All Board members and staff hosted representatives from 8 out of the 17 State Affiliates at the Summit. 
  
• Bad weather prohibited travel for some. 
  
• Three new state affiliates were added this past year and 3 more state Societies are still being encouraged to affiliate in the future.  That would complete the 20 State Societies that are still operating.
  
• Nancy Harrington and Steve Szopa from the Greater Washington Society (who hosted a lovely reception the night before for everyone) joined us, again, this year as did Joel Kanter from AAPCSW, Marsha Wineburgh from New York,  Diane Frankel from Pennsylvania, Lynda Tate from South Carolina, and Lynn Houck Hefetz from North Carolina.  
  
• New faces to the Summit included Judy Gallant from Greater Washington, Britni Brown and Stacie Fitzgerald from Georgia, Jodi Hogue from Missouri and Shannon Boyle from New York.  Board members Michael Rose and Susanna Ward represented Arizona and Kentucky this year. 
  
• The “trade show” was fun, but State reports and exchange of information from state to state, state to national, and national to state carried the day.  The meeting was informative, inspiring, and enlightening.  What an awesome group.  CSWA hopes that ALL state Societies can be represented next year!
  

*CSWA/NASW Leadership Collaboration Meeting

• Memorandum Of Understanding (MOU) signed and shared
  
• Monthly legislative team conferences to occur
  
• Increased leadership communication established
  
• Potential CSWA participation in NASW 2016 National Conference discussed
  
• CSWA invited NASW leadership to next Board meeting luncheon in DC
  
• NASW offered support regarding greater CSWA presence in DC
  
• CSWA discussed upcoming Stabenow Medicare Bill.  Joint statement upon release of the Bill being developed.

Membership in CSWA is an investment in your professional growth and development. CSWA is the only national organization that advocates for your interests! CSWA IS WORKING FOR YOU!  LOGIN TO RENEW YOUR MEMBERSHIP TODAY!

July, 2015:  CSWA's President met with NASW’s Executive Director to further develop collaborative efforts between the two social work organizations.  Discussions will continue around issues related to legislative efforts, conference possibilities, as well as developing  open lines of communication.  More to come!

I wanted to inform you of the filing of a Washington State class action lawsuit against Group Health Corporation, a major insurer in Washington State, for failing to use adequate guidelines in covering psychotherapy.  An article about the suit has been published by Courthouse News Service at http://www.courthousenews.com/2015/08/05/class-says-insurer-wont-cover-psychotherapy.htm

One of the lead plaintiffs is Washington State Society for Clinical Social Work Past-President, and CSWA Board Member, Karen Hansen, LICSW.  Group Health's attitude toward covering mental health treatment has been quite restrictive for decades.  This is a brave move by Karen and her fellow plaintiffs to stop these unethical practices and potentially benefit all clinicians and patients.

Please contact Albert Kirby, JD, the attorney who has filed this complaint, at ahkirby@soundjustice.com for more information or if you have a case to add to the complaint inn Washington State.

This suit is likely to have an impact on all psychotherapy coverage in Washington State and provide a model for other states who have similar restrictive insurers.

CSWA President Susanna Ward, CSWA Deputy Director of Policy and Practice Margot Aronson, and I met with Sean Cavanaugh, the Director of Medicare, and 7 Deputy Directors last week (four by webcam from Baltimore) about the disparity between Medicare reimbursement for LCSWs providing psychotherapy services. Medicare currently will reimburse clinical social workers only 75% of the amount psychiatrists and psychologists receive for psychotherapy codes.

President Ward, Margot, and I were pleased to find that Dir. Cavanagh and others at the meeting were well-versed in the clinical work we do and appreciative of the documentation and explanatory materials we presented, i.e., the CSWA 4-point description of clinical social work; the list of numbers of LCSWs by state; and the Medicare Position Paper (all available on the CSWA website).

Dir. Cavanaugh explained that neither he nor anyone on his staff could express a stance without first having a go-ahead from the Office of the President. He then generously offered to put us in touch with the relevant White House Office staff to whom we could make our case urging that resources be found to add needed funding to the President's budget next year to fund the request. Additionally we have introductions to staff from the Departments of Management and Budget and Health and Human Services Planning and Evaluation.  We are currently following up with these contacts. 

CSWA has also been in contact with NASW and hopes to reach agreement with our sister organization about seeking full parity for Medicare reimbursement, i.e., 100% of what psychologists and psychiatrists are paid for the psychotherapy codes that LCSWs use. Currently, NASW is seeking 85% of what the other two groups are paid.

Additionally, our visit to the Hill focused on two omnibus mental health bills, one (House) which was developed last year, and one (Senate) which is about to be dropped. CSWA has concerns about how these bills approach evidence-based practice, the Medicare lifetime limit of 190 days of psychiatric hospital treatment, block grant funding, and integration of primary care and mental health treatment.

The relationships we are developing with the prime sponsors of these bills will help us influence these issues of concern. It is gratifying to see that the mental health omnibus bills now have many references to clinical social workers as psychotherapy providers due to our advocacy work earlier this year; the bill last year had only one reference to social work, as discharge planners.

CSWA will continue to keep you informed about the progress of our advocacy efforts and welcomes your thoughts.

The CSWA has secured a meeting with CMS Director of Medicare, Sean Cavanaugh and his deputy directors in two weeks to discuss our Medicare Position Paper about equal reimbursement for equal codes. Several members of Congress encouraged us to have this meeting and we are grateful to them for their support.

CSWA President Susanna Ward, Deputy Policy and Practice Director Margot Aronson, and I will attend and report back to members about next steps.

As many of you may have heard, the Supreme Court decided to uphold the right to all states should have premium subsidies under the Affordable Care Act, on a 6-3 vote.  This is a major victory for the 6.4 million citizens covered in the 34 states who are receiving subsidies from the Federal government,many of whom are our patients.  For more information go to http://www.washingtonpost.com/politics/courts_law/obamacare-survives-supreme-court-challenge/2015/06/25/af87608e-188a-11e5-93b7-5eddc056ad8a_story.html

On another note, many of you may also have heard about the new version of the Helping Families in Mental Health Crisis Act of 2015, H.R. 2646, (formerly H.R. 3717).  CSWA has been working on this bill for the past two years, meeting with prime sponsor Rep. Tim Murphy's office to express our concerns last year.  As a result, Rep. Murphy agreed to include the phrase "clinical social worker" in the bill every time the groups of providers for psychotherapy are mentioned, approximately 20 times.  Previously the term had been the more general "social worker."

Additionally, H.R. 2646 includes the following recommendations made by CSWA last year:  1) establishment of federally qualified community behavioral health clinics; 2) extension of health information technology assistance for behavioral health facilities and professionals engaging in meaningful use; 3) reauthorization of the Garrett Lee Smith suicide prevention program; 4) reauthorization of the National Child Traumatic Stress Network; 5) improvements in Department of Justice programs focused on children with mental illness and substance use disorders involved with the criminal justice systems; and 6) full implementation of the 2008 Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act.  

Our main concern about the new version of this bill is around cuts to those with disabilities.  While CSWA will be talking with main sponsors of this bill later this summer, we see this bill as an improvement in many ways from the original bill.  

Finally, CSWA continues to meet with members of Congress and CMS on our Medicare Position Paper to create reimbursement parity for LCSWs.  A report on these efforts will be out later this summer. 

As you know, the CSWA Government Relations Committee has been working for the past year on our Medicare Position Paper to implement Medicare reimbursement at parity with other mental health psychotherapy providers and to include LCSWs as independent providers in Medicare Part A.  

CSWA has been working on these issues with members of Congress, other mental health organizations, and CMS to find a way to implement these goals.

We were glad to note this month that NASW is joining us in pursuing these goals. The more the social work community is united on legislative goals that benefit all LCSWs and our patients, the more successful we are likely to be.