January 18, 2026

Clinical social workers know many things about child development: childhood is a period where young people go through emotional, intellectual, social, and psychological growth, and they are exquisitely sensitive to developing relationships that enhance their wellbeing. Humans grow emotionally through learning to solve conflicts with others; increasing their critical thinking skills by research; and putting together ideas in their own unique way. Having a large language model, such as ChatGPT or other AI chatbots, complete research that is produced in polished language does not help anyone, particularly a child, to learn information or build problem-solving skills.

These issues present real problems for parents and educators. How do they manage the potential risk of students inappropriately using AI to assist with assignments? As children grow into ‘tweens, teens and young adults, for example, how do parents tell the difference between normal separation behavior (such as confiding in classmates rather than family members) or whether their child becoming socially withdrawn is a result of dependency on a bot created by artificial intelligence (AI) that will agree with anything the child says? Such sycophancy can even support suicide as a good idea, unbeknownst to parents.

Even prior to the recently exploding use of artificial intelligence, parents noticed the impact of social media on their children. Social media, “electronic communication tool(s) that enable users to create, share, and interact with each other through internet platforms,”[1]  came into common use in the early 2000’s with the development of Facebook and Twitter. In the past few years, Reddit and TikTok have become more commonly used by tweens and teens, and even younger children. Social media includes content-sharing communities, social networks, and virtual worlds. Approximately 70% of children 8-12 use social media, according to recent statistics.[8] Mental disorders continue to increase and research shows that frequent use of social media is strongly linked to the development of psychiatric disorders in children.

Add to this impact of social media the current explosion of AI, including chatbots that help children with homework, become online companions, confidants or authorities about subjects that many of these children never knew existed, possibly with sadistic, threatening, and sexualized content. For example, the app called “Character AI” creates iterative bots that can do all these things.[2]

As online companions, these bots and other forms of AI produce sycophantic language were developed to invite continued usage and an on-going relationship; this has been somewhat modified recently to remind users that communication is with a machine, not a person. However, children and teens need to be reminded that this ‘relationship’ is not a human-to-human interaction, where disagreements can be worked on and repaired with on-going contact and compromise. The bots, however, can become supportive in an insidious manner that does not allow the “relationship” to develop in an authentically human way. This deprives children and teens of the experience to help them become emotionally attuned adults.

“Relational AI” means that chatbots can simulate emotional support, companionship, or intimacy. In actuality, such chatbots present the risk of the user developing emotional dependency on a machine, reinforcing delusions, and/or encouraging addictive behaviors and self-harm, including suicide.

Children and teens who blur the line between bots and humans for emotional support may forget that bots are not people, interfering with the complexity of emotional development. Bots are not licensed psychotherapists like clinical social workers, who are overseen and can be disciplined by state licensing boards [7]. Companies who create bots for emotional support take no such responsibility for the ways that bots impact everyone, especially children and teens.

AI companies have recently been facing lawsuits from families whose loved ones have died by suicide [1]. Prior to such extreme behaviors in which AI has played a prominent role, families have watched their children go from happily functioning individuals to people with anxiety, panic attacks, fear, and suicidal ideation, without having the skills to share the causes with trusted parents.[3]

Regulation of AI

In bringing lawsuits to force AI companies to take responsibility for the harm their products have caused children and teens, people face considerable odds. There are no Federal laws that protect children and teens from AI companies that have paid little attention to public safety. Only recently have states (Illinois, Nevada, Utah) begun to pass laws that may prohibit AI bots from presenting itself as a therapist, and from diagnosing or treating mental health conditions. Other states, such as Ohio and NY, have also passed laws that restrict AI companies in different ways.[4]

The FDA’s Digital Health Advisory Committee met in November, 2025, to discuss Generative Artificial Intelligence-Enabled Digital Mental Health Medical Devices. It allowed a comment period for organizations and individuals to offer ideas about what devices the FDA should consider to be medical devices, and how regulations should protect the public. The Clinical Social Work Association, alongside the Greater Washington Society for Clinical Social Work, submitted detailed comments to the FDA. These are useful documents that provide more specificity about risks for children and teens, particularly those with anger and depression, who rely on AI bots for emotional support.[5]

The FDA is authorized by law to regulate medical devices. Currently, AI bots are not regulated as medical devices, which they are in fact, though this technology has a major impact on the mental health of the public. How the FDA chooses to regulate medical devices that use AI is an important aspect of protecting the public, but it is not enough.

In December of 2025, the President signed an executive order banning states from regulating AI, which was later rescinded after a major outcry. Congress needs to pass a law that says states have the right to regulate AI, especially as it affects children and teens.

In The Atlantic magazine (12/11/25), Chuck Hagel (former Secretary of Defense and Senator) wrote about the significant problems with the lack of federal legislation to regulate and put guardrails on the indiscriminate growth of AI. Without laws, deep critical thinking, and planning based on the morality of how AI can be used, we lack safeguards against the harm being done to children and teens. Absence of adequate safeguards has already led to deaths and increased mental illness.[6]

Use of AI by LCSWs

Clinical Social Workers have begun to us AI in a variety of ways. Some clinicians may feel that they have already benefited from the use of AI in their practice. Some use AI programs to help with billing and scheduling or to record and summarize sessions. Some may use AI to help with symptom analysis and to pinpoint a diagnosis.

Any choice to benefit from use of AI also needs careful consideration of the potential risks. Many questions must be answered to understand these risks:

- Will the company sign a Business Associate Agreement that they and their AI programs will be legally responsible for, and that they will abide by HIPAA laws and protect the privacy of communication of LCSWs and clients?

- Will information that the company now has in its possession be used to train other bots or programs?

- Does client information now belong to the AI company, the LCSW, or the client?

- Does a child or teen client currently have a perceived relationship with a bot?

- How does a child or teen client think about the bot?

- Will the patient think of both the therapist and the bot as “co-therapists” working with them?

- How might having a bot co-therapist impact the clinician's therapeutic work with the patient?

CSWA Recommendations

CSWA recommends that LCSWs think as carefully about using AI in their practice as one would about anything that could impact the relationship with one's clients, such as receiving gifts, missed appointments policies, what one decides to say or not say, etc. Additionally, when evaluating a potential child or teen client, ask them about their use of AI in their day-to-day life, especially for mental health purposes.

Educate child and teen clients about AI, to the extent that they are developmentally ready to receive the information. If the clinician is using AI in their practice in a way that involves sharing information about the patient (even just in a billing program), best practice includes discussing the potential risks and benefits of the use of AI with the client and/or guardians, before asking them to sign an informed consent. If the patient or guardian does not agree, using AI in work with the client should be avoided.

Contact state legislators to find out if there are any laws impacting AI use in mental health. If there are no laws currently in place, advocate for changes with your local Society for Clinical Social Work (if there is one near you), or with your legislators. Pay attention to CSWA Alerts and contact your Congresspeople and Senators as requested.

CSWA supports the informed use of AI as a tool to help keep LCSWs records or provide research for our work. Understanding the ways that child and teen clients are using AI as an adjunct to actual therapy with a trained professional is now also an important area to explore.

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[1] The Impact of Social Media on Children’s Mental Health: A Systematic Scoping Review by Ting Liu, et al., National Institute of Health,  https://pmc.ncbi.nlm.nih.gov/articles/PMC11641642/ 

[2]  “Her daughter was unraveling, and she didn’t know why. Then she found the AI chat logs”. By Caitlin Gibson, 12/23/25, Washington Post.

[3] “What my daughter told ChatGPT before she took her life”, Laura Reiley, New York Times, 8/24/25. 

[4] Retrieved from https://www.ilga.gov/documents/legislation/104/HB/10400HB1806.htm,

 https://archive.leg.state.nv.us/Session/83rd2025/Bills/AB/AB406_EN.pdf.

[5]  Retrieved from https://www.regulations.gov/document/FDA-2025-N-2338-0001/comment?pageNumber=4

[6] Retrieved from  The Atlantic, https://www.theatlantic.com/ideas/2025/12/ai-regulation-moratorium-threat/685216/?gift=x-mI35MFP_bXNYPJbOAfvvaEeKHfeA0XJxlaUqZW7vU

[7] CSWA Position Paper, “Use of Artificial Intelligence», 2025

[8] American Academy of Pediatrics, https://www.aap.org/en/patient-care/media-and-children/center-of-excellence-on-social-media-and-youth-mental-health/qa-portal/qa-portal-library/qa-portal-library-questions/screen-time-guidelines/?srsltid=AfmBOorhIpwD9dhcaHVwPpS-wsEjzJY0TMASMG3Renqh13WrBC

January 16, 2026

Yesterday CSWA participated in the Congressional Briefing on maintaining Professional Degrees in mental health. One of the six panelists at the event, attended by many legislators and staffers, was Jordyn Skahill, CSWA’s MSW intern from Utah State. Jordyn was the only student to participate and gave a stellar explanation of how changing the MSW in clinical social work from a Professional Degree to a Graduate Degree would have made it impossible for her to attend the MSW program at Utah State University; the change in degree would cut access to FAFSA funding by over 60 percent.

Jordyn was a presenter with several leaders in social work, including the Executive Director of the National Association of Social Work (NASW), Anthony Estreet (picture below). CSWA Deputy Director of Policy and Practice, Judy Gallant, LCSW-C, graciously offered to house Jordyn during her DC stay, and to lobby with Jordyn after the Briefing.

Many thanks to Jordyn and Judy for representing CSWA so well (full text of Jordyn’s remarks).

There are now five bills that would maintain the MSW as a Professional Degree with the current levels of loan availability. CSWA will let members know when the bill that looks promising is known so they can contact their members of Congress.

Please contact Laura Groshong, LICSW, CSWA Director of Policy and Practice with any questions at lwgroshong@clinicalsocialworkassociation.org.

January 2026

As most CSWA members know, the Association of Social Work Boards (ASWB), which oversees the licensure examinations for social workers, has been working for the past three years to eliminate the disparities in pass rates to the exam (see ASWB Report, 2022). CSWA has been having quarterly meetings with ASWB leaders to share updates in the field, as well as to discuss the problems we have seen in the clinical examination.

ASWB has just released the first of several changes which will be made to improve the exams as follows:

Association of Social Work Boards Examination Changes

The exam will shift from four content areas to three to better reflect real-world social work practice.

The total number of questions will be reduced (specifically from 150 scored + 20 pretest to 110 scored + 12 pretest) while maintaining the 4-hour exam time.

There will be a stronger emphasis on problem-solving, reasoning, and application - not just recall.

The updated exam will feature a higher proportion of 3-option multiple-choice items to improve clarity and focus.

These changes are set to go live in August 2026. ASWB hopes these changes will lead to a more streamlined, relevant exam; content that mirrors current professional practice; and a greater emphasis on real-world skills. The other changes which CSWA hopes will be addressed will be the pass disparities which have been identified. ASWB’s information on the topic can be found at https://www.aswb.org/upcoming-changes-to-the-social-work-licensing-exams/.

December 8, 2025

CSWA submitted comments to the Federal Drug Administration on the use of AI yesterday. These comments included the previously distributed CSWA Position Paper on Artificial Intelligence, as well as comments developed by the Greater Washington Society for Clinical Social Work. You can view the pdf of the submitted comments below.

Thank you!

Comments Submitted to the FDA

December 1, 2025

Some important changes are being proposed in the way that loans for MSW and DSW social work degrees are funded by the Federal government. Under current rules, students can borrow the full amount of the cost of the program they are attending. With new limits in the One Big Beautiful Bill Act (OBBBA; P.L. 119-21), federal loans for “graduate degrees,” which now includes degrees in social work, will be capped at $20,500 for each academic year or a total of $100,000 over a lifetime.

Changes were made by the Department of Education to the categorization of numerous previously designated “professional degrees” that are now designated as “graduate degrees.” Social work is one of the degrees that now falls in the “graduate degree” category and will only qualify for a lower level of Federal loan funding than “professional degrees.” Other degrees that are being classified as “graduate degrees” include accounting, architecture, audiology, business Masters, counseling and therapy, education, engineering Masters, nursing, occupational therapy, physical therapy, physician assistant, public health, speech and language pathology. Graduate programs for professional counselors and marriage and family therapists, while not mentioned by name, would also be seen as conferring graduate degrees. 

For more information, please visit https://www.usatoday.com/story/news/nation/2025/11/21/what-considered-professional-degree-explained/87396245007/.

This will impact the affordability of social work and other graduate degrees, by decreasing the Federal loan amounts students can qualify for, and will create a barrier to students being able to afford graduate social work education, including for clinical social work practice (it does not affect being licensed as a clinical social worker, as licensing is in the purview of the states). The irony of the exclusion of clinical social workers, counselors, and MFTs from having professional degrees, as we do now, is that it comes at a time when there is clearly a rapidly increasing need for mental health services.

Action Needed

Please send the following message to your members of Congress to educate them about the serious harm these decisions would have to educating clinical social workers and promoting access to behavioral health treatment at https://www.house.gov/representatives/find-your-representative for your representative and https://contactsenators.net/email-addresses for your senators.

Here is suggested language but you can use your own as well:

“I am a licensed clinical social worker, a constituent, and a member of the Clinical Social Work Association. I am writing to let you know about a potential threat to our citizens who need to access mental health treatment. The Department of Education is currently developing a plan to limit Federal loan funding to clinical social workers by claiming they are not “professional” degrees.

LCSWs have received a Masters Degree, have 4-5 years of training in supervised mental health treatment and have passed a national examination to become licensed. We are the largest group of mental health providers in the country, at over 400,000 currently (CSWA, 2025). Cutting funding and arbitrarily saying that clinical social work graduate degrees are not a professional degree is simply wrong and needs to be stopped. To see what the Department of Education is proposing, please go to https://www.ed.gov/about/news/press-release/us-department-of-education-concludes-negotiated-rulemaking-session-implement-one-big-beautiful-bill-acts-loan-provisions.

If the new regulations go into effect, loan limitations for graduate social work education will prevent many students from attending school and receiving their Masters Degree and will prevent them from providing mental health care. The Department of Education will be voting on the final regulations under the Accountability in Higher Education and Access through Demand (AHEAD) Committee, scheduled to meet on December 8–12, 2025.

Thank you for your attention to this potentially harmful attempt to limit access to clinical social workers and to addressing the US mental health crisis. I would be happy to talk with you further.”

Laura Groshong, LICSW, CSWA Director of Policy and Practice will keep members posted on further developments. As always, please let her know when you have sent your messages by emailing lwgroshong@clinicalsocialworkassociation.org.

November 15, 2025

By Laura Groshong, LICSW, CSWA Director of Policy and Practice

Here is some relatively good news.

The bill opening the Federal government this week included another extension that delays the in-person requirements for Medicare patients that went into effect on October 1. The new deadline for this extension is January 31, 2026.

It is frustrating to have these short-term extensions. CSWA will continue to work to have the in-person requirement for telemental health treatment eliminated permanently.

I’ve had several posts from members concerned about how the in-person requirement would affect the interstate licensure Compact if it were to go into effect as it seems there is a conflict between the requirement and that the Compact is supposed to allow LCSWs to see patients virtually. The way this conflict may be solved is to call seeing a patient in person a “burden” because distance is too far to meet in person. This is an option in CMS guidance though distance is not specifically mentioned as a burden. There is no guarantee that this will be accepted by CMS as a burden. There are 14 Compacts with thousands of licensees across various professions and all of them are facing this problem, so I expect there to be some kind of exemption for Compacts.

Another ongoing concern is whether commercial insurers are starting to adopt the in-person requirement. I have had anecdotal reports about insurers that are taking this route but there is no major company I am aware of that is doing so. Be careful to read any information from plans in which you are paneled to stay on top of this issue.

On another note, please take the Telemental Health Survey sponsored by CSWA and NASW. We have almost 500 responses and want to get as many as possible by November 22 when the survey closes. Thanks for your help.

November 11, 2025

Update by By Laura Groshong, LICSW, CSWA Director of Policy and Practice

I attended a 6-hour meeting on the Compact Commission on November 5, 2025. It was the first annual meeting of the Commission. About 40 people attended, mostly delegates from the 30 states that have joined the Compact. At that time, there were 5 states with pending legislation. Here are the high points from the meeting.

A data system was chosen to process all the LCSWs who join the Compact. Unique identifiers will be assigned to each Compact member.

As for finances, there is still a lot of work to do by the Commission to figure out what the fees will be to join the Compact. More information will be coming in 2026. The Commission itself is primarily a home for all the data collected by the states and a way to make states aware of any disciplinary issues that arise across Compact states.

The Compact should be set up by the end of 2026 as states start to process Compact members. States will on-board in groups, not all at once. There are many more steps to getting the Compact ready to start. CSWA will keep you informed as the Commission puts the rest of the structure in place.

Let me know if you have any Compact questions by emailing me at lwgroshong@clinicalsocialworkassociation.org.

October 29, 2025

For those of you who have been following the development of the Social Work Compact, the Compact Commission's Annual Meeting, to be held on November 5, 2025 from 9 am to 5 pm ET, is an opportunity to hear more details about the progress being made. The Compact Commission oversees the creation of the Social Work Compact. Delegates from the 32 states that have passed legislation to join the Compact will be attending. 

To register to attend the Annual Meeting, please visit https://swcompact.org/meetings/full-commission-meetings/.

Please contact CSWA Director of Policy and Practice, Laura Groshong, LICSW, with any questions at lwgroshong@clinicalsocialworkassociation.org.

October 24, 2025

Regarding our update sent on 10/22/25 which stated that Kaiser Permanente as an insurer is requiring a yearly in-person visit for patients receiving telemental health services: this only applies to Medicare Advantage enrollees whose benefits are managed by Kaiser Permanente. It appears this notice was sent to LCSWs in the states of Washington and Oregon.

To our knowledge, CMS has required all Medicare Advantage plans – overseen by commercial insurers – to implement the in-patient requirement. If you receive a letter from Kaiser or other commercial insurers regarding the requirement, please let Laura Groshong, LICSW, Director of Policy and Practice, know at lwgroshong@clinicalsocialworkassociation.org. The Clinical Social Work Association is seeking clarification from CMS on how this affects the Medicare Advantage plans.

October 22, 2025

Here are two additional pieces of news related to the Medicare Telemental Health changes. First, the good news! CMS has decided to eliminate the hold on payment of claims for mental health treatment (though not for other health care services) so claims will be paid on the usual basis, i.e., about 14 days after being submitted. Below is the message that was sent yesterday from CMS (yellow highlight mine):

Claims Hold Update

"CMS instructed all Medicare Administrative Contractors (MACs) to lift the claims hold and process claims with dates of service of October 1, 2025, and later for certain services impacted by select expired Medicare legislative payment provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025 (Pub. L. 119-4, Mar. 15, 2025). This includes claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and Federally Qualified Health Center (FQHC) claims. This includes telehealth claims that CMS can confirm are definitively for behavioral and mental health services. CMS has directed all MACs to continue to temporarily hold claims for other telehealth services (i.e. those that CMS cannot confirm are definitively for behavioral and mental health services) and for acute Hospital Care at Home claims.

Beginning October 1, 2025, for services that are not behavioral health services, many of the statutory limitations on payment for Medicare telehealth services that were, in response to the COVID-19 Public Health Emergency, lifted, and subsequently extended, through legislation again took effect. These include prohibition of many services provided to beneficiaries in their homes and outside of rural areas, and hospice recertifications that require a face-to-face encounter. In the absence of Congressional action, practitioners who choose to perform telehealth services that are not payable by Medicare on or after October 1, 2025, may want to evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage (ABN). Further information on use of the ABN, including ABN forms and form instructions: https://www.cms.gov/medicare/forms-notices/beneficiary-notices-initiative/ffs-abn. Practitioners should monitor Congressional action and may choose to hold claims associated with telehealth services that are currently not payable by Medicare in the absence of Congressional action. For further information: https://www.cms.gov/medicare/coverage/telehealth."

Now for the not so good news: Kaiser Permanente has decided to start requiring the in-person meeting with patients once during every 12-month period that Medicare implemented on October 1. We can expect other commercial insurers to follow suit. Please let Laura Groshong, LICSW, CSWA Director of Policy and Practice, know if you get any information about this from insurers that you work with by contacting her at lwgroshong@clinicalsocialworkassociation.org.