November 4, 2021
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.
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, CSWA Director of Policy and Practice
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