October 15, 2025

Here is an update on the ongoing issues which have been raised around telemental health since October 1 when the in-person requirement went into effect for LCSWs and other mental health clinicians.

To recap, there is now a requirement that we see all NEW Medicare patients – after October 1 – at least once in-person before starting virtual treatment. After that, we need to see them once a year in-person. The hope is that this rule will be stopped permanently, or that exemptions will be again extended, when the government reopens. For LCSWs that have given up their offices, this will create a problem. Many are using the offices of colleagues; others are reconsidering finding an office of their own again. The advantages of not paying rent have to be weighed against the problem of not having a place to see patients in person.

There is an exemption for new Medicare patients who cannot be seen in-person. This must be explained and entered into the Medical Record. A template has been created for your use. It can be found in the Members-Only section of the CSWA website.

Another consideration, which will be hard on those of us who see many Medicare patients, is that there is a recommendation from the Mental Health Liaison Group (MHLG) Telehealth Group that we not file claims until after the government reopens. They will be denied because they cannot be processed and would have to be filed as an appeal once the government reopens. This will be a real hardship for us but there is no solution at the moment. This will NOT apply to Medicare Advantage patients unless the commercial insurers that offer those plans refuse to pay claims as well. None have announced that they plan to do so at this time.

Please continue to notify your members of Congress about the hardship this will present for you and let me know when you have done so by emailing Laura Groshong, LICSW, CSWA Director of Policy and Practice at lwgroshong@clinicalsocialworkassociation.org.