July 3, 2025

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

A new rule issued by CMS affects the practices of LCSWs. I encourage all CSWA members to read the entire rule at https://www.cms.gov/files/document/mln1986542-medicare-mental-health-coverage.pdf. I want to call your attention to two parts of the rule that are problematic (I added the yellow highlighting), specifically related to clinical social workers’ ability to provide services in skilled nursing facilities, as well as in-person visit requirements. See the glossary of terms used by CMS below*, as well as a detailed interpretation of the rule:

MFT Scope of Medicare Practice/MHC Scope of Medicare Practice

Payment

- We pay only on assignment.

- We pay for services at 80% of the lesser of the actual charge or 75% of the amount a CP gets under the PFS.

- We don’t pay under the MFT benefit category for MFT services to patients under a PHP or an IOP by a hospital outpatient department or CMHC.

- We exclude MFT services provided to SNF residents from consolidated billing. Include the SNF’s Medicare provider number when you bill for these Part B services. This means MFTs and MHCs can bill Medicare for independent services in SNFs while CSWs cannot.

LCSW Scope of Medicare Practice

Clinical Social Worker

Payment

- We pay only on assignment

- Paid at 80% of the lesser of the actual charge for the service or 75% of the CP’s PFS

[No coverage of independent CSW services as for MFTs and MHCs] This means that CSWs cannot bill Medicare for independent services in SNFs while MFTs/MHCs can.

All Mental Health Clinicians

In-Person Meetings

Starting October 1, 2025, in-person visit requirements will apply for mental health services provided by telehealth. This includes a required in-person visit within the 6 months before the initial telehealth treatment, as well as the required subsequent in-person visits at least every 12 months.

Problems:

The problems CSWA sees with this rule are as follows:

1. The long standing (1997) rule that has prevented LCSWs from providing psychotherapy for residents of skilled nursing facilities does not apply to MFTs and MHCs who are allowed to do so. This is extremely unfair to LCSWs. We must be allowed the same privilege.

2. There will be an in-person requirement every 6 months/12 months when patients are being seen virtually. This would likely make it impossible to work with virtual patients who are more than an hour away; in addition, some LCSWs no longer have an actual office. This will also interfere with the way the Social Work Compact will be run when it opens in the next year, as the Compact will allow LCSWs to work in all member states without seeing patients in person.

Action steps:

CSWA will be addressing the disparity in Part B coverage between CSWs and MFTs/MHCs working in SNFs, as well as the issue of seeing patients in person every 6 months/12 months to conduct virtual psychotherapy. Your help is needed. Please send the following message to your members of Congress at https://www.congress.gov/contact-us: “I am a constituent and a member of the Clinical Social Work Association. The new Medicare rule at https://www.cms.gov/files/document/mln1986542-medicare-mental-health-coverage.pdf will seriously impact the psychotherapy practices of licensed clinical social workers, the largest group of mental health clinicians in the country (370,000). Please tell CMS to include LCSWs as a group that can bill independently for psychotherapy services in SNFS under Part B; all other Master’s mental health clinicians are now allowed to do so. Also, please eliminate the requirement that patients being seen virtually must be seen in person every 6-12 months. This would make it impossible to see patients in other states or jurisdictions as many LCSWs do now.”

As always, please send me an email at lwgroshong@clinicalsocialworkassociation.org when you have sent your messages.

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*GLOSSARY

CMHC = community mental health center (Federal)

CP = clinical psychologists

IOP = intensive outpatient services

MFT = licensed marriage and family therapist

MHC = licensed mental health counselor

PFS = physician fee schedule [includes LCSWs]

PHP = primary health provider

SNF = skilled nursing facility

May 20, 2025

A week ago, the Trump Administration announced its intention to stop the passage of the 2024 Mental Health Parity Rule that would have made the 2008 Mental Health Parity and Addiction Parity Act (MHPAEA) enforcement much stronger. As most CSWA members are aware, the implementation of this 16-year-old law has been a challenge [laws are the beginning of the legislative process which are implemented by rules]. The constant problems LCSWs have dealing with prior authorizations, network adequacy, reimbursement rates, timely reimbursement of claims, and more would have been largely resolved in the 2024 rule proposed by the Biden Administration. (View the proposed rule at https://www.federalregister.gov/documents/2024/09/23/2024-20612/requirements-related-to-the-mental-health-parity-and-addiction-equity-act.)

Also about a week ago, the Trump Administration stopped putting new rules out for public comment, making it difficult for CSWA and other organizations to have a voice in the development of new rules. This is a major attack on the democratic process which allows the public to have a voice in the implementation of our laws.

One way we CAN affect rules is by contacting our members of Congress to ask that they informally influence the administration and agencies that carry out the proposed rule. An excellent summary of the dangers of eliminating the proposed rule can be found at KFF by visiting https://kffhealthnews.org/news/article/trump-biden-mental-health-parity-insurance-law-coverage-deadline/. These helpful materials can be used to develop a bill in Congress to implement this rule. Even though the current administration has announced that they are unwilling to implement any of the 2024 proposed rule, we can let our members of Congress know that we as constituents want them to push back on this attempt to allow insurers to continue practices that hurt LCSWs and our patients.

Here is a template for that you can use to send a message to your members of Congress at https://www.congress.gov/contact-us: “I am a licensed clinical social worker, a constituent, and a member of the Clinical Social Work Association. I am writing to ask you to oppose the intent of the Trump Administration to stop the 2024 Rule for the Mental Health Parity and Addiction Parity Act. For 16 years this Act has languished because passing meaningful rules has been opposed by insurers and the corporations that have become the groups that control our health care system. Please give our citizens the access to the mental health and addiction services they need by pushing for the passage of the 2024 MHPAEA Rule.”

As always, please let CSWA Director of Policy and Practice, Laura Groshong, LICSW, know when you have sent your messages by emailing her at lwgroshong@clinicalsocialworkassociation.org.

May 9, 2025

As the current administration continues to implement harmful policies affecting both our practices and our patients, you may have not have heard about the changes being made to how LCSWs are providing mental health services in the Veterans Administration. There is an excellent article in the New York Times about the way this has impacted confidentiality and privacy about this problem, which we hope you will all read. 

In short, most of the 100,000 LCSWs and other VA mental health staff have been required to return to working in offices without having private spaces in which to work. As the article notes:

“In a Boston V.A. hospital, six social workers are conducting phone and telehealth visits with veterans from a single, crowded room, clinicians say. In Kansas City, providers are planning patient care while facing each other across narrow, cafeteria-style tables in a large, open space, according to staff members.

And in South Florida, psychiatric nurses have been treating veterans with mental health conditions in a hallway near a bathroom, sitting down with them in a makeshift medical bay jury-rigged out of filing cabinets and a translucent screen.”

This new policy violates basic social work ethics and HIPAA rules. As stated in the Clinical Social Work Association (CSWA) Code of Ethics (2024):

“Clinical social workers have a primary obligation to maintain the privacy of both current and former clients, whether living or deceased, and to maintain the confidentiality of material that has been transmitted to them in any of their professional roles. Exceptions to this responsibility will occur only when there are overriding legal or professional reasons and, whenever possible, with the written informed consent of the client(s).”

The conditions under which LCSWs are being forced to work violates this fundamental clinical premise. This puts LCSWs in a difficult position of choosing between ethics, their livelihoods, and continuing to serve their patients. The CSWA calls on the VA to ensure all mental health professionals in their organization have private spaces in which to work.

CSWA would like to know if any members who work for the VA or have other connections to VA patients have been affected by these changes. Please let CSWA Director of Policy and Practice, Laura Groshong, LICSW, know if this is your experience by emailing her at lwgroshong@clinicalsocialworkassociation.org.

April 22, 2025

The Clinical Social Work Association (CSWA) and the Psychotherapy Action Network (PsiAN) are alerting mental health professionals, the public, and regulators that a company called 7 Cups of Tea, or 7 Cups, has used the professional information of licensed mental health clinicians without permission or notification. Using clinicians’ names and professional information is concerning on many levels. First, 7 Cups is a for profit business, and it is using this information about therapists, which it has obtained in unclear ways, to sell its own services. Second, 7 Cups’ actions may also represent a restraint of trade, and we are pursuing legal options on this front. Finally, this marketing tactic adds to the confusion of unreliable information circulating online about mental healthcare and breeds mistrust, which is especially concerning at a time of such high need for reliable and effective psychotherapy.

In addition, the 7 Cups website offers connections both to licensed mental health clinicians and to “listeners.” While talking to someone about one’s problems may be helpful, it is starkly different from engaging in therapy with a professional. 7 Cups listeners are rated and rewarded as they are on many apps and games, earning “cheers” and “compassion hearts” for increased engagement. Blurring the lines between professional treatment and gamified interactivity is a fraught strategy, and will likely only add to the confusion people have when they are in need of effective mental healthcare.

Background Information

7 Cups is apparently taking information from therapists’ Psychology Today profiles, and other places, to list on its website, representing that these therapists work for 7 Cups. However, clinicians who wish to get referrals from 7 Cups must pay for the privilege, $39.99 a month. Additionally, here is a list of the costs which 7 Cups charges clients for various services:

Free: Access to volunteer listeners, chat rooms, and forums.

Premium: $7.99 monthly for 1-on-1 chats with an Active Listener, group chats, and the AI chatbot.

Messaging Therapy: $159 monthly for text-based therapy with a licensed therapist.

Talk Therapy: $299 monthly for all premium features and a weekly video call with a therapist.

These tactics are similar to those that were used by a company called CareDash in 2022. The difference is that CareDash used data taken from the government’s NPI database. Following complaints filed to the Federal Trade Commission by CSWA, PsiAN, and other organizations, CareDash’s parent company shut down that business.

Guidance for Therapists

To protect therapists and the public, here is what CSWA and PsiAN recommend therapists do to protect their practices and the public:

1. Google “7 Cups [your name]” to confirm that you have been listed on this website. This is more likely if you have a Psychology Today profile.

2. Once you see your name is listed, go to 7 Cups help and use the drop down box to “data removal request”.

3. You should receive confirmation that your request was received in the next 24 hours. If you do not, send your request again.

4. Contact your state’s Insurance Commissioner about this attempt to stop potential clients from contacting you, since anyone who checks a clinician’s name who has not paid a fee is referred to 7 Cups' own list of clinicians. Here’s a link to locate your state’s commissioner.

5. Email the 7 Cups' legal department at legal@7cups.com or have your attorney contact them and ask 7 Cups to “cease and desist” using your professional information. If you prefer to use their mailing address, it is 7 Cups of Tea Company, 1201 Orange Street, #600, Wilmington, Delaware 19899.

6. Contact your state Attorney General with this information and ask them to investigate as this seems to violate the Lanham Act which is designed to keep companies from profiting from the name and professional qualifications of others without consent.

7. Contact the Federal Trade Commission to report this issue. The FTC will ask for an actual address which is 7 Cups, 746 E. Colorado Blvd, Pasadena, CA 91101.

8. You may also file a complaint with your state attorney general consumer protection.

9. Here is a template for sending a complaint:

I am a Licensed [enter your discipline] writing to inform you that a company, 7 Cups, is unfairly restricting my practice as [your discipline]. They have listed my professional information on their website without my permission and refer anyone who checks my name to their own list of clinicians. I do not wish to work with 7 Cups, nor even to have my name listed on what they call a “registry”. The bulk of people on this registry are doing “listening,” which is not psychotherapy and does not require a license. Having my name on this registry blurs the line between what might be considered coaching/peer support and psychotherapy. This is a restriction of trade that should be stopped immediately.

These marketing tactics add to the confusion of unreliable information circulating online about mental healthcare. As we know, many people seeking care are especially vulnerable and need effective psychotherapy.

CSWA and PsiAN encourage all members and affiliated societies to file complaints with the appropriate state and/or national organizations.

Contacts:

Stephanie Payne, LCSW, President, Clinical Social Work Association, president@clinicalsocialworkassociation.org

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

Linda Michaels, PsyD, MBA, Chair, Psychotherapy Action Network (PsiAN), Linda.michaels@psian.org

April 8, 2025

Thanks to all of you who have contacted our Director of Policy and Practice, Laura Groshong, LICSW, to let her know you have sent messages to 7 Cups that you would like to be taken off their list. Please continue to check if your name is on the 7 Cups list. CSWA is working with the Psychotherapy Advocacy Network (PsiAN) to expand the number of clinicians who respond to 7 Cups. This effort is more complex than our work with CareDash was because 1) it has been in place and gathering clinicians’ information for much longer, and 2) it mixes peer counseling and licensed professionals together without acknowledging the differences in scopes of practice, training, and regulation.

CSWA will be writing a letter to the 7 Cups Legal Department to demand that the ways our professional information is being used without our permission, as well as confused with unlicensed people, be stopped. We will be sending more information on how to fight this attempt to make clinicians join the 7 Cups network or risk losing potential patients. Here is a summary of what we know so far.

The following letter has been sent to many clinicians when they ask to be removed from the 7 Cups list:

Thank you for contacting 7 Cups. 7 Cups is the world’s largest mental health community. We have over 570,000 trained volunteer listeners across 189 countries that provide support in 140 languages. We have reached over 73 million people. Often, we need to make referrals to licensed clinicians, shelters, and food pantries. That is why we built our provider directory and local support service. We are now starting to make referrals to local clinicians.

The goal of the local support systems (7cups.com/local) is to connect people online to services offline so they can get better help. We believe therapists are an important part of local support systems.

I understand that you may have reasons for wanting to be removed, but I wanted to share some additional context that you might find helpful. 7 Cups sends out thousands of free referrals to therapists every month. If someone were to complete the contact form on your profile, we would forward their information to you for follow-up. This would essentially be a free referral for you. We operate similarly with food pantries and shelters, as our goal is to connect people with local resources in their community.

We are providing therapists the option of a free premium month of being listed on 7 Cups to gain additional referrals. We are also providing this premium service to therapists free of charge if they cannot afford it as we think it is important for therapists to get referrals and build their practice. We want to feature as many therapists we can as part of the local support system.

If you do not wish to have your profile listed and decide not to become part of our local support network then please let us know and we will delete your profile within 48 business hours.

When members have checked to see whether their names were in fact removed, often they were not within the 48 hours as 7 Cups said they would. One malpractice insurer has recommended the use of our information without our permission be considered internet fraud and that a complaint be filed with the Internet Crime Complaint Center (https://www.ic3.gov/). This can be added to the list of actions to be taken to oppose 7 Cups from our previous post.

CSWA will continue to provide information about this unfair and possibly illegal activity as we have it.

April 3, 2025

As an organization dedicated to the needs of our patients, licensed clinical social workers and the practice of clinical social work, the Clinical Social Work Association (CSWA) strongly opposes the Trump Administration’s ongoing efforts to eradicate diversity, equity, and inclusion (DEI) initiatives. These actions contradict the foundational values of social work, threaten the well-being of marginalized individuals and communities, and hinder clinical social workers’ efforts to ensure equitable access to society’s benefits.

Our profession is built on a commitment to both mental health and social justice, ensuring that all individuals—regardless of race, ethnicity, gender, sexual orientation, disability, or socioeconomic status—have access to equitable opportunities and care. The dismantling of DEI initiatives undermines these efforts, reinforcing systemic disparities and eroding progress toward a more just society.

The dignity and worth of the person-in-environment is central to clinical social work. We recognize that acknowledging and addressing systemic inequities is essential to affirming the humanity of all individuals. The importance of human relationships further compels us to foster inclusive spaces that support diverse voices and lived experiences.

As social workers, we are bound by the principles of integrity and competence, requiring us to base our practice on evidence and ethical responsibility. Decades of research affirm that culturally competent and inclusive approaches improve client outcomes, making DEI efforts a professional necessity, not a political choice.

CSWA stands firmly against policies that seek to erase or delegitimize DEI initiatives. The attack on DEI principles is a misguided and harmful attack on our profession and the people we serve. We call upon policymakers, educators, and practitioners to uphold the field of clinical social work’s mission by advocating for policies that promote inclusivity, equity, and the well-being of all communities.

Stephanie Payne, LCSW, President

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

March 27, 2025

An incident has come up in which our professional information may have been – or may be – taken and used without your permission. Here are the details and ways to protect your practices.

7 Cups of Tea

A few days ago, a new attempt to use the professional information of LCSWs to direct potential patients to another website and other therapists emerged. It is called 7 Cups of Tea. The information appears to have been taken from Psychology Today profiles and put into their website, as if we were working for 7 Cups. This is the same tactic that was used by a company called CareDash in 2022. The difference is that CareDash used data taken from our NPI accounts. Following complaints filed to the Federal Trade Commission, CareDash’s parent company shut down the business.

To protect ourselves from having patients sent to other clinicians without our permission, there are several steps that need to be taken as follows:

1. Google “7 cups [your name]” to confirm that you have been listed on this website. This is more likely if you have a Psychology Today profile.

2. Once you see your name is listed, go to https://help.7cups.com/hc/en-us/requests/new?ticket_form_id=36000205411 and use the drop down box to “delete my information”.

3. You should receive confirmation that your request was received in the next 24 hours. If you do not, send your request again.

4. Contact your Insurance Commissioner about this attempt to stop potential clients from contacting you.

5. Contact 7 Cups' legal department at legal@7cups.com or have your attorney contact them and ask to have them to “cease and desist” using your professional information. If you prefer to use their mailing address, it is 7 Cups of Tea Company, 1201 Orange Street, #600, Wilmington, Delaware 19899.

6. Contact your state Attorney General with this information and ask them to investigate as this seems to violate the Lanham Act which is designed to keep companies from profiting from the name and professional qualifications of others without consent.

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

March 17, 2025

As CSWA predicted, the Continuing Resolution to keep the Federal government running passed the Senate on March 14, having already passed the House, with the stipulation that telemental health, telehealth, and audio-only treatment through Medicare be continued for six months beginning April 1, 2025. This means that there will need to be another vote to continue coverage of telemental health after October 1, 2025. As we know, most commercial insurers follow the Medicare policies.

An even better outcome is that the in-person requirement every 6 or 12 months is put on hold as well.

The text of the Continuing Resolution that confirms this in the Federal Register as follows:

p. 93 of CR

(d) DELAYING THE IN-PERSON REQUIREMENTS UNDER MEDICARE FOR MENTAL HEALTH SERVICES FURNISHED THROUGH TELEHEALTH AND TELECOMMUNICATIONS TECHNOLOGY.— (1) DELAY IN REQUIREMENTS FOR MENTAL HEALTH SERVICES FURNISHED THROUGH TELEHEALTH.—Section 1834(m)(7)(B)(i) of the Social Security Act (42 U.S.C. 1395m(m)(7)(B)(i)) is amended, in the matter preceding subclause (I), by striking ‘‘on or after April 1, 2025’’ and inserting ‘‘on or after October 1, 2025,’’

(e) ALLOWING FOR THE FURNISHING OF AUDIO ONLY TELEHEALTH SERVICES.—Section 1834(m)(9) of VerDate Sep 11 2014 12:32 Mar 11, 2025 •HR 1968 EH  the Social Security Act (42 U.S.C. 1395m(m)(9)) is amended by striking ‘‘ending on March 31, 2025’’ and inserting ‘‘ending on September 30, 2025’’.

Thanks to all who wrote to members of Congress.

March 13, 2025

Since CSWA published the Statement on Gender Executive Order on February 9, 2025, and the Retraction of the Statement on February 14, 2025, we have received multiple emails from members in response. We would like to give some context for where CSWA stands now on this important issue.

The blanket rejection of transgender treatment by the current administration is harmful to our patients and other individuals who are navigating their gender identity journeys. CSWA continues to stand by its beliefs that LCSWs have a fundamental ethical responsibility to honor and support individuals’ rights to self-determination. We also continue to affirm the right of transgender individuals to express their gender identity in a manner that promotes their mental health.

The responses have identified two major issues that led to the retraction of the original statements that require clarification. First, we used a term that is clearly out of date and should not be used when referring to gender identity. CSWA apologizes for the use of this language, and will not be using the term in the future. We are committed to ongoing professional development.

The second issue was much more controversial: the reference to the Cass Review in the original statement. The many comments on this study were quite divided, as were the comments on the retraction. There is a split in the field about whether the Cass Review is a valid document. Some members felt it was inappropriate to include it, some felt it was a major study that has some good points.

CSWA will continue to monitor the most current data that supports the mental health of the trans community in the hopes that a consensus emerges that aligns with our core social work value focused on the dignity and worth of the individual.

Thanks to all who took the time to educate CSWA on the state of current knowledge about treatment of transgender individuals.

 

Laura Groshong, LICSW, CSWA Director of Policy and Practice

Stephanie Payne, LCSW, CSWA President

CSWA Board of Directors

March 7, 2025

It is clear from the responses that CSWA has received to our post yesterday that there is more to say about asking patients to advocate for continuing telemental health as an option for delivery of mental health delivery treatment.

Asking patients to contact their elected representatives should only be done with patients who are not vulnerable or fragile. This is an unusual situation which affects both LCSWs and patients. Discussing the meaning of the LCSW asking for the patient’s help, the feelings which are stirred up by this, and the way it connects with the patient’s past, is of course recommended with any patient who is asked to contact legislators. This is not a requirement, only an option, if it is appropriate to each clinician with each patient.

Additionally, some members expressed concern about risks to patients if they voluntarily disclose that they are receiving services for mental health or substance use. This should also be considered and discussed with clients.

Many LCSWs do not have in-person offices any more so virtual treatment is all that they can offer. Many patients have come to treatment because they had difficulty getting to an office and need the telemental health option. To reiterate, time is short as virtual treatment may end on March 31 of this month.

In light of the concerns that CSWA has heard, for members who, after assessment, decide that a patient may be willing and able to contact legislators in Congress, here is revised language for them to use: “I am your constituent and believe that the following action is essential for the mental wellbeing of all citizens. Please extend Medicare coverage of telemental health treatment which is currently scheduled to end on March 31.”

CSWA always welcomes feedback from our members. Contact Laura Groshong, LICSW, Director of Policy and Practice, at lwgroshong@clinicalsocialworkassociation.org.