October 8, 2020

I’ve received several questions about the HHS extension of the State of Emergency which I will answer below:

1. Does the HHS State of Emergency affect reimbursement for telemental health or audio only treatment? No, this only applies to the coverage in some form of telemental health and audio only therapy by Medicare and Medicaid, which is determined by CMS. Reimbursement rates are the same as for in-person sessions.

2. Does the HHS State of Emergency extension affect coverage and reimbursement by commercial insurers? The commercial insurers, e.g., Optum, Aetna, BlueCross/BlueShield, Cigna, etc., will develop their own policies about telemental health/audio only coverage. Many have followed the direction that CMS takes so far. Reimbursement is more varied. Some states have required insurers that cover telemental health and audio only treatment to reimburse at the same level as in-person treatment. Check with your Insurance Commissioner or Social Work Board.

3. Does the HHS State of Emergency extension affect the ability to provide treatment across state lines without being licensed in the state of the client? The extension does not address the ability to treat clients in states where the LCSW is not licensed. Some states have allowed LCSWs to get a temporary license, some allow temporary reciprocity if an LCSW is licensed in another state. There are a couple bills in Congress that would make this national policy if they are passed. For now, it is the responsibility of the individual LCSW to find out what the policy about treating clients in states where they are not licensed in that state, as well as in the state where they ARE licensed.

4. What will happen when the State of Emergency ends to coverage of telemental health and audio only treatment? That is currently unknown but unless there is a permanent requirement that telemental health and audio only treatment be covered as in-person treatment is, it is likely that insurers will only cover in-person treatment.

In short, coverage of telemental health and audio only treatment will now continue until January 21, 2021, for Medicare and Medicaid. The reimbursement rates will remain the same for Medicare and Medicaid during this time. Commercial insurers may follow this policy but are not required to. The responsibility to find out what coverage is for commercial insurers is our responsibility as LCSWs to check.

Let me know if you have any other questions about the State of Emergency extension at lwgroshong@clinicalsocialworkassociation.org.

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

October 6, 2020

A new extension of the State of Emergency has been signed by Alex Azar. This extends coverage of telemental health services and audio only services until January 20, 2021. Click here for the Memo.

Let me know if you have questions at lwgroshong@clinicalsocialworkassociation.org.

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

October 28, 2020

Please visit the CSWA Position Papers page to view a Position Paper on Mental Health. 

October 5, 2020

A new source of funds for behavioral health/mental health providers who have worked with anyone affected by the COVID-19 pandemic is now open. Phase 3 of the CARES Act Relief Fund will be available starting today, October 5, 2020, to any LCSWs who have met the criteria listed below until November 6, 2020. Any LCSW who meets one of the yellow outline requirements in the first section may apply. All criteria in the second section must be submitted. The link to apply is also listed below.

To be eligible to apply, the applicant must meet at least one of the following criteria:

Additionally, to be eligible to apply, the applicant must meet all of the following requirements:

Note: Receipt of funds from SBA and FEMA for coronavirus recovery or of Medicaid HCBS retainer payments does not preclude a healthcare provider from being eligible.

To apply go to https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html#how-to-apply.

Let me know if you have any questions.

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

October 5, 2020

Today, October 5, is the last day that comments about the possible Medicare cuts by CMS to LCSWs will be accepted. If you have not yet sent your comments to CMS, or messages to your members of Congress, please do so by TODAY at 5 pm ET or they will not be included.

As always, please let me know when you have sent these messages at lwgroshong@clinicalsocialworkassociation.org.

September 24, 2020

On September 16, you should have received a Legislative Alert to members of Congress regarding the proposed cut to Medicare reimbursement for LCSWs scheduled for January 1, 2021 ( copied below). Many thanks to the hundreds of members who have sent these messages. If you have not done so, it is not too late. While the issue of Medicare cuts is being opposed in the House through Rep. Rush’s letter, it is fine to send your message to Senators as well. All messages must be sent by October 5, 2020.

Now I am asking you to send another message directly to CMS (Centers for Medicare and Medicaid Services), the organization that oversees reimbursement rates for all Medicare providers, including LCSWs. Both messages are necessary to make our position on this issue clear by October 5, 2020. Send the following message (use your own words if you like) to the following link: https://www.federalregister.gov/documents/2020/08/17/2020-17127/medicare-program-cy-2021-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part.

“I am a Medicare provider [if you are] and wish to express my concern about the proposed rate reduction for Clinical Social Workers set to begin on January 1, 2021. Clinical Social Workers are already paid 25% less than other mental health providers for the same CPT Codes as other mental health providers. Though some psychotherapy CPT codes have increased, the 10.6% cut will result in a net reduction of about 7%. My fixed costs have not changed and I cannot afford this reduction in my fees for my mental health services.

The onslaught of COVID-19 has increased the need for mental health services. Please make it possible for me to continue to provide them by eliminating the proposed Medicare reimbursement cut.”

As always, let me know when you have sent both messages at lwgroshong@clinicalsocialworkassociation.org. Thanks for your help.

- Laura Groshong, LICSW, CSWA  Director of Policy and Practice, Government Relations Chair

September 19, 2020

2020 has been a challenging year for everyone. The pandemic has increased anxiety, fear, isolation and grief, leading to declining mental health and increased substance use in our communities that will only continue to get worse.

In July, the Federal Communications Commission (FCC) made the historic announcement that it had unanimously voted to designate 9-8-8 as the universal three-digit dialing code for the National Suicide Prevention Lifeline.

Unfortunately, the bipartisan, non-controversial National Suicide Hotline Designation Act is stalled in Congress, putting at risk the promise that this easy-to-access, three-digit dialing code for the life-saving services 9-8-8 could provide.

To date, the House and Senate have each approved similar, but not identical, bills establishing 9-8-8 as the dialing code and supporting the new hotline by establishing a funding mechanism through states and wireless phone carriers. But that legislation is not yet over the finish line. Without this bill becoming law, our communities will not be able to respond to the increasing demand for needed suicide prevention services.

CSWA urges you to call all your Members of Congress by tomorrow to help pass the National Suicide Hotline Designation Act. Go to https://www.contactingcongress.org/ to get their emails or phone numbers and leave the following message: “I am a member of the Clinical Social Work Association and a constituent. Please pass the National Suicide Hotline Prevention Act and save lives. The pandemic and other natural disasters have increased the number of citizens who have hopeless helpless feelings leading to suicidal thoughts. They need ways to access mental health treatment which the over 250,000 clinical social workers can provide.”

Thanks for your help. As always, let me know when you have sent your messages.

- Laura Groshong, LICSW, CSWA Director of Policy and Practice, Government Relations Chair

September 16, 2020

There is a proposed cut to Medicare reimbursement for many health care providers, including LCSWs, scheduled for January 1, 2021. This 7% cut is connected to Evaluation and Management services, for diagnostic and treatment services that LCSWs provide. It is imperative that all LCSWs contact their members of Congress as soon as possible to let them know how damaging this would be for LCSWs.

We are fortunate to have the support of Rep. Bobby Rush (D-IL) and 93 members of Congress in stopping this cut. Please check the letter they wrote to Congressional leadership at https://rush.house.gov/sites/rush.house.gov/files/documents/Letter%20to%20Leadership%20on%20EM%20Code%20Cuts%20General.pdf and thank your legislator if he or she signed on.

Even if you are not a Medicare clinician, please send the following message to your members of Congress at https://www.contactingcongress.org:

“I am a member of the Clinical Social Work Association, a Medicare provider [if you are], and a constituent. Maintaining budget neutrality on the backs of clinical social workers and other mental health providers is a burden that I will not be able to bear. I am already paid 25% less than other mental health providers for the same diagnostic and treatment services as other mental health providers. My fixed costs have not changed. The onslaught of COVID-19 has increased the need for mental health services. Please make it possible for me to continue to provide them by eliminating the proposed Medicare reimbursement cut.”

As always, let me know when you have sent your messages. 

- Laura Groshong, LICSW, CSWA Director of Policy and Practice, Government Relations Chair

August 12, 2020

There have been several opportunities for LCSWs who are Medicare, Medicaid or CHIP providers to access additional funds if our income has been affected by COVID-19. Through the Coronavirus Aid, Relief, and Economic Security (CARES-donation) Act and the Paycheck Protection Program and Health Care Enhancement Act (PPPCHE-loan), and the Provider Relief Fund (PRF-donation), the federal government has allocated $175 billion in payments to be distributed through HHS (administered by Optum).

Yesterday the fourth option was announced, the Provider Relief Fund Phase 2, which includes funding for LCSWs, and is detailed below. This is called the Phase 2 General Distribution funding. This is a way to make up lost income, not a loan. To apply for these funds go to https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html#key-facts-providers and complete the 6-step application process.

To date only a fraction of the $175 billion in funds has been claimed. Therefore, CMS is extending access to these funds, which was supposed to end on August 9 for all behavioral health providers and other health care providers, including for LCSWs, until August 28, 2020. The funds distributed will be up to 2% of all income from Medicare, Medicaid or CHIP in tax years 2017, 2018, or 2019 (not all three, just the highest one).

HHS will host a webinar on Thursday, August 13, at 3PM EDT. Register here to learn more about the application process, which is somewhat cumbersome.

You need to be able to document lost income due to COVID-19 and provide the income that you received from Medicare, Medicaid or CHIP per your tax returns for one of three previous years to 2020.

I hope this will be somewhat helpful to members who work in these areas and help give some relief for those who have seen a decline in revenue during these difficult times.

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

July 29, 2020

Regardless of how we feel about providing psychotherapy through telemental health, LCSWs are currently in the position of having to continue to use telemental health or audio only mental health treatment for many months to come. Since mid-March, the vast majority of LCSWs who used to have an office where they met in person with patients, have been working from home. We have mostly made peace with the frustrations and, occasionally, surprising advantages, of working from home online or on the phone.

Returning to the Office – The conditions that would allow us to return to our offices without major changes to the air flow and air cleaning, use of masks, plastic shields, are not easy to create and there will be a high level of risk in some areas that is potentially harmful to many of us. That is why it is so important that Secretary Azar extended the public emergency declaration to October 23, 2020, this week to allow the use of telemental health to continue to be covered by Medicare. Be aware that this does not guarantee that private insurers will continue to cover telemental health.

Legislative Goals – Other immediate goals are to make telemental health a permanent option through Congressional laws; to make reimbursement for telemental health at the same level as for in office visits; and to compare the use of in office and telemental health treatment delivery methods. There are about 10 bills that would impact some or all of these issues. CSWA will keep you aware of the progress of these bills as they affect LCSWs.

Inter-state Telemental Health Practice – There continue to be variation in state rules that allow LCSWs in one state to see patients in another state through telemental health. This is especially difficult for ongoing patients who were seeing a patient in office from a state in which the LCSW was not licensed. I hope this chaos will resolve soon, but for now check on current laws and rules for practicing telemental health in states where you are not licensed with the state Board.

Self-Care – Please know that telemental health is more tiring for many LCSWs than office work and build in ways to give yourself more down time, whether it is through seeing fewer clients in a day; having longer breaks between clients; and having some time for relaxation, exercise, and other self-care.

Many of us have been paying for an office the past five months that we only use for billing or our own research. More and more requests to sublease offices are showing up. This painful decision is affecting all of us. The webinar given last month “To Be or Not To Be: LCSWs Returning to the Office” offers a template for helping make this decision and can be found at the CSWA website in the Members Only Section.

Be safe, stay well, and let CSWA know if there is any way we can help.