April 3, 2020

Below is an update on several issues related to our transition to telemental health services.

1. Zoom – There have been concerns raised about the security of the Zoom platform and Zoom is taking steps to address these issues. A more secure system will be in place by April 5 for the ZoomPro and other platforms Zoom offers. Here is a summary of what will be happening:

Zoom

We’re always striving to deliver you a secure virtual meeting environment. Starting April 5th, we’ve chosen to enable passwords on your meetings and turn on Waiting Rooms by default as additional security enhancements to protect your privacy.

Meeting Passwords Enabled “On”

Going forward, your previously scheduled meetings (including those scheduled via your Personal Meeting ID) will have passwords enabled. If your attendees are joining via a meeting link, there will be no change to their joining experience. For attendees who join meetings by manually entering a Meeting ID, they will need to enter a password to access the meeting.

For attendees joining manually, we highly recommend re-sharing the updated meeting invitation before your workweek begins. Here’s how you can do that:

Log in to your account, visit your Meetings tab, select your upcoming meeting by name, and copy the new meeting invitation to share with your attendees. For step-by-step instructions, please watch this 2-minute video or read this FAQ.

For meetings scheduled moving forward, the meeting password can be found in the invitation. For instant meetings, the password will be displayed in the Zoom client. The password can also be found in the meeting join URL.

Virtual Waiting Room Turned on by Default

Going forward, the virtual waiting room feature will be automatically turned on by default. The Waiting Room is just like it sounds: It’s a virtual staging area that prevents people from joining a meeting until the host is ready.

How do I admit participants into my meeting?

It’s simple. As the host, once you’ve joined, you’ll begin to see the number of participants in your waiting room within the Manage Participants icon. Select Manage Participants to view the full list of participants , then, you’ll have the option to admit individually by selecting the blue Admit button or all at once with the Admit All option on the top right-hand side of your screen. 

Check out these resources to learn How to Manage Your Waiting Room and Secure Your Meetings with Virtual Waiting Rooms (links no longer available).
Please reach out to our Support Team if you have any questions at support@zoom.us.Medicare Issue

Medicare has made several changes in the past few days, revising some previous guidance. Below are some of the most important changes. To see the latest guidance, go to https://www.cms.gov/newsroom/fact-sheets/additional-backgroundsweeping-regulatory-changes-help-us-healthcare-system-address-covid-19-patient.

2. Medicare Coding – the Medicare coding for psychotherapy continues to be in flux. Here is Guidance which came out today saying we should now use the POS we would have used had the service been provided in person, e.g., “11” for in-office psychotherapy, and the modifier “95”:

Billing for Professional Telehealth Distant Site Services During the Public Health Emergency — Revised (4/3/20)

This corrects a prior message that appeared in our March 31, 2020 Special Edition.

Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with:

As a reminder, CMS is not requiring the CR modifier on telehealth services. However, consistent with current rules for telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:

There are no billing changes for institutional claims; critical access hospital method II claims should continue to bill with modifier GT.

3. Medicare Reimbursement – this is the area that has seen the most confusion; previous guidance had stated that reimbursement would be the same for telemental health as in-person treatment. So far, there have been payments made for telemental health that are 7-8% lower than previous reimbursement, some that have remained the same This seems to vary by region. Contact your MAC to discuss if you have received a payment that is not consistent with previous reimbursement.

4. Medicare Provider Enrollment - CMS is making it easier for providers to enroll in Medicare. Local private practice clinicians and their trained staff may be available for temporary employment since nonessential planned medical and surgical services are postponed during the pandemic.

5. Telephonic Coverage – this is the area that has caused the most confusion based on the March 30 guidance: “Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. During the public health emergencies, individuals can use interactive apps with audio and video capabilities to visit with their clinician for an even broader range of services. Providers also can evaluate beneficiaries who have audio phones only.” The problem with this statement for LCSWs is that there is only one service that is expanded for psychotherapy, e.g., the E/M 10 minute evaluation, NOT psychotherapy sessions. CSWA is still working hard to get coverage of telephonic sessions by Medicare. At present, they are not covered. Continue to let your members of Congress know that this is a problem as noted below.

CSWA will continue to provide information on regulatory changes to members that affect LCSW practices which will likely be continuing for the next month.

Please let me know if you have any other questions.

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

March 31, 2020

Things are changing rapidly to give people better access to mental health services. Here is some more information that affects LCSWs.

First, a correction. Maryland has not required coverage of telephonic sessions; Gov. Hogan was one of the first states to allow emergency reciprocity for LCSWs not licensed in Maryland. Apologies for the error.

Along these lines, many states have followed his example and are now allowing LCSWs to practice in states where they are not licensed, as long as they are licensed in at least one state. There are many variations so make sure to read the emergency declarations carefully. The list helpfully created by Shrink Space can be found at https://theshrinkspace.blog/covid-19-teletherapy-across-state-lines/. It is being updated daily.

Finally, sending a message like the one below to the President would be a good idea. You can send it to www.WhiteHouse.gov.

I will be sending more information as it comes in. Let me know about any changes to practice in your state/jurisdiction.

“I am a constituent and a member of the Clinical Social Work Association. I have patients who are unable to meet with me in person for psychotherapy because of the COVID-19 crisis and do not have access to a smart phone or computer. The Centers for Medicare and Medicaid Services have not expanded coverage of psychotherapy to telephonic sessions, only videoconferencing; however, the only way I can provide services to these beneficiaries is by telephone.

Some enlightened insurers like Cigna and Aetna have already allowed some temporary coverage of telephonic psychotherapy sessions. Some states such as Texas, and Ohio have also required temporary coverage of telephonic psychotherapy sessions by private insurers.

Please tell CMS [and/or private insurers for state legislators and Insurance Commissioners] to approve coverage of telephonic psychotherapy sessions, sorely needed in these fraught times, for Medicare beneficiaries [and other enrollees privately insured] who may be isolated, emotionally fragile, and in need of mental health services."

March 30, 2020

It was a pleasure to ‘meet’ with many of you virtually this weekend about the changes to our practices in the time of COVID-19 which has restricted our in-office practices. I hope the discussions about how to move to telemental health, the confusion regarding coverage by insurers and how to code for our services, and many other issues were helpful to you.

One of the topics we talked about was advocacy to get Medicare – as well as private insurers – to cover telephonic sessions. To accomplish this goal we will need an all-out effort, not just to CMS and HHS, but to members of Congress, state legislators, and state Insurance Commissioners. Use your own words to convey the following message:

“I am a constituent and a member of the Clinical Social Work Association. I have patients who are unable to meet with me in person for psychotherapy because of the COVID-19 crisis and do not have access to a smart phone or computer. The Centers for Medicare and Medicaid Services have not expanded coverage of psychotherapy to telephonic sessions, only videoconferencing; however, the only way I can provide services to these beneficiaries is by telephone.

Some enlightened insurers like Cigna and Aetna have already allowed temporary coverage of telephonic psychotherapy sessions. Some states such as Maryland, Texas, and Ohio have also required temporary coverage of telephonic psychotherapy sessions by private insurers.

Please tell CMS [and/or private insurers for state legislators and Insurance Commissioners] to approve coverage of telephonic psychotherapy sessions, sorely needed in these fraught times, for Medicare beneficiaries [and other enrollees privately insured] who may be isolated, emotionally fragile, and in need of mental health services."

You can find contact information for members of Congress at https://www.house.gov/representatives and https://www.senate.gov/general/contact_information/senators_cfm.cfm. You can find email addresses for your state legislators and Insurance Commissioners by going to your state websites.

Finally, send a letter to CMS Administrator Seema Verma and HHS Secretary Alex Azar at the addresses below:

The Honorable Seema Verma, Secretary Administrator, U.S. Department of Health & Human Services Centers for Medicare & Medicaid Services, 200 Independence Avenue, S.W. 200 Independence Avenue, S.W., Washington, D.C. 20201 Washington, D.C. 20201

The Honorable Alex Azar, Secretary, U.S. Department of Health & Human Services, 200 Independence Avenue, S.W. 200 Independence Avenue, S.W., Washington, D.C. 20201

This is a lot of work, but we need to help the millions of patients who have lost their ability to get psychotherapy because they cannot get coverage for telephone sessions.

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

Stay healthy and let me know if you have any other questions.

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

March 27, 2020

The complete change to our personal and professional lives in the past two weeks as the result of the COVID-19 pandemic has been overwhelming. It has led to feelings of helplessness about how to do our jobs as clinical social workers that many of us have not had to face for decades.

CSWA has tried to outline the changes that most private practitioners are facing and ways to adjust our practices. Once we get past the shock of feeling disoriented, the shift to telemental health that we need to make for at least the next 2-3 months are manageable. Below is a brief summary of the areas that should be considered. The complete hour-long webinar can be found under the Members-only area of the CSWA website.

Practice Considerations:

CSWA is offering more guidance on the changes created by this pandemic. There will be two Open Webinars to discuss the questions LCSWs have and provide mutual support on March 28 and 29 (see Upcoming Events at CSWA website). There will be a two-hour conference on more detailed discussion of how to provide telemental health. We want to be your partner in this time of flux and transition.

March 22, 2020

A bill for Phase 3 Emergency Relief of COVID-19 is due to be passed TODAY.

Unfortunately, it does not include the needed coverage of telephonic sessions through Medicare.

Please send the following message to your members of Congress: "I am a member of the Clinical Social Work Association and a constituent. I have patients who are unable to meet with me for psychotherapy because of the COVID-19 crisis and do not have access to a smart phone or computer. The only way I can provide services to them is by telephone. Please approve coverage of telephonic psychotherapy sessions, sorely needed in these fraught times."

You can find contact information at https://www.house.gov/representatives and https://www.senate.gov/general/contact_information/senators_cfm.cfm.

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

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

March 17, 2020

I spoke this morning with Karyn Anderson, CMS Technical Director as she was about to develop this guidance from CMS on telemental health services. She was quite receptive to our concerns.

I am happy to report that CMS has approved an expansion of Medicare telemental health to cover anyone we see, new patients or ongoing ones. Unfortunately, it does not include telephonic sessions. CSWA will keep working to get them included as well. To see the FAQ on all the changes included see 3.17.20 COVID 19 Telehealth Waiver FAQ Final.pdf.

Please read this carefully and let me know if you have any questions.

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

March 16, 2024

There have been many questions about how to establish a telemental health practice as we address COVID-19. Here are some ideas about what to consider.

• Take a course to understand the basic skills that are needed to provide telemental health videoconferencing. The TBHI Courses offered by Marlene Maheu are excellent and can be found here. There are many others, but Dr. Maheu has based hers in part on the ethical standards for clinical social workers.
• Read the Technology in Social Work Standards, that CSWA helped develop, which can be found here.
• Find a platform to use for your videoconferencing work. There are several available but the ones that seem to be the best are VSee, Zoom, doxy.me (which has some service problems from recent reports), Simple Practice and Theranest. Most have a monthly charge. Some are more reliable than others. To see comparisons of the platforms, go to Rob Reinhardt’s website www.tameyourpractice.com.
• Find a payment method for videoconferencing. The ones that seem to be the best are Zelle and Paypal. Zelle is bank related and have privacy protections; you will need to get the patient’s bank account number. I believe Paypal will sign a BAA.
• Develop an Informed Consent form for videoconferencing. CSWA has developed a template which can be found at CSWA - Telemental Health Informed Consent - 3-20.docx.
• Check with all third party payers as to whether your patients will be covered for videoconferencing or telephonic sessions. Medicare patients await guidance from CMS and HHS which should be forthcoming in the next two weeks. If patients are not covered, see if arrangements for private pay can be made.

If you have any other questions, please let me know.

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

March 15, 2020

There have been many questions about the status of the telemental health expansion of Medicare and private insurers as the COVID-19 crisis itself has rapidly expanded. Here is what CSWA knows so far.

The emergency bill signed on March 6 allows for an expansion of Medicare telehealth services of all kinds, once guidance from CMS and HHS is made available. There is no definite date when this will happen, but we hope to have it within two weeks.

CSWA, NASW, and the American Psychological Association will be sending a letter to CMS and HHS tomorrow encouraging them to allow a temporary expansion for patients that we have been seeing within the past three years. The option that is currently being discussed per the March 6 bill is videoconferencing only, not telephonic sessions. Of course CSWA hopes that telephone sessions will be allowed as well, but it is unlikely that it will be as soon as videoconferencing is covered. It is a possibility that when videoconferencing is expanded by CMS, it will be retroactive to February, 2020.

As for private insurers, there is confusion about what they are willing to cover through videoconferencing and telephonically at this time. Most companies that offer coverage are doing it for in-network providers only, who must use a specific telemental health platform and accept the fee offered. This is generally less than LCSWs are used to being paid by these insurers for in-person sessions. Out-of-network providers may or may not have the option of being covered for videoconferencing or telephonic sessions. It is VERY important to check with any private insurers you have been reimbursed by, if you want to know the facts about their policies at this time. Having patients call to find out what their policies are and request videoconferencing and/or telephonic coverage if necessary, is a good idea as well.

Another question is coverage for patients who live in a jurisdiction in which you are not licensed, for example, a patient has previously come to your office in Washington, DC, but lives in Maryland. You are licensed in Washington, DC, not Maryland, so would be practicing without a ;license if you treat the patient through videoconferencing while they are in Maryland. I recommend calling the Social Work Board in any state in which a patient resides in which you are not licensed, to ask what their policy is on videoconferencing with patients (or telephonic sessions) who reside there. Again, there may not be good solutions here if the state insists that you be licensed in the state in which the patient resides. Have patients call the Social Work Board in their state and ask for an exemption.

Finally, there is the question of what to do if you have already moved to videoconferencing or telephonic sessions to protect you and your patients from becoming infected by COVID-19; it is problematic if you want to continue getting reimbursed by third party payers who currently do not cover videoconferencing. You can continue to provide sessions through videoconferencing with the hope that they will be covered eventually; take a break while this is sorted out; or make arrangements with patients to pay privately. None are ideal.

I hope we will have some clarity on telemental health expansion soon and will keep you posted. This is a unique and troubling time for LCSWs, all mental health professionals, and our patients. CSWA will do everything possible to give us the ability to continue providing our needed services.

March 10, 2020

On Friday, the President signed into law a $8 billion emergency funding bill that included $500 million towards Medicare telehealth, including telemental health services, because this is a declared emergency. There are a few caveats (see below).

The good news: this bill allows the HHS Secretary to waive current Medicare telehealth restrictions (originating/geographic sites) on telemental health during the COVID-19 public health emergency, so that care can be provided regardless of where a patient is located, including at home.

The other news: a qualifying provider, like licensed clinical social workers, needs to have provided a service to an eligible beneficiary in the last three years—so this can only be applied to existing, or recent, patients. Additionally, the telemental health services can only be provided through videoconferencing, not telephone only.

Place of service should be 02 for telehealth. The GT modifier is no longer necessary, but 95 is still needed. CPT codes should be as for an office visit.

This is overall good news and CSWA will work to make it a permanent option.

March 9, 2020

I just received guidance from CMS on whether we can be reimbursed for telemental health beyond the accepted treatment in rural areas. Their response is attached.

Basically the answer is no at this time. I recommend calling CMS at1-866-288-8912, x3 to ask for more guidance.

CSWA is developing a Legislative Alert to send to members of Congress to request an expansion of coverage for telemental health during this health crisis.

CSWA - Medicare on Distance Sessions - 3-9-20.docx