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CSWA ALERTS

CSWA is proud to vigilantly monitor issues within the field of clinical social work, and national legislation that affects clinical social workers. Please see below for a history of those announcements and legislative alerts. To receive timely information directly to your inbox, join CSWA today

  • December 26, 2024 12:04 PM | Anonymous member (Administrator)


    January 25, 2020

    I have been hearing from members who have had trouble communicating with Noridian, the Medicare Administrator for much of western United States. This post is to gather information about how widespread this problem is.

    Please let me know the following if you have had any of the following difficulties in the past three months:

    1. Mistakes on EOBs which cannot be corrected

    2. Inability to get a person to talk to about EOBs or other problems

    3. Wait times of more than 20 minutes

    4. Being disconnected while on hold

    Please respond by February 2. Thanks for your help. Once I have more data I will contact CMS about the problem.

  • December 26, 2024 12:03 PM | Anonymous member (Administrator)


    December 28, 2019

    I want to call your attention to a terrific article called 'The War for the Future of Psychotherapy". on the conflict in psychotherapy regarding manualized algorithms as the basis for treatment and the treatment alliance as the basis for treatment. The article is by Todd Essig, PhD, a psychologist/psychoanalyst, who writes a column in Forbes Magazine and can be found here

    This is not a new battle between short term and in-depth treatment but according to the article, there is new support for using algorithms to guide treatment from the American Psychological Association Guidelines.

    CSWA has members who provide all methods and lengths of treatment but the human connection is seen as primary, not one-size-fits-all research. I urge all members to read the article and send me your thoughts, which I will share with other members.

    This article came out of the Psychotherapy Action Network (PsiAN) Conference which was held in San Francisco the past month. Full disclosure: I spoke at the conference on clinical social work education in schools of social work (diminishing) and psychotherapy advocacy (time-consuming). Let me know if you want information about those topics. It was heartening to see the many LCSWs in the audience.

    Here's to a happy productive new year for clinical social workers.

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

  • December 26, 2024 12:01 PM | Anonymous member (Administrator)


    December 11, 2019

    MHLG 2019 Hill Staff Champion Awards, given to the members of Congress for their outstanding support of the goals of the Mental Health Liaison Group. These legislative aides are identified below. Peeking out of the second row is our own Margot Aronson, LICSW, CSWA Deputy Director of Policy and Practice.

    • Joseph Ciccone, Office of Representative Grace F. Napolitano
    • Jennifer Tyler, Office of Representative John Katko
    • Jeff Morgan, Office of Representative Paul Tonko


  • December 26, 2024 11:57 AM | Anonymous member (Administrator)


    October 1, 2019

    The American Foundation for Suicide Prevention and the Suicide Prevention Resource Center have put together some excellent materials which may be helpful to members.

    Here is a general overview of the scope of suicide, costs, vulnerable populations and more. The link is http://www.sprc.org/about-suicide.

    Here is a summary of the guidelines which states use to prevent suicide. The link is http://www.sprc.org/stateInfrastructure/tools.

    Here is a summary of the number of suicides that occur each year by state and the ranking per capita of the states. The link is https://afsp.org/about-suicide/state-fact-sheets/.

  • December 26, 2024 11:56 AM | Anonymous member (Administrator)


    November 20, 2019

    This post is to let you know that clinical social workers will not be required to report on the Merit-Based Incentive Payment System (MIPS) in 2020. CSWA has checked with the Centers for Medicare and Medicaid Services (CMS) to verify this. There will be no penalties and no bonuses for LCSWs through MIPS in 2020.

    MIPS is the successor to the PQRS program that ended in 2016, which was cumbersome and did not always provide correct results in the penalties assessed to the LCSWs that complied with it.

    Here is the rule about clinical social workers in 2020:

    Are clinical social workers eligible for MIPS? Why is there a clinical social worker specialty measure set?

    No. Clinical social workers continue to be excluded from MIPS in the 2020 performance period. However, we have finalized a clinical social worker measure set to help these clinicians prepare in the event that they are added to the definition of a MIPS eligible clinician through future rule making.

    To review the whole final rule, click here.

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

  • December 26, 2024 11:51 AM | Anonymous member (Administrator)


    September 24, 2019

    Below is updated information on the CMS Proposed Rules changes.

    At this point, the 800 pages of Proposed Rules for LCSWs are mainly about our being included in the Merit-based Incentive Payment System (MIPS), the successor to PQRS. CMS has asked CSWA for recommendations on the measures which we can logically keep records on. The CSWA-recommended 16 measures are included in the attached document.

    We also encourage you as individual members – whether or not you are Medicare providers - to send comments to CMS about these proposed rules. A strong showing from the LCSW community can make a difference. Remember, these proposed rules are not about reimbursement rates, just the inclusion of LCSWs as Medicare providers in the MIPS system. If you believe LCSWs should not be included in MIPS or that inclusion would affect your willingness to be a Medicare provider, feel free to say so.

    Suggested language:

    Re: Proposed rules CMS-1715-P

    I am a licensed clinical social worker and a member of the Clinical Social Work Association. I am hoping that the reporting requirements will be simpler and clearer than the ones that were required for PQRS, and more carefully monitored. [Or, I oppose the inclusion of LCSWs in the MIPS system.] Many LCSWs [I was, if you were] had their reporting rejected although it was in compliance with the PQRS measures. Many LCSWs [I decided, if you did] decided not to remain part of the Medicare provider network because of these onerous reporting requirements. Such requirements seem particularly unfair given the reimbursement rate for LCSWs at 25% less than for others providing the exact same services.

    How to submit comments:

    Your comments should be submitted to https://www.regulations.gov/document?D=CMS-2019-0111-0092. Click on the “Comment Now” box on the right side to submit your comment. All comments must be submitted by Friday, September 27, 2019, 5 pm EDT.

    Comments sent by CSWA:

    If you would like to read the more extensive comments sent by CSWA, you can find them at CSWA - CMS Comments on Medicare Proposed Rules (Final) - 9-24-19.pdf. CSWA will keep members apprised of the final decision on these proposed rules.

    ============================================================

    September 20, 2019

    I have received several messages from you about the new CMS proposed rule to lower the Medicare reimbursement for psychologist services.

    It appears from the proposal (found in the Federal Register at https://www.govinfo.gov/content/pkg/FR-2019-08-14/pdf/2019-16041.pdf) that the reduction for psychologists is a higher reduction than for clinical social workers , i.e., 7% vs. 6%.

    The proposed rule also asks for recommendations for measures that could be used to include LCSWs in MIPS, the new PQRS, in 2022.

    We are in contact with NASW and hoping to submit joint comments on this proposed rule.

    CSWA will be responding to all of these proposals shortly and asking members to do so as well. You can start reviewing the extensive rule now. Comments must be in by September 27, 2019.

    CSWA will have our comments by early next week for your consideration.

    Let me know if you have any questions.

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

  • December 26, 2024 11:48 AM | Anonymous member (Administrator)


    September 24, 2019

    Centers for Medicare and Medicaid Services, Director Seema Verma, http://www.regulations.gov

    RE: CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies, CMS–1715–P

    Dear Director Verma:

    The Clinical Social Work Association (CSWA) is happy to provide these comments on the proposed Medicare rules for 2020. There are over 250,000 licensed clinical social workers (LCSWs) in the country, the largest group of behavioral health providers. We are proud to be able to participate in the Medicare program and serve the mental health needs of beneficiaries.

    As we understand the proposed rules for LCSWs, they are similar to the Physician Quality Record Systems (PQRS) which were in place from 2010-2017 for LCSWs. When the Merit-based Incentive Payment System (MIPS) was created in 2018, LCSWs were not asked to report on the measures that were part of that system. The proposed rule, CMS-1715-P, is specifically considering that clinical social workers now be included in the MIPS reporting. The PQRS rule had many difficulties for LCSWs with denied reporting and we hope that if the MIPS measures are applied to LCSWs that the processing of the reporting will be improved.

    CSWA understands that the Medicare Economic Index (MEI) is subject to change, and is hopeful that the proposed 6% decrease in overall RVUs for LCSWs may change as well. As has long been the case, we have concerns about the way that LCSWs, who use the same behavioral health codes as psychologists and psychologists for psychotherapy, have nonetheless been reimbursed at 25% less than the other two groups. We know this will take legislative change. This disparity continues to be patently unfair; groups doing the same work using the same codes should not have different reimbursement rates. CSWA encourages our members to become Medicare providers and serve this vulnerable population. However, decreasing reimbursement rates and increasing the paperwork burden could lead to fewer LCSWs choosing to do so.

    As requested on p. 460, CSWA would like to offer the following comments on the Clinical Social Work specialty set, in the event clinical social workers are proposed for inclusion in the definition of a MIPS eligible clinician in future rulemaking. Measures which CSWA finds would fit with the clinical social work scope of practice are marked “ACCEPTED”. Measures which are not included, but recommended by CSWA, are marked “PROPOSED”.

    B.41 Clinical Social Work (p.664)

    Measures in MIPS

    #130, Medications for every patient listed in the Medical Record in each session ACCEPTED

    #134, Depression Screening, once a year, followup treatment plan if positive screening ACCEPTED

    #181, Elder Maltreatment Screening, once a year, with followup treatment plan if positive screening ACCEPTED

    #182, Functional Outcomes Assessment, as needed, followup treatment plan if positive screening ACCEPTED

    #226, Tobacco Cessation, once every two years or sooner if positive screening ACCEPTED

    #281, Dementia Cognitive Assessment, once a year regardless of age, followup treatment if positive screening ACCEPTED

    #283, Dementia Psychiatric Screening, once a year if positive cognitive assessment for dementia, for behavioral/psychiatric disorders, followup treatment if positive screening ACCEPTED

    #286, Dementia Physical Safety Screening, as needed if danger to self or others because of physical limitations, followup treatment if positive screening ACCEPTED

    #370, Adolescent Depression Remission Percentage at 12 months for 12-17 year old patients who have a positive screening for depression ACCEPTED

    #382, Assessment of Suicide Risk for children/adolescents who have diagnosed suicidality with followup plan for continued suicidality ACCEPTED

    #383, Assessment of adherence to anti-psychotic medication as needed for patients who have a diagnosis of schizophrenia or schizoaffective disorder and followup plan if positive screening for non-adherence ACCEPTED

    #402, Assessment of tobacco cessation for adolescents 12-20 as needed with followup plan if cessation not achieved ACCEPTED

    #431, Assessment of Unhealthy Alcohol Use for adults every two years with followup plan for cessation if not achieved ACCEPTED

    PROPOSED: Assessment of Unhealthy Alcohol Use for adolescents 12-20 every year if cessation not achieved

    PROPOSED: Assessment of Unhealthy Drug Use for adults every two years with followup plan for cessation if not achieved

    PROPOSED: Assessment of Unhealthy Drug Use for adolescents every two years with followup plan for cessation if not achieved

    Thank you again for the opportunity to offer our comments to CMS on these proposed rules. We are happy to discuss them with you further.

    Sincerely,

    Britni Brown, LCSW, President, Clinical Social Work Association, bbrown@clinicalsocialworkassociation.org

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

    cc:

    Margot Aronson, LICSW, Deputy Director of Policy and Practice, Clinical Social Work Association, maronson@clinicalsocialworkassociation.org

    Donna Dietz, CSWA Administrator, Clinical Social Work Association, administrator@clinicalsocialworkassociation.org

  • December 26, 2024 11:46 AM | Anonymous member (Administrator)


    September 20, 2019

    I have received several messages from you about the new CMS proposed rule to lower the Medicare reimbursement for psychologist services.

    It appears from the proposal (found in the Federal Register at https://www.govinfo.gov/content/pkg/FR-2019-08-14/pdf/2019-16041.pdf) that the deduction for psychologists is a higher deduction than for clinical social workers , i.e., 7% vs. 6%. In one area, E/M services, we are now included, and have a small increase of 1%compared to psychologists who have a small decrease of 1%. This is one of the first times that there have been separate recommendations for psychologists and LCSWs, small though they may be.

    The proposed rule also asks for recommendations for measures that could be used to include LCSWs in MIPS, the new PQRS, in 2022.

    We are in contact with NASW and hoping to submit joint comments on this proposed rule.

    CSWA will be responding to all of these proposals shortly and asking members to do so as well. You can start reviewing the extensive rule now. Comments must be in by September 27, 2019.

    CSWA will have our comments by early next week for your consideration.

    Let me know if you have any questions.

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

  • December 26, 2024 11:45 AM | Anonymous member (Administrator)


    August 15, 2019

    The Clinical Social Work Association strongly opposes the DHHS proposed Section 1557 rule change. This revision would open the door to discrimination by healthcare providers and by insurers offering Marketplace plans. Discrimination and denying access to health care in our public health care system is unethical and harmful.

    Ethical Treatment vs Prejudice

    CSWA represents many of the 250,000 Licensed Clinical Social Workers (LCSWs) who provide mental health diagnosis, treatment, and other health related services through in the public and private sectors. We adhere to a code of ethics that prohibits discrimination; indeed, a social worker would never turn away someone seeking health or mental health care. It is self-evident that all health professions practice within codes of ethics that prohibit discrimination and do no harm.

    The DHHS proposed changes are in stark contrast to ethical practice. Currently, Section 1557 regulations standardize the protections and processes that prohibit discrimination in health care for all vulnerable populations. Further, current regulations recognize that intersectional discrimination can affect people who belong to multiple protected classes; for example, discrimination against an African-American woman could be based on race, sex, or both. While DHHS maintains that it “is committed to ensuring the civil rights of all individuals who access or seek to access health programs or activities of covered entities,” the proposed changes, if finalized, would substantially scale back current protections against discriminatory practices, and create a climate friendly toward providers inclined to deny care based on stereotyping and generalized prejudice.

    Proposed Changes for Insurance Carriers

    With regard to changes for insurance carriers, CSWA notes with dismay that the DHHS proposal would provide leeway for insurers to shape benefit designs with potential to disadvantaged vulnerable groups often targeted for discrimination by race, color, national origin, sex, age, and/or disability. While these rules would only apply to Marketplace plans, the change would have significant impact on the lives of the 20 million people covered by these plans and could be adopted by private plans.

    It is also of significant concern to CSWA that DHHS also wants to eliminate basic consumer protections by ending grievance procedure requirements and restricting the right to challenge violations of the right to access care in court.

    Disability Discrimination

    As to the question of relaxing protections currently provided to individuals with disabilities, we cannot see how the proposed exemptions are justified. Surely an increase in the “undue hardship” exemptions for federally covered entities would seriously curtail access to healthcare for individuals who in their daily lives already face undue hardships due to their disabling conditions.

    Recommendation

    CSWA urges that DHHS keep Section 1557 in place and protect the rights of vulnerable and/or disabled enrollees to health care through the Marketplace plans. To open the door for healthcare providers to refuse to provide healthcare services to certain groups and for insurers to develop policies that disadvantage such groups is unethical and would destroy civil and disability rights protections to specific patient populations.

    Thank you for this opportunity to provide input on the DHHS proposal to change non-discrimination regulations under ACA Section 1557. We are available to respond to any questions. Please contact us.

  • December 26, 2024 11:41 AM | Anonymous member (Administrator)


    June 26, 2019

    Though I have not been sending the voluminous posts that I was sending last summer, the issue of immigrant children who are separated from their families, given inadequate housing, and denied basic care is one that CSWA is carefully tracking. Here is some information that will keep you up to date and provide options on how to stop these injustices. There are currently between 1000 and 3000 immigrant children in the US separated from their parents; some older (8 and up) children are being forced to care for younger children.

    Summary of Harm – this article is a good summary of the current issues: https://time.com/5613435/government-moves-migrant-kids-border-inadequate-shelter/

    Agencies for Immigrant Children –Here are some good agencies that are working to improve the conditions of immigrant children and reunite them with their families:

    Kids in Need of Defense (KIND) works to ensure that no child appears in immigration court alone without representation.

    Women’s Refugee Commission offers Resources for Families Facing Deportation and Separation in English and Spanish.

    Young Center for Immigrant Children’s Rights advocates for the safety and well-being of unaccompanied kids arriving in the United States. They recently announced a project specifically dedicated to helping children separated from their parents at the border.

    Donations to Help – here is one of many organizations that are using donations to help immigrant children: https://secure.actblue.com/donate/borderfamilies2019?refcode=20190624esborderd&link_id=0&can_id=1dd38bb56c3bb701463ff79392bbbcf5&source=email-this-is-not-immigration-policy-it-is-inhumane-and-cruel&email_referrer=email_569843&email_subject=this-is-not-immigration-policy-it-is-inhumane-and-cruel

    Let me know if you have any questions.

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

PO Box 105
Granville, Ohio  43023

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