December 4, 2023

The final rule for the Medicare Physician Fee Schedule (PFS) in 2024 has been issued and will go into effect on January 1, 2024. The link to the complete summary can be found by visiting https://www.cms.gov/files/document/mm13452-medicare-physician-fee-schedule-final-rule-summary-cy-2024.pdf. 

Please find a list of the changes that will affect clinical social workers below.

Physician Fee Schedule Changes

New codes:

Telemental Health Services:

Expansion of Behavioral Health Services:

Expansion of Crisis Codes:

New Codes for LCSWs:

Change to Relative Value Units (RVUs) for LCSWs:

Please let me know if you have any questions.

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

December 24, 2023

Licensed Clinical Social Workers (LCSWs) are the largest group of licensed mental health clinicians in the country, working in the public and private sector, providing psychotherapy and counseling on an individual, family and group basis in every state and jurisdiction. The acronyms below are the titles used in each state/ jurisdiction to designate independent clinical social work practice in that state. Here is a list of the number of LCSWs in each state with the exact title used in that state. This data was collected from state social work Boards and administrators in November, 2023. All LCSWs have requirements of two-three years post-graduate supervised experience and have taken a national exam. Most LCSWs are licensed to diagnose all mental health disorders in the Diagnostic and Statistical Manual-5-TR and future editions and to treat these disorders through psychotherapy when appropriate.

November 15, 2023

The recent communication about Medicare Advantage led to several questions. Please see answers below:

Will Medicare Advantage reimburse traditional Medicare paneled LCSWs? Since Medicare Advantage is a separate program from traditional Medicare, it does not reimburse claims for traditional Medicare.

Why does Medicare Advantage often pay less than traditional Medicare? Because Medicare Advantage plans are run by commercial insurers, some reimburse at less than traditional Medicare and some at a higher rate. Remember that traditional Medicare rates vary from region to region as well.

Should LCSWs accept Medicare Advantage, even if rates are lower, because it is all that some people can afford? Some people think of Medicare Advantage as a midway point between Medicare and Medicaid and want to accept these plans to offer services to lower income patients.

How can we make Medicare Advantage have reimbursement parity with traditional Medicare? Medicare Advantage is a completely different system from traditional Medicare with different reimbursement. Medicare Advantage reimbursement has reimbursement governed by commercial insurers; traditional Medicare has reimbursement governed by CMS. While CSWA has advocated for reimbursement parity in traditional Medicare (with medical/surgical reimbursement) and in commercial plans (with medical/surgical), there is no way to create parity between Medicare Advantage and traditional Medicare.

How can we improve access to mental health treatment in general? There is no one way to accomplish this but the new mental health parity rules and integration of primary care and mental health should help.

Do LCSWs have to be credentialed with Medicare to be eligible for Medicare Advantage? No. The reverse is true as well, i.e., LCSWs can be credentialed with Medicare without accepting Medicare Advantage patients.

Do LCSWs have to be credentialed with the commercial insurer sponsoring the Medicare Advantage plan? This varies, but in general it is not necessary to be credentialed with a commercial insurer to be reimbursed for a Medicare Advantage plan. Check with each plan.

How much will Medicare Advantage plans affect Medicare beneficiaries going forward? Many analysts have said that the Medicare Advantage plans will continue to grow to cover 50-60% of Medicare beneficiaries by 2030.

Please continue to send questions on Medicare Advantage as they occur.

- Laura Groshong, LICSW, Director of Policy and Practice

November 13, 2023

WHAT IS MEDICARE ADVANTAGE?

Medicare Advantage (MA) plans have been heavily marketed for the past year or so. LCSWs have had many questions about what the difference is between MA plans and traditional Medicare. This summary of those differences may be helpful in understanding what mental health coverage patients have in these plans and how MA plans may affect coverage overall.

MA plans, known as Part C plans, are overseen by commercial insurers, i.e., United, Aetna, Cigna, BCBS, etc. The general goal of these plans is to improve profits; this is not different from the other plans that commercial insurers offer. Traditional Medicare, a public plan with Federal oversight, has an interest in keeping costs down balanced with an interest in giving the elderly and disabled reasonable health care.

Some Medicare Advantage plans inappropriately delay and deny critical care; have low premiums but then charge exorbitant copays that prevent people from getting care; have limited networks and few providers available; and may have networks with poor quality providers. Additionally, MA plans do not have the Medigap component that traditional Medicare offers to cover the “gap” that Medicare does not allow for certain conditions, including mental health treatment.

There is little doubt that the for-profit MA plans will put the needs of their shareholders first. Most Medicare-eligible beneficiaries are drawn to the low premiums and do not read the fine print about the limitations of MA plans. This may happen when there is a health crisis and the limitations on what care is covered by which paneled clinicians becomes suddenly clear.

According to the Psychotherapy Action Network, “Medicare Advantage (Part C) plans have been demonstrably disadvantageous to people who are sicker. If you have Part C and wait until you are sick to shift over to a Traditional Medicare plan, you may not be able to get a Medigap policy to cover copays and coinsurance, or that premium may be much higher.”

How do the MA plans affect mental health treatment coverage? For acute or short-term treatment, the lower premiums may be an advantage. The advantage will disappear in an MA plan if a beneficiary needs long-term psychotherapy. The cost of copays may be so high that the total cost of treatment may be much more expensive. Further, beneficiaries cannot purchase a Medigap policy (which covers co-pays) if MA is their primary insurance.

There are many articles on what can be done to prevent the “bait-and-switch” approach of MA plans, from lawsuits against commercial insurers to advocating for a single payer health care plan. For now, the best option in the view of CSWA, is to think carefully about the pros and cons of MA plans and traditional Medicare before choosing MA plans. Please contact me if you have any other questions about MA plans.

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

September 26, 2023

Please take a moment to submit a comment on the proposed rule to make the Mental Health Parity and Addiction Equity Act more enforceable. You may use the template below or write your own. Comments are due on October 2, 2023.

To read the document visit https://www.regulations.gov/document/EBSA-2023-0010-0001.

To submit a comment visit https://www.regulations.gov/commenton/EBSA-2023-0010-0001.

Template:

Subject: Re: 0938-AU93 1210-AC11 1545-BQ29 Requirements Related to the Mental Health Parity and Addiction Equity Act

Dear Secretary Becerra, Assistant Secretary Gomez, and Deputy Commissioner O’Donnell;

Thank you for the opportunity to comment on the Requirements Related to the Mental Health Parity and Addiction Equity Act (MHPAEA) proposed rule. I write as a licensed clinical social worker who has noticed increased difficulty for patients to find coverage for mental health and substance use (MH/SUD) treatment.

It is quite unfair that mental health and substance use treatment is still not covered at parity with medical/surgical care after the initial rules for the 2008 MHPAEA were delayed until 2014 and are still not covered at parity almost 10 years later.

Please finalize the following specific proposals WITHOUT EXCEPTION:

We urge the Departments to consider penalties when plans ignore these consequences.

Please make these changes to eliminate barriers to care and ensure that everyone has the same access to mental health and substance use benefits as they do physical health benefits.

Thank you again for the opportunity to comment.

As always, let me know when you have submitted your comments.

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

August 10, 2023

Please visit https://jswve.org/volume-20/issue-1/item-03/ for an editorial written by our Director of Policy and Practice and Board President. 

August 2023

Please visit the CSWA Position Papers page to view the Position Paper on Artificial Intelligence and Psychotherapy.

July 29, 2023

For the past year, I have been working on a document with NASW on Clinical Social Work Standards. A draft of this document has been released for public comment. I hope all CSWA members will take a look at it and offer your comments. You can find it at https://www.socialworkers.org/Practice/Clinical-Social-Work/Practice/clinical-social-work-standards-draft-forum2. The comment period is open until September 15, 2023.

This is kind of a condensed version of the Private Practice in Clinical Social Work: A Reference Manual, which I also participated in developing with NASW, released in 2021.

Please send me your thoughts as well.

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

July 12, 2023

Good news! On July 7th, 2023, Governor Mike Parson signed Senate Bill 670 and Senate Bill 157 making Missouri the first state to enact the Social Work Licensure Compact. This is a milestone development in supporting the mobility of licensed social workers.

SB 670 was sponsored by Senator Travis Fitzpatrick and Senator Lauren Arthur, and SB 157 was sponsored by Senator Rusty Black.

The Social Work Licensure Compact seeks to increase public access to social work services, provide licensees with opportunities for multistate practice, support relocating military families, and allow for expanded use of telehealth technologies. Currently, the model compact legislation is available for other states to introduce and enact like Missouri. Thus far there have been nine other states that have introduced: Utah, Kentucky, Vermont, New Hampshire, New Jersey, Georgia, South Carolina, North Carolina, and Ohio.

How is the Social Work Compact progressing in your state?

If you have not reached out to your legislators to let them know about the Compact, please start the process now. You can find the materials to use on the Compact Information page on the CSWA website.

Please let me know when you have 1) a pending or passed bill in your state, 2) a legislator who is willing to sponsor the bill, 3) if you need assistance in finding a legislator to sponsor the Compact bill, and/or 4) have talked to NASW about working together to get the Compact going.

Let me know when you have any information on the above issues.

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

June 29, 2023

By Laura Groshong, LICSW, Director, Policy and Practice

Here are two issues which I hope you will all address with your members of Congress and your state legislature.

For Members of Congress:

For State Legislatures:

Please let me know when you have sent messages to Congress and members of your state legislatures. Thanks for your help.