June 14, 2022

This episode of The Aware Advocate will focus on POS Codes for Medicare; Public Health Emergency extension; and the Social Work Compact development.

POS Codes for Medicare

There remains a lot of confusion about which POS codes should be used for Medicare. Here is a reminder of what Medicare and other insurers are requiring for claims:

Be sure to check with EACH private insurer for a patient to find out what combination of POS and Modifier are being requested so that claims will not be denied.

Public Health Emergency

The Public Health Emergency is predicted to be in effect until the end of 2022, possibly longer. I will be keeping you informed on any changes that take place which may affect Medicare coverage and commercial insurance.

Social Work Compact

As you know, CSWA began working as part of the Technical Assistance Group (TAG) in October of 2021, along with representatives from ASWB, NASW, CSWE, and Department of Defense and the Council of State Governments to create a Social Work Compact. The latter two groups listed are funding the effort to create a compact for clinical social workers that would allow us to work in any state that has joined the Compact. The process for creating the Compact is as follows:

Once the process is moving forward, we will need to have a legislative campaign to pass the Compact in as many states as possible. I will be sending materials to help you make the case for the Compact in your state.

Let me know if you have any questions about any of these issues.

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

June 7, 2022

Below is a Letter to Congress on gun violence that CSWA signed on to with 9 other national organizations which was published in USA Today this morning.

May 25, 2022

The Clinical Social Work Journal (CSWJ) is pleased to announce a call for papers for a special issue called: Life After the MSW. This special issue will be co-edited by the Editor in Chief of the journal, Melissa D. Grady, PhD and Kendra C. Roberson, PhD, the President of the Clinical Social Work Association (CSWA). In this issue we will be seeking manuscripts that offer readers a mix of historical/scholarly information about the topic, as well as concrete and practical information for soon to be and/or recent MSW graduates. The aim of this special issue is to offer practical advice to newer professionals in the field. We hope that the articles within this special issue can be used by faculty members and supervisors who are helping to train new social work practitioners, as well as by the graduates/students themselves.

Some examples of topics for this special issue could include, but are not limited to issues related to post-masters education, clinical supervision considerations, navigating and/or preparing for the licensure process, practicing clinical social work with a social justice lens, and potential career paths as a clinical social worker.

Interested authors should submit an abstract of no more than 750 words describing the proposed manuscript. Those that are chosen will then be invited to submit full manuscripts that will be between 10-15 pages in length.

Each abstract should include the following:

In addition to the above, full manuscripts will also require

Deadlines for process:

For any questions, please contact Melissa D. Grady at grady@cua.edu or Kendra Roberson at kacey@uw.edu.

May 17, 2022

The Improving Access to Mental Health Act (S.870), which CSWA has been supporting since 2012, has provisionally been included in the omnibus mental health legislation package being developed by the Senate Finance Committee. The request from the Committee is that we find more Republican cosponsors for the bill. This needs to happen by Friday, May 20, 2022 COB.

To review the high points of this bill, they are:

The Committee members/Legislative aides that are most important to this effort are:

Sen. Mike Crapo (R-ID): Rebecca Alcorn, Senior Policy Advisor, rebecca_alcorn@crapo.senate.gov

Sen. Chuck Grassley (R-IA): Nic Pottebaum, Health Policy Advisor, nic_pottebaum@grassley.senate.gov

Sen. John Cornyn (R-TX): Alaura Ervin, Legislative Assistant, alaura_ervin@cornyn.senate.gov

Sen. John Thune (R-SD): Danielle Janowski, Health Policy Director, danielle_janowski@thune.senate.gov

Sen. Richard Burr (R-NC): Angela Wiles, Health Policy Director (HELP Committee), angela_wiles@help.senate.gov

Sen. Rob Portman (R-OH): Jack Boyd, Health LC, jack_boyd@portman.senate.gov

Sen. Pat Toomey (R-PA): Mike Weiss, Health LA, mike_weiss@toomey.senate.gov

Sen. Tim Scott (R-SC): Brianna Wood, Legislative Correspondent, brianna_wood@scott.senate.gov

Sen. Bill Cassidy (R-LA): Mary Moody, Health Policy Advisor, mary_moody@cassidy.senate.gov

Sen. James Lankford (R-OK): Cambridge Neal, Legislative Assistant, cambridge_neal@lankford.senate.gov

Sen. Steve Daines (R-MT): Rachel Green, Health Policy Advisor, rachel_green@daines.senate.gov

Sen. Todd Young (R-IN): Beth Nelson, Health Policy Director, beth_nelson@young.senate.gov

Sen. Ben Sasse (R-NE): Shannon Hossinger, Policy Advisor, shannon_hossinger@sasse.senate.gov

Sending the following message to the LAs is a good way to make contact with the senators. You can send your message even if you are not a constituent.

The suggested message is as follows (feel free to use your own language):

“I am [a constituent and] a member of the Clinical Social Work Association. Please consider becoming a cosponsor for S.870 which will provide greater access to mental health and substance use treatment, desperately needed in these difficult times. S. 870 will increase the number of LCSWs who become Medicare providers. Thank you for your consideration.”

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

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

April 27, 2022

I have received a deluge of emails from you about the use of POS “10” for Medicare and other insurers. This guidance that Medicare has provided about this policy is complicated.

The current guidance from CMS is that:

• POS “11” should be used until the end of the Public Health Emergency, timing of which is currently unknown, even though this is not what the POS “11” is for.
• And, as of April 4, 2022, there is some variation according to Medicare Administrative Contractors (MACs) about whether or not to move to POS “10” as initially stated by CMS.
• Check with YOUR MAC to clarify which POS code is being accepted currently if the patient is being seen through telemental health in their home; for example, technically, if a patient is in their car, the POS code should be “02”.
• You can find your MAC contact information at the CSWA website under “Clinical Practice”.
• The Medicare Modifier for POS codes is still 95. This may seem counterintuitive as 95 is supposed to be for telemental health but it is the only combination that currently works.

Be sure to check with EACH private insurer for a patient to find out what combination of POS and Modifier are being requested so that claims will not be denied.

I hope this resolves the confusion about POS codes. Let me know if there are any other questions.

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

April 24, 2022

There has been some confusion about what Point of Service (POS) Codes should be used for Medicare and other insurers as of April 1, 2022.

As you know, there were changes to POS codes that were announced as of January 1, 2022 to be “available” for Medicare as of April 1, 2022. POS “10”, a new POS code for telemental health services that are provided when the patient is in their home, and the LCSW is in their office or elsewhere. Other POS Codes are “2” which is used when a patient is not in their own home and receiving telemental health services from an LCSW or “11” which is used when seeing a patient in the LCSW’s office.

The Medicare modifier is 95 for any of the above codes.

It appears that the POS 10 is now being used instead of POS 2 for Medicare for reimbursement. All other insurers, public and private, should be contacted about the POS codes that are required for reimbursement of claims. The same goes for which modifier is being used – check with the individual insurer.

For more information, go to https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set If you have other questions, contact me at lwgroshong@clinicalsocialworkassociation.org.

March 28, 2022

Transgender children have been in the crosshairs of conservative groups in the legislature and elsewhere for the past decade. Amongst legislative attempts to discriminate against them, there have been attempts to ban them from gender-specific bathrooms or from participating in sports consistent with their gender identity. Support for transphobic attitudes and actions has grown. Now there is an attempt in Texas to lay blame on parents who affirm their child’s gender identity. This bill is one of the most harmful to trans children, but is the tip of the iceberg; there have been over 235 state-based bills that limit the rights of trans children in 2022 (https://www.msn.com/en-us/news/us/nearly-240-anti-lgbtq-bills-filed-in-2022-so-far-with-most-targeting-trans-people/ar-AAVhMSa). The current law that has passed in Texas, abhorrently describes parental support of trans children as child abuse; though, for now, it has been placed on hold by a Texas appeals court.

CSWA believes that gender identity is an integral aspect of our intersectional identities and that children’s rights to express their identities, and to participate in everyday activities of childhood, regardless of this expression, should be protected. LCSWs work with trans-children and adults who have been harmed because their trans identities. To our affiliated colleagues in the Texas Society for Clinical Social Work, we send our support and encouragement to stand strong. No law can persuade us to ignore our ethical stance on respecting the identity of any individual child, and for parents that support and affirm their children. Also notable, the Texas law does nothing to prevent the violence directed toward trans BIPOC youth for being themselves. This violence has increased at alarming rates in the last few years.

As reported by Forbes, 30 trans youth were killed in 2020, including 23 that were BIPOC youth. (Forbes, “Transgender America: 30 Killed And Fatally Shot Already In 2020”, 10/2/20, https://www.forbes.com/sites/jamiewareham/2020/10/02/30-trans-woman-have-now-been-violently-murdered-in-america-in-2020/?sh=296cb38564a4). The work of groups like GLAAD (glaad.org), the Trans Youth Equality Foundation (http://www.transyouthequality.org/), and the Transgender Law Center (https://transgenderlawcenter.org/) are crucial to educating the public and advocating across multiple domains to prevent transphobic violence and discrimination against trans youth and their parents. CSWA supports the work of these groups in preventing harm and protecting trans children.

March 1, 2022

President Biden’s State of the Union address tonight will have a major focus on the need for more mental health funding and services. A few of the areas he will discuss are:

To see a complete summary of what the President will discuss regarding mental health go to: https://www.whitehouse.gov/briefing-room/statements-releases/2022/03/01/fact-sheet-president-biden-to-announce-strategy-to-address-our-national-mental-health-crisis-as-part-of-unity-agenda-in-his-first-state-of-the-union/

CSWA will provide a message to send to Congress, who will have to approve the funding and policy measures regarding mental health, on the issues that most affect clinical social workers following the State of the Union speech.

February 1, 2022

As you have no doubt heard, the Public Health Emergency (PHE) will end on May 11, 2023. Continued coverage for telemental health treatment may depend on the insurance your patient holds when the PHE ends. Here is what we know currently.

Federal Government

CMS, which oversees Medicare and Medicare Advantage, has already announced that these programs will cover telemental health through December 31, 2024. CMS is reviewing the use of telemental health treatment and will make a decision, along with DHHS, about the future of expanded telemental health coverage after the end of 2024.

Some members of Congress are wanting to end the PHE immediately. The Senate and the President will not agree to this, so it is extremely unlikely that this will happen. Regardless, it will not affect the coverage of telemental health by Medicare and Medicare Advantage at this time.

Medicaid

All 50 states and DC expanded coverage and/or access to telehealth services in Medicaid during the PHE. When the PHE ends, coverage for telehealth services may be tied to federal and/or state PHEs. Most states have made, or plan to make, some Medicaid telehealth flexibilities permanent.

Commercial Insurers

It is likely that some commercial insurers will no longer cover telemental health after May 11, 2023. I have heard that LCSWs have been told that telemental health will no longer be covered by commercial insurers NOW. Those companies should be reported to your Insurance Commissioner. As long as the PHE is in effect, telemental health should be covered.

Communication about commercial insurance has been spotty, so have patients check with their insurers. Some states, but not all, are putting laws into effect that will require commercial insurers to cover telemental health treatment.

Free Vaccines and COVID-19 Tests

Separate from the coverage of telemental health, the end of the PHE creates changes about who may receive free vaccines and COVID-19 test kits. A good summary of the changes that are coming has been put together by Kaiser Family Foundation at https://www.kff.org/coronavirus-covid-19/issue-brief/what-happens-when-covid-19-emergency-declarations-end-implications-for-coverage-costs-and-access/#coverage-costs-and-payment.

The Possible Impact on LCSWs

Many of us have converted our practices to exclusively provide telemental health and some us no longer have physical offices. The end of the PHE may require us to reconsider these decisions if telemental health does not continue in the way that we have been using it.

There is a lot of uncertainty at the moment, and CSWA will do our best to give you timely and accurate information about the situation.

January 26, 2022

I hope everyone is feeling well informed about the Good Faith Estimate rule, part of the No Surprises Act, which went into effect on January 1. There have been several webinars on this topic and one was listed on the CSWA website in the Members Only Section.

CSWA is working on two fronts to get LCSWs exempted from the GFE. One is a letter we co-wrote with the Psychotherapy Action Network (attached). The other is a campaign to let members of Congress know about the fact that LCSWs in private practice do not need to be part of the GFE; we already do everything that it requires and there are vanishingly low numbers of LCSWs who have had actionable complaints filed against them for surprise billing.

Please send your members of Congress at www.Congress.gov the following message: “I am a constituent and a member of the Clinical Social Work Association. The No Surprises Act requires me as a Licensed Clinical Social Worker to give my patients a Good Faith Estimate. I am in private practice and have patients pay me directly. The GFE interferes with the mental health treatment process (detailed in the attached letter). Please exempt LCSWs from the Good Faith Estimate requirements.”

NSA Letter to CMS (fin.) - 1-25-22.pdf

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

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