Here is a clarifying announcement from CMS about coding and requirements for in-person meetings. Most of this information was sent last month. There is coding information about audio only which should be followed. Though the information is for rural health clinics it also applies to private practice elsewhere.
The information can be found at:
https://www.cms.gov/files/document/se22001-mental-health-visits-telecommunications-rural-health-clinics-federally-qualified-health.pdf
Please let me know if you have any questions.
All best,
Laura W. Groshong, LICSW, Director, Policy and Practice
The Aware Advocate
Telemental Health Coverage When PHE Ends: Part 2
Laura Groshong, LICSW, Director, Policy and Practice
May 1, 2023
As was noted in the CSWA Announcement of March 16, 2023, “Telemental Health Coverage When PHE Ends” (https://www.clinicalsocialworkassociation.org/Announcements/13134039), there will be changes to clinical social work practice when the Public Health Emergency (PHE) ends on May 11, 2023. This paper elaborates on these additional changes which affect many more areas of practice.
HIPAA Changes
As we know, the kinds of video platforms that were allowed to conduct mental health treatment during the pandemic were relaxed. Platforms that did not meet the security requirements of HIPAA including Facetime, Skype, and others which did not provide a Business Associate Agreement (BAA), were accepted by the Office of Civil Rights (OCR) and not seen as a violation of HIPAA rules. This relaxation will change with the end of the PHE. The relaxation of providing the Good Faith Estimate (GFE) for telemental health will also be back in effect.
OCR is providing a 90-calendar day transition period for covered health care providers to come back into compliance with the HIPAA Rules with respect to their provision of telehealth. The transition period will be in effect beginning on May 12, 2023 and will expire at 11:59 p.m. on August 9, 2023. OCR will continue to exercise its enforcement discretion and will not impose penalties on covered health care providers for noncompliance with the HIPAA Rules that occurs in connection with the good faith provision of telehealth during the 90-calendar day transition period.
In other words, by August 9, 2023, all LCSWs will need to demonstrate that they are using a HIPAA compliant platform, e.g., ZoomPro, Doxy.me, and other platforms offer a BAA. OCR has not been penalizing LCSWs for the failure to give a GFE to patients who are self-pay or pro bono. These penalties will be back in effect as of August 9 if LCSWs are found to be non-compliant.
For more information go to:
https://www.hhs.gov/about/news/2023/04/11/hhs-office-for-civil-rights-announces-expiration-covid-19-public-health-emergency-hipaa-notifications-enforcement-discretion.html
Changes to Codes and Modifiers for Medicare
Medicare has added more guidance in regard to codes which will be covered and modifiers needed for coverage. In addition to psychotherapy codes, there are several new codes available to clinical social workers for Behavioral Care Management which would include care integration and other services that have not been covered until now. The code will be G0323 for Care Management Services for Behavioral Health Conditions.
The details are: ● New for CY 2023: Describes general BHI that a clinical psychologist (CP) or clinical social worker (CSW) performs to account for monthly care integration ● A CP or CSW, serving as the focal point of care integration furnishes the mental health services ● At least 20 minutes of CP or CSW time per calendar month
Additionally, the modifier for Medicare claims is “GT” though “95” can be used for other claims.
For more details go to: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/BehavioralHealthIntegration.pdf
Medicare Advantage Changes
Medicare Advantage (MA) plans may offer continued telehealth benefits. Individuals in a Medicare Advantage plan should check with their plan about coverage for telehealth services. Remember that MA plans are commercial insurance and have their own coverage. Some MA plans may require patients to be seen in person at least once a year. After December 31, 2024, when these flexibilities expire, some MA Accountable Care Organizations (ACOs) may offer telehealth services that allow primary care doctors to care for patients without an in-person visit, no matter where they live. If your health care provider participates in an ACO, check with them to see what telehealth services may be available. In short, the coverage for MA plans may be more variable than coverage for traditional Medicare.
For more information, go to: https://www.cms.gov/files/document/what-do-i-need-know-cms-waivers-flexibilities-and-transition-forward-covid-19-public-health.pdf
Private Health Insurance and Telehealth
As is currently the case during the PHE, coverage for telehealth and other remote care services will vary by private insurance plan after the end of the PHE. When covered, private insurance may impose cost-sharing, prior authorization, or other forms of medical management on telehealth and other remote care services. For additional information on your insurer’s approach to telehealth, contact your insurer’s customer service number located on the back of your insurance card.
Summary
For more detailed information in general, go to https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/BehavioralHealthIntegration.pdf.
The next few months will bring many changes. Let me know if you have any questions.
Contact:
The ASWB Clinical Social Work Examination:
Competence, Context and Next Steps
March 2023
A professional debate is taking place about the validity of the Association of Social Work Boards’ (ASWB) Clinical Examination as a gateway to giving clinical social workers the ability to practice independently and in settings that require clinical social work licensure. Data on the pass rates for this examination were released in August 2022. The ASWB Pass Rate Analysis showed that 45% of African American test takers passed the examinations while 85% of white test takers passed. Additionally, there was an approximate 20-percentage-point disparity in the pass rates for older test takers and for those whose primary language is not English (https://www.aswb.org/wp-content/uploads/2022/07/2022-ASWB-Exam-Pass-Rate-Analysis.pdf). As an organization, the Clinical Social Work Association (CSWA) is concerned about members who face these disparities.
CSWA is particularly concerned about Black social workers and other marginalized groups being denied social work licensure, being denied access to jobs that require licensure, and the impact this has on their ability to support their families. To be sure, clinical social work is not the only profession which has disparities in examination pass rates; psychologists, LMFTs, physicians and many other professions show similar disparities (Nienow, Sogabe and Husain, 2023). CSWA is nonetheless determined to set a standard for clinical social work credentialing and licensing that is just and equitable.
The need for careful preparation of clinical social workers to practice as independent clinicians and in other settings is not in dispute. The main concerns have been about the ASWB clinical examination which those who desire to be independent clinical social workers must pass. How can we make this process more equitable?
CSWA has participated in a number of ASWB-sponsored events over the past year. ASWB CEO Dr. Stacey Hardy-Chandler presented to the CSWA State Affiliate Annual Summit in October 2022, followed by a meeting of CSWA leadership with Dr. Hardy-Chandler to continue this discussion. Many CSWA members also attended an ASWB meeting on the psychometrics of the exam and participated in the ASWB “Community Conversations,” a focus group for CSWA members where ideas for improving the disparities in the licensure process were considered. Finally, CSWA President Kendra Roberson, PhD, met with other social work leaders as part of a coalition of leaders organized by ASWB.
CSWA has also held monthly Town Halls (which started during the pandemic and have continued for almost three years) where we have listened to members about their concerns and ideas for improving the clinical examination. In these Town Halls, the pain of CSWA members who had struggled with the ASWB examination came through loud and clear. When the ASWB report was released in August 2022, the experiences of these members were sadly validated.
There are known racial inequities in academic institutions at every level (Nienow, et al., 2023) including graduate school programs. CSWA has examined the ASWB clinical examination pass data by schools. Some schools are doing a better job of correcting for these inequities and providing adequate support for their students to pass the exams. The ways that these graduate programs are improving pass rates should be explored and adopted by other programs. We believe that the Council of Social Work Education (CSWE) could play a central role in helping schools address this issue.
CSWA strongly believes that clinical social workers preparing for the ASWB clinical exam need test prep materials, including courses, peer group involvement, and financial support. In addition to more support from graduate programs, CSWA would like to see ASWB provide more financial support and exam preparation.
CSWA encourages the social work community to continue to discuss the use of written exams as a means of determining competence. Can an examination adequately predict whether a clinician who passes will increase public protection? Can an examination signal that a clinician is better prepared to be a clinically astute clinical social worker? Answering these questions requires collaboration between educators, clinicians, and regulators, a process that fortunately began during recent meetings to develop the language for the Social Work Compact. That said, it is possible that a more neutral organization could also assist our community in making these larger decisions about testing.
In the absence of another pathway to licensing, CSWA has come to the conclusion that for now, we need an examination or some suitable secondary pathway to demonstrate clinical competency. The ASWB clinical examination fills this role. The 2022 ASWB report shows the need for significant changes to the examination to eliminate the disparities in pass rates for Black clinical social workers and the other groups that are currently unable to pass the examination at rates comparable to white clinical social workers.
Here are the steps CSWA is taking to address the elimination of these disparities. We aim to:
As the social work community grapples with best approaches to clinical social work competencies and examinations, CSWA’s intention is to collaborate with other social work organizations interested in improving each clinical social worker’s journey to licensure and enjoyment of their work life through increased access and skills. Clinical social workers need more support in their MSW programs, throughout the 3000 hours of supervised experience, and to prepare for the ASWB clinical examination and/or other ways of evaluating clinical competency.
References:
https://www.aswb.org/wp-content/uploads/2022/07/2022-ASWB-Exam-Pass-Rate-Analysis.pdf
Nienow, M., Sogabe, E, and Husain, A. (2023). Racial disparity in social work licensure exam pass rates. Research on Social Work Practice 33/1, 76 – 83.
Contacts:
Kendra Roberson, PhD, CSWA President president@clinicalsocialworkassociation.org
Laura Groshong, LICSW, CSWA Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
Telemental Health Coverage after PHE Ends
March, 2023
The Public Health Emergency (PHE) is ending on May 11, 2023. This has caused some concern for LCSWs who have been working through telemental health since the pandemic began in 2020. The question of whether psychotherapy will be covered when the PHE ends is a complex one. Here is what we know about telemental health coverage at the moment:
We have become aware that the Compact webpage and associated links that were sent out to you on February 27th have not been working for everyone. The Council of State Governments (who is responsible for that website) is aware and has their technology team actively working on resolving the issue.
To assist those individuals having trouble loading the pages, we have downloaded the majority of the information from the Compact website to our own CSWA website. You can access that information HERE. Please check back and try the Compact website when you get a chance, however, as some fixes have already been put in place by the Council of State Governments' team.
Here is the long awaited Social Work Compact Bill which will allow:
The Compact will not be operational until at least seven states’ legislative bodies have passed the Compact into law in their states. Once this happens, the Social Work Commission will be created to oversee the Compact and individual LCSWs can join.
This is the basic information that explains the Compact: https://swcompact.org/
The actual language of the Social Work Compact Bill is here: https://swcompact.org/wp-content/uploads/sites/30/2023/02/Social-Work-Licensure-Compact-Final.pdf OR HERE.
I will be sending lobbying suggestions shortly.
In states which have a session that is ending soon, the bill will probably have to wait until next year. Some states are ready to drop the bill today. We hope to reach the seven state threshold by next year.
Let me know if you have any questions.
Laura Groshong, LICSW, Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
Remembering Margot - February 2023
It is with great sadness that we announce that our long time Deputy Director of Policy and Practice, Margot Aronson, passed away on January 30. We are honored to have been a part of Margot's legacy and send our deepest condolences to her loving family and extensive network of friends.
Margot's family has requested that donations be made to her favorite charities in lieu of flowers. They are the Erin Levitas Foundation, Frank Lloyd Wright Conservancy and DC Appleseed Center.
In Margot's honor, the Clinical Social Work Association has newly established the Margot Aronson Legislative Warrior Award. The recipient of this annual award will be given to someone from the State Societies who manifests the same kind of energy that Margot had for being an advocate for Social Justice and a leader in engaging legislative action. CSWA will award this honor every year at the Fall Summit for State Affiliates.
Please see below for two special tributes to Margot.
Margot Aronson: A Remembrance
by Laura Groshong, LICSW, CSWA Director, Policy and Practice
I first met Margot at the Clinical Social Work Federation meetings in 2004. She was President of the Greater Washington Society for Clinical Social Work and I was working on the CSWF Government Relations Committee. We were just getting to know each other when CSWF morphed into the Clinical Social Work Association in 2006; I was asked to lead the CSWA Government Relations Committee. Living in the “other” Washington, I quickly realized I would need someone in Washington DC to attend MHLG meetings, briefings, and other DC based events. Knowing that Margot had spent about 5 years doing advocacy for GWSCSW, I asked her if she would like to serve as my Deputy in DC. She quickly agreed and our partnership blossomed. We wrote papers together (she was a master editor), developed policy positions, lobbied together during my quarterly trips to DC, and often talked daily about the many issues we covered. We worked with about eight CSWA Presidents and created the Policy and Practice Committee where she also served as my Deputy.
I loved Margot for many reasons, including the times my husband and I spent with her and her late beloved husband, Ed Levin. Losing Ed five years ago left a hole in Margot’s life that led to a deepening of our personal relationship. I encouraged her to get involved with PsiAN, a new organization in Chicago, where she joined the Board and became as indispensable to them as she was to me.
I never gave up hope that Margot would recover when she started having health problems a year ago, but it was not to be. Her daughter Stephanie (a social worker) did a wonderful job taking care of her for the past year. Her son, Jeff, and other daughter, Ali, were also devoted to her.
A light has gone out in the world, but I hope we all can recognize the incredible gifts that Margot brought to our field and the ways she made clinical social work stronger. I will miss her more than I can say.
A Tribute to Margot Aronson
by Judy Gallant, LCSW-C, GWSCSW Director of Legislation and Advocacy
There are many people our Society is indebted to for our success in achieving legislative goals, but, sadly, we have lost one of our most committed, beloved and active members, Margot Aronson, who passed away on January 30, 2023, at the age of 81, after a year of coping with various illnesses.
As several of our members have commented, she was “a force to be reckoned with.” From her ability to encourage, cajole and support members to become more active in the Society’s work, to her enthusiasm for progressive and social justice causes, and to the detailed work she would do to make sure Clinical Social Workers were included in Federal legislation, she was always able to move things along in the right direction.
Margot’s experience growing up in New Jersey was the basis of her lifelong interest in and support of a group dedicated to Frank Lloyd Wright’s architecture. Her parents were teachers whose goal for their family was to live in a house built by Wright. Now called “The Richardson House,” it is a “Usonian” house. These homes were built for the working class, with the goal of building affordable, functional homes for those with more limited budgets. Margot’s mother and father wrote to Frank Lloyd Wright with their wishes, and they collaborated with him to get the home built.
After attending college in NY, Margot worked for a number of years with the Peace Corps and treasured those experiences, including editing their magazine at the time. This helped her feel comfortable with taking on her first major role in our Society, editor of our newsletter.
After marrying and starting a family, she eventually found her way to Social Work, graduating with a Master’s degree from the University of Maryland’s School of Social Work. She worked for many years with children, adolescents and their families at the Regional Institute for Children and Adolescents (RICA) in Montgomery County, MD. She also joined GWSCSW, where in addition to being our newsletter editor, she became President (2002-2005), and Vice President for Legislation and Advocacy (currently named Director of L&A).
It was in this last role that Margot tapped on my shoulder and drew me in to working on our MD Legislation and Advocacy Committee. We drove to Annapolis together countless times, thought through strategies to accomplish our goals, and discussed how best to write testimony together with our lobbyist at the time, Alice Neily Mutch. I learned that I could actually talk to legislators (they are people!), as well as provide testimony in committee hearings. I was nervous, but Margot was a calming, informative, and for me, a necessary presence.
When Margot became more involved with CSWA, becoming the Deputy Director for Policy and Practice, she and then-President Nancy Harrington asked that I step into the role of Director of L&A. I did so and continued to consult with Margot for her sage advice and experience, which was vast.
Margot would do things like sit with a Congressional bill for several days, painstakingly marking up the bill in every place where a Clinical Social Worker should have been included (It passed in that form). In 2014, along with Janice Berry Edwards and Eileen Dumbo, Margot organized a “Training for Cultural Competency: A Colloquium for Social Work Educators.” Along with her other accomplishments, Margot pulled people in to collaborate and form coalitions to get things done.
She also shared other parts of her life, including her and her husband at that time, Ed Levin’s, involvement in the DC Appleseed Center for Law and Justice. Ed, along with Ralph Nader, was a founding member of the national Appleseed network. Margot and Ed were strong supporters of the DC Center and their efforts to make DC a better place to live, including supporting DC statehood, and providing pro bono legal assistance to achieve many of their goals.
Margot’s support of the DC Appleseed Center for Law and Justice, as well as her family raising her in a Frank Lloyd Wright Usonian house, were of importance to her. They show an overarching theme in her growth and thinking about social justice from exposure to those ideas even at an early age. Margot was a many-faceted, strong, and principled woman, a staunch friend, a “woman of valor.” She was formally recognized as such in different ways, for example, as the NASW Social Work Advocate of the Year and as the first recipient of the GWSCSW Frances Thomas Award for Legislative Excellence. I will always carry her with me, treasuring her principles, joie de vivre and her love.
Questions and Answers about the Compact
February 13, 2023
The information about the Compact development has led to a number of questions which I will try to answer here. However, there are some basic misunderstandings about the way that CSWA functions which need to be clarified first.
The Clinical Social Work Association is an independent membership organization; to have access to staff and the materials that CSWA has created, LCSWs need to join CSWA. State Societies are affiliated with CSWA and receive some materials for all their members, even those who are not CSWA members. This causes some confusion because being a member of a state Society does not mean you are a member of CSWA. You can join CSWA if you are a member of a State Society for a reduced rate at www.clinicalsocialworkassociation.org. You can also join CSWA as an individual member if you are not a member of a State Society. This underlying structure is one that has been hard to grasp at times. I hope this clears it up. Now on to the questions that have been raised by the Compact information.
Compact Questions and Answers
CSWA members who reached out to me had mixed emotions about the outcome of the Compact meetings this week. In general, the outcomes were consistent with the goals that CSWA has explained to members for the past year and a half during the development of the Compact. Please review the information on the CSWA website for more background on how CSWA has worked to implement the Compact during this time.
One important piece of information is that NO STATE OR JURISDICTION belongs to the Compact yet. We are in about step three of a process that has many more to go and will require up to two years to accomplish. We will need seven individual states/jurisdictions to sign on before we can begin the process of establishing a Commission to oversee the Compact. Thus, we will need everyone’s help to get the Compact passed in as many states as possible and eventually in each state/jurisdiction. Once the final language of the Compact bill is available on February 27, CSWA will be explain how to advocate for the Compact in your state/jurisdiction.
In no particular order, here are the questions that have come in about the Compact and answers to them:
ASWB Report
ASWB has put out a report on the ways that they intend to correct the disparities in the pass rates for the exams. See below for their update, or find it on their website at this link: https://www.aswb.org/aswb-social-work-examination-update/
As we enter 2023, the Association of Social Work Boards wants to provide an update on our social work licensing examinations. Last year, we took the groundbreaking step of publishing the national, state, and school exam pass rate data to contribute to and lead engagement in profession-wide conversations around diversity, equity, and inclusion.
The data highlighted disparities in exam pass rates for different demographic groups. For Black test-takers and older test-takers, pass rates were particularly low. The discrepancies seen in the data are unacceptable. Recognizing that multiple factors impact a test-taker’s performance and need to be addressed, we remain committed to doing our part and working with other members of the social work community to address the societal inequities that are reflected in the pass rate differences.
We are actively exploring the causes of these gaps with educators and practitioners and are already taking action to better prepare all social workers for licensed practice while continuing to support our members—social work regulators—with their public protection mandate.
We welcome the chance to share our latest efforts with the profession. The initiatives outlined below build on our previously communicated pledge to include a more diverse set of voices in our exam development process and recent efforts to provide support and resources for educators and supervisors as they prepare licensing candidates.
ASWB is taking seriously the feedback we have received from the social work community and is committed to continue listening. ASWB has engaged HumRRO, an independent nonprofit research and consulting firm, to collaborate with community partners in facilitating inclusive and productive conversations about the social work licensing exams. This series of community conversations launched in January and will continue through May. The sessions are designed to gather information to be used as we develop exams for the future of social work. For anyone not able to participate in a session, we are also offering a self-paced online survey to gather additional feedback and ensure the largest possible number of voices can be heard.
We are also exploring additional or alternative assessments, in line with our strategic framework. As we re-envision competence assessment, we are looking at ways that candidates can demonstrate competence beyond the use of a multiple-choice examination format. We are carefully weighing the feasibility of numerous assessment options. Our primary concern is to ensure the validity and reliability of any assessment format we choose; however, we are also reviewing the impacts of changes on test-taker well-being and the potential for cost increases for test-takers. We anticipate that qualitative data gleaned from the community conversations will influence decision making.
In addition, we are continuously reviewing our exam administrative policies and procedures. We are considering, for example, the possibility of offering secure, remote proctoring of examinations. As each possibility is explored and measured, the goal of keeping the exam fair and accessible for all will remain at the forefront.
Finally, we will issue a call for proposals for third-party research in March. ASWB will provide data sets and limited funding for approved proposals through its research arm, the American Foundation for Research and Consumer Education in Social Work Regulation. ASWB has committed to investing in this important work. Areas that would benefit from research include exploring how the professional standard of competency is defined and measured and gaining a more complete understanding of pipeline variables that account for differences in pass rates.
While these important research initiatives are underway, ASWB is continually evaluating other ways of supporting test-takers that are appropriate to our work as stewards of a professional competency assessment program. In January, we began piloting a free test mastery program for test-takers who did not pass the social work licensing exams. We have engaged Fifth Theory, an independent firm with expertise in helping individuals understand and develop the test mastery mindset required to succeed on high-stakes exams. Rather than teaching specific exam content, Fifth Theory provides tools that strengthen general skills needed to pass important exams, like anxiety reduction and preparation strategies. ASWB will solicit feedback from users during this pilot phase of the initiative.
Summary of Compact Technical Assistance Group Meetings
February 7-8, 2023
Laura Groshong, LICSW, CSWA Director, Policy and Practice
Kendra Roberson, CSWA President, and I attended 12 hours of meetings about the Social Work Compact sponsored by the Council of State Governments (CSG) this week. We are part of the Technical Assistance Group (TAG) which has been working to develop the Compact language for the past 18 months. There were 20 TAG members with representatives from major social work and clinical social work organizations at these meetings.
There has been general agreement that the benefit of the Compact would be to allow LCSWs, licensed new MSWs, and licensed BSWs (in states where they are licensed) to work across state lines in any state that joins the Compact. Nurses, physicians, counselors, and about 10 other professions have already set up Compacts, sponsored by CSG. Funding is provided by the Department of Defense which started the project to give military spouses the ability to work in multiple states; they have now expanded this option to all licensed social workers whose home state is a member of the Compact.
Examinations
One of the main topics under discussion at these meetings was the requirement that all licensees have passed a national examination or other demonstration that they have met competencies for their licensure level’s scope of practice. Currently the only way these criteria can be met is by taking the ASWB examination. There has been great concern by CSWA and other groups about the ASWB report issued in August of 2022 which showed disparities in pass rates between white applicants and BIPOC applicants; older applicants; and applicants who had English as a second language. There were several ASWB representatives at the meetings who outlined what ASWB is doing to remove these existing disparities which are:
The TAG was somewhat pleased by these changes, but felt more information is necessary to determine whether they will resolve the disparities.
Oversight of the Compact
All Compacts are run by a Commission which is created when seven states have passed the Compact into law. The Commission will have nothing to do with defining scopes of practice or changing any existing state laws and regulations. There will be one representative from each state that joins the Compact and four ex officio members from national social work associations and regulatory bodies. Many of the details of running the Commission will be developed by the Commission when the Commission is created.
There will be a fee for states to join the Compact. There will also be a fee for individual LCSWs (and other licensees) to join the Compact. Every LCSW must have a home state, which is also the state in which the LCSW resides. One of the requirements for a state joining the Compact is that they accept the language of the Compact as developed. One of the most helpful items is that if an LCSW moves from one state in the Compact to another state in the Compact, they will automatically be licensed in the new state.
Next Steps
The language for the Compact will be available on February 27, 2023. While this may be too late for most 2023 legislative sessions, it should be possible to reach the seven state threshold by 2024.
I will be sending information about how to lobby your state legislatures in the next two weeks. CSWA will provide guidance as the process moves forward. We know there is a lot of interest in making the Social Work Compact ‘real’ and have made state passage a priority.
After a successful meeting with the Social Work Compact Document Team and Technical Assistance Group, CSG and partners are proud to share that compact language will be finalized and ready for state enactment by February 27, 2023. The compact must be enacted into state law by at least seven states. Once the Social Work Compact Commission and additional infrastructure is established, multistate licenses will begin to be issued. If your state legislature is interested in pursuing the compact this legislative session or would like additional information, please contact socialworkcompact@csg.org or matthew.shafer@csg.org.
Pictured here are most of the members of the Technical Assistance Group, including our own Director of Policy & Practice, Laura Groshong, bottom right. TAG members include national social worker organizations, State regulators, CSG staff and counsel.
PO Box 105Granville, Ohio 43023
