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CSWA - Questions about State of Emergency Extension - 10-8-20

08 Oct 2020 12:56 PM | CSWA Administrator (Administrator)

I’ve received several questions about the HHS extension of the State of Emergency which I will answer below:

  1. Does the HHS State of Emergency affect reimbursement for telemental health or audio only treatment? No, this only applies to the coverage in some form of telemental health and audio only therapy by Medicare and Medicaid, which is determined by CMS. Reimbursement rates are the same as for in-person sessions.

  2. Does the HHS State of Emergency extension affect coverage and reimbursement by commercial insurers?  The commercial insurers, e.g., Optum, Aetna, BlueCross/BlueShield, Cigna, etc., will develop their own policies about telemental health/audio only coverage.  Many have followed the direction that CMS takes so far.  Reimbursement is more varied.  Some states have required insurers that cover telemental health and audio only treatment to reimburse at the same level as in-person treatment.  Check with your Insurance Commissioner or Social Work Board.

  3. Does the HHS State of Emergency extension affect the ability to provide treatment across state lines without being licensed in the state of the client? The extension does not address the ability to treat clients in states where the LCSW is not licensed. Some states have allowed LCSWs to get a temporary license, some allow temporary reciprocity if an LCSW is licensed in another state. There are a couple bills in Congress that would make this national policy if they are passed. For now, it is the responsibility of the individual LCSW to find out what the policy about treating clients in states where they are not licensed in that state, as well as in the state where they ARE licensed.

  4. What will happen when the State of Emergency ends to coverage of telemental health and audio only treatment?  That is currently unknown but unless there is a permanent requirement that telemental health and audio only treatment be covered as in-person treatment is, it is likely that insurers will only cover in-person treatment.

In short, coverage of telemental health and audio only treatment will now continue until January 21, 2021, for Medicare and Medicaid.  The reimbursement rates will remain the same for Medicare and Medicaid during this time.  Commercial insurers may follow this policy but are not required to.  The responsibility to find out what coverage is for commercial insurers is our responsibility as LCSWs to check.

Let me know if you have any other questions about the State of Emergency extension at

Laura W. Groshong, LICSW, Director, Policy and Practice

PO Box 10
Garrisonville, Virginia  22463

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