There have been many questions about the status of the telemental health expansion of Medicare and private insurers as the COVID-19 crisis itself has rapidly expanded. Here is what CSWA knows so far.
The emergency bill signed on March 6 allows for an expansion of Medicare telehealth services of all kinds, once guidance from CMS and HHS is made available. There is no definite date when this will happen, but we hope to have it within two weeks.
CSWA, NASW, and the American Psychological Association will be sending a letter to CMS and HHS tomorrow encouraging them to allow a temporary expansion for patients that we have been seeing within the past three years. The option that is currently being discussed per the March 6 bill is videoconferencing only, not telephonic sessions. Of course CSWA hopes that telephone sessions will be allowed as well, but it is unlikely that it will be as soon as videoconferencing is covered. It is a possibility that when videoconferencing is expanded by CMS, it will be retroactive to February, 2020.
As for private insurers, there is confusion about what they are willing to cover through videoconferencing and telephonically at this time. Most companies that offer coverage are doing it for in-network providers only, who must use a specific telemental health platform and accept the fee offered. This is generally less than LCSWs are used to being paid by these insurers for in-person sessions. Out-of-network providers may or may not have the option of being covered for videoconferencing or telephonic sessions. It is VERY important to check with any private insurers you have been reimbursed by, if you want to know the facts about their policies at this time. Having patients call to find out what their policies are and request videoconferencing and/or telephonic coverage if necessary, is a good idea as well.
Another question is coverage for patients who live in a jurisdiction in which you are not licensed, for example, a patient has previously come to your office in Washington, DC, but lives in Maryland. You are licensed in Washington, DC, not Maryland, so would be practicing without a ;license if you treat the patient through videoconferencing while they are in Maryland. I recommend calling the Social Work Board in any state in which a patient resides in which you are not licensed, to ask what their policy is on videoconferencing with patients (or telephonic sessions) who reside there. Again, there may not be good solutions here if the state insists that you be licensed in the state in which the patient resides. Have patients call the Social Work Board in their state and ask for an exemption.
Finally, there is the question of what to do if you have already moved to videoconferencing or telephonic sessions to protect you and your patients from becoming infected by COVID-19; it is problematic if you want to continue getting reimbursed by third party payers who currently do not cover videoconferencing. You can continue to provide sessions through videoconferencing with the hope that they will be covered eventually; take a break while this is sorted out; or make arrangements with patients to pay privately. None are ideal.
I hope we will have some clarity on telemental health expansion soon and will keep you posted. This is a unique and troubling time for LCSWs, all mental health professionals, and our patients. CSWA will do everything possible to give us the ability to continue providing our needed services.
Laura Groshong, LICSW, Director, Policy and Practice, Government Relations ChairClinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY
On Friday, the President signed into law a $8 billion emergency funding bill that included $500 million towards Medicare telehealth, including telemental health services, because this is a declared emergency. There are a few caveats (see below).
The good news: this bill allows the HHS Secretary to waive current Medicare telehealth restrictions (originating/geographic sites) on telemental health during the COVID-19 public health emergency, so that care can be provided regardless of where a patient is located, including at home.
The other news: a qualifying provider, like licensed clinical social workers, needs to have provided a service to an eligible beneficiary in the last three years—so this can only be applied to existing, or recent, patients. Additionally, the telemental health services can only be provided through videoconferencing, not telephone only.
Place of service should be 02 for telehealth. The GT modifier is no longer necessary, but 95 is still needed. CPT codes should be as for an office visit.
This is overall good news and CSWA will work to make it a permanent option.
Below is an update on the COVID-19 epidemic.
It appears that the number of cases is spreading, close to 500 with the Seattle area being the heaviest hit (128 cases, 19 deaths as of this writing). We really don't know when the situation will improve as various cities are just starting to see cases and the tests for confirmation of COVID-19 are still hard to get.
I wanted to pass on some things that members are doing to protect themselves and their patients in addition to the list I sent out last Monday. Some are cover fabric chairs and couches, even leather ones, with plastic/vinyl material which is easier to clean with antiseptic spray.
It is important to make sure that any DIY hand antiseptic is at least 70% alcohol, the rest aloe vera gel, with some drops of aromatic oils like tea tree or lavender; unfortunately many areas are completely out of alcohol and aloe vera. Amazon can send in a week.
Those most at risk of being harmed by COVID-19 are people with underlying health conditions and those over 65. Traveling is not recommended for this group in particular.
Many members have asked about whether Medicare will cover telemental health sessions. The bill signed on Friday provides $8.3 billion for a variety of ways to address the virus but there is no clear guidance on whether CMS will expand their coverage of telemental health yet. I will let you know when this becomes available. Sen. Ron Wyden did get a provision in to support telemental health but no specific enforcement. As for private insurers there is no clarity there either. I suggest having patients request that telemental health be covered if they have private insurance; that is the most likely way to get coverage.
This is a time of anxiety in our personal and professional lives. We should try to remember that we are all in this together and hopefully can help each other get through it.
Laura Groshong, LICSW, Director, Policy and Practice, Government Relations Chair
Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY
I just received guidance from CMS on whether we can be reimbursed for telemental health beyond the accepted treatment in rural areas. Their response is attached.
Basically the answer is no at this time. I recommend calling CMS at1-866-288-8912, x3 to ask for more guidance.
CSWA is developing a Legislative Alert to send to members of Congress to request an expansion of coverage for telemental health during this health crisis.
Clinical Social Work Association
The National Voice of Clinical Social Work
Strengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY
CSWA - Medicare on Distance Sessions - 3-9-20.docx
The Covid-19 virus is spreading and LCSWs need to anticipate the impact that this may have on our patients and our practices. Many of the suggestions below were gathered from the World Health Organization and other sources. CSWA hopes we may be helpful to you as this health crisis evolves.
More information can be found at https://www.who.int/emergencies/diseases/novel-coronavirus-2019/events-as-they-happen
Another comprehensive article can be found at https://www.washingtonpost.com/health/2020/02/28/what-you-need-know-about-coronavirus/?arc404=true
Clinical Practice Action Plan:
- Develop a plan for limiting in-person sessions if there is a public health recommended limitation for being in public places, or a perceived need for such limitation
- Review the CSWA Technology Standards for Social Workers if you have not done so recently ( https://www.clinicalsocialworkassociation.org/Social-Work-Technology-Standards)
- Check with insurers as to coverage of telephone or videoconferencing
- Make sure that any videoconferencing platform you use is HIPAA compliant (VSee, Zoom, etc.)
- Decide if patients with symptoms should have sessions by telephone or videoconferencing
- Decide if you should be working if you have symptoms
- Discuss a plan with patients in advance of the need to limit in-person contact, including arranging for phone or video sessions
- Sanitizing doorknobs and other surfaces touched by patients
- Be aware of own anxieties and try to contain
- Be prepared to acknowledge the anxieties of patients, should they occur
Public Health recommendations to reduce infection from flu or Covid-19:
- Perform frequent hand washing and use of hand sanitizer after being in public spaces
- Cough into elbow or shoulder, not covering your mouth with your hand
- Stay more than 6 feet away from individuals who are coughing or otherwise appear ill
- Avoid social ways of touching others, including handshakes
- Avoid touching your own face as much as possible
- Avoid public transportation such as buses or trains if recommended distance cannot be maintained
- Use hand sanitizer after going through TSA if flying by plane
- Use sanitizing wipes on plane armrests and tables and rental car keys and steering wheels
- Be aware of countries and cities where Covid-19 virus is increasing if traveling
- Engage in immune enhancing activities, i.e., get enough sleep, reduce alcohol intake, get exercise)
- Do not go to an emergency room unless absolutely essential; for a cough, fever, or other respiratory issues contact your primary care doctor first.
- Self-quarantine at the first sign of illness and wear an N-95 face mask in public spaces
Helping Children with Meaning of Restrictions Due to Covid-19
Suggestions can be found at https://onedrive.live.com/view.aspx?resid=D589777FC7C86E35!118&ithint=file%252cdocx&authkey=!ALcOpxBYPPJR_h4
Striking a balance between being overly cautious and overly optimistic may not be easy but as clinical social workers, I think we can achieve it. As you may know, here in Seattle we have a cluster of Covid-19 cases and two deaths, so I will be applying these principles to my own practi
Laura W. Groshong, LICSW, Director, Policy and Practice
The abuse of immigrant minors continues. This article from the Washington Post details how a 17-year-old who was seen by a therapist while in detention and then had his confidentiality violated with serious emotional consequences.
The article is called "Trust and Consequences", written by Hannah Drier, and was published on February 15, 2020. You can find it at https://www.washingtonpost.com/graphics/2020/national/immigration-therapy-reports-ice/
CSWA's commitment to confidentiality includes anyone who is seen by an LCSW. We condemn this act and will continue to work for the right to privacy of all clients.
Dear CSWA Members,
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.
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.
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 ishttps://afsp.org/about-suicide/state-fact-sheets/
I hope this may be useful to you and your colleagues.
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, PresidentClinical Social Work Associationbbrown@clinicalsocialworkassociation.org
Laura Groshong, LICSW, Director of Policy and PracticeClinical Social Work Associationlwgroshong@clinicalsocialworkassociation.org
cc:
Margot Aronson, LICSW, Deputy Director of Policy and Practice Clinical Social Work Associationmaronson@clinicalsocialworkassociation.org
Donna Dietz, CSWA AdministratorClinical Social Work Associationadministrator@clinicalsocialworkassociation.org
Please view our Privacy Policy, Cookie Policy, Terms of Use and Refund/Cancellation Policy.
PO Box 105Granville, Ohio 43023
