Please see the below link for an editorial written by our Director of Policy and Practice and Board President:
https://jswve.org/volume-20/issue-1/item-03/
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 lwgroshong@clinicalsocialworkassociation.org
Social Work Compact Update - 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 at https://www.clinicalsocialworkassociation.org/Announcements/13212620.
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.
Many thanks,
Laura Groshong, LICSW, CSWA Director of Policy and Practice
lwgroshong@clinicalsocialworkassociation.org
Looking for a way to be more involved?
Organizations that Offer Support for Trans People
June 2023
To follow up on our Position Paper released in April, please find resources below that may be helpful in promoting efforts to block anti-trans bills, notably relative to the provision of gender-affirming care.
https://www.acludc.org/en/cases/hinton-v-district-columbia-challenging-department-corrections-policy-discriminatorily-housing
https://www.aclu.org/legislative-attacks-on-lgbtq-rights
https://www.them.us/story/orgs-fighting-back-anti-trans-legislation
https://www.npr.org/2022/11/28/1138396067/transgender-youth-bills-trans-sports
https://www.wbur.org/hereandnow/2023/06/16/anti-trans-laws-mental-health
https://www.cnn.com/2023/04/06/politics/anti-lgbtq-plus-state-bill-rights-dg/index.html
Barsky, A. E. (2023, June 16). Ethics Alive: Urgent Alert – “Some states have banned gender-affirming care for transgender minors. What are our responsibilities?” The New Social Worker.
https://www.socialworker.com/feature-articles/ethics-articles/urgent-alert-states-banned-gender-affirming-care-social-workers-responsibilities
Please let us know if you have other resources that we can share with CSWA members. CSWA will continue our efforts to oppose anti-trans legislation and other harmful practices.
Contact: Laura Groshong, LICSW, CSWA Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
Below are the materials to use to begin lobbying for the creation of the Social Work Compact. They are hopefully self-explanatory but let me know if you need any further information or direction. Please start the process in the next couple weeks.
Laura Groshong, LICSW, CSWA Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
Background on SW Compact 6-23
LCSW Compact - Lobbying 6-23
Here is some clarifying information about Medicare’s requirement that patients that are being seen through telemental health must have an in-person session every six or twelve months.
The language from Medicare is as follows: (yellow outline is mine):
Telehealth includes certain medical or health services that you get from your doctor or other health care provider who's located elsewhere (or in the U.S.) using audio and video communications technology (or audio-only telehealth services in some cases), like your phone or a computer. You can get many of the same services that usually occur in-person as telehealth services, like psychotherapy and office visits.
Through December 31, 2024, you can get telehealth services at any location in the U.S., including your home. After this period, you must be at an office or medical facility located in a rural area (in the U.S.) for most telehealth services.
You can get certain Medicare telehealth services without being in a rural health care setting, including:
In short, diagnosis and treatment of mental health disorders will be covered by traditional Medicare until at least 12/31/24 without an in-person session. Audio only treatment will be covered “in some cases” so more guidance is needed on what the cases are that will be covered.
Treatment overseen by Medicare Advantage, or commercial insurers, may or may not require in-person sessions, and may or may not cover telemental health or audio only treatment.
I hope this clarifies the situation for now. Let me know if you need more information.
Laura Groshong, LICSW, Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
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
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:
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