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CSWA - Comments on CMS Proposal Rules for LCSW Inclusion oin MIPS - 9/24/19

September 24, 2019 11:00 PM | Anonymous

Below is updated information on the CMS Proposed Rules changes.

At this point, the 800 pages of Proposed Rules for LCSWs are mainly about our being included in the Merit-based Incentive Payment System (MIPS), the successor to PQRS.  CMS has asked CSWA for recommendations on the measures which we can logically keep records on.  The CSWA-recommended 16 measures are included in the attached document.

We also encourage you as individual members – whether or not you are Medicare providers - to send comments to CMS about these proposed rules.  A strong showing from the LCSW community can make a difference.  Remember, these proposed rules are not about reimbursement rates, just the inclusion of LCSWs as Medicare providers in the MIPS system.  If you believe LCSWs should not be included in MIPS or that inclusion would affect your willingness to be a Medicare provider, feel free to say so. 

Suggested language:

Re:  Proposed rules CMS-1715-P

I am a licensed clinical social worker and a member of the Clinical Social Work Association.  I am hoping that the reporting requirements will be simpler and clearer than the ones that were required for PQRS, and more carefully monitored. [Or, I oppose the inclusion of LCSWs in the MIPS system.]   Many LCSWs [I was, if you were] had their reporting rejected although it was in compliance with the PQRS measures.  Many LCSWs [I decided, if you did] decided not to remain part of the Medicare provider network because of these onerous reporting requirements.  Such requirements seem particularly unfair given the reimbursement rate for LCSWs at 25% less than for others providing the exact same services.

How to submit comments:

Your comments should be submitted to Click on the “Comment Now” box on the right side to submit your comment.  All comments must be submitted by Friday, September 27, 2019, 5 pm EDT.

Comments sent by CSWA:

If you would like to read the more extensive comments sent by CSWA, you can find them at CSWA - CMS Comments on Medicare Proposed Rules (Final) - 9-24-19.pdf. CSWA will keep members apprised of the final decision on these proposed rules.


September 20, 2019

I have received several messages from you about the new CMS proposed rule to lower the Medicare reimbursement for psychologist services.

It appears from the proposal (found in the Federal Register at ) that the reduction for psychologists is a higher reduction than for clinical social workers , i.e., 7% vs. 6%.

The proposed rule also asks for recommendations for measures that could be used to include LCSWs in MIPS, the new PQRS, in 2022. 

We are in contact with NASW and hoping to submit joint comments on this proposed rule.

CSWA will be responding to all of these proposals shortly and asking members to do so as well.  You can start reviewing the extensive rule now. Comments must be in by September 27, 2019.

CSWA will have our comments by early next week for your consideration.

Let me know if you have any questions.

Laura Groshong, LICSW, Director, Policy and Practice, Government Relations Chair

PO Box 105
Granville, Ohio  43023

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