October 2026

By Laura Groshong, LICSW, Director of Policy and Practice

For LCSWs paneled with commercial insurers, the billing process generally takes additional time and attention. CSWA will be exploring and sharing with its membership some of the problems that have been created for LCSWs in working with insurers over the coming months. Topics will include a decline in referrals; lowered reimbursement; LCSWs as clinicians; insurers buying LCSW practices; and new limits by Headway and other billing services.

In this first bulletin, we review the differences between psychotherapy and coaching in working with insurers. Remember that major commercial insurers have many different plans and the issues listed here may not apply to all plans they oversee.

History

Insurers have been trying to make a distinction between psychotherapy and coaching since 2023 when United Health Care first offered coaching for free to enrollees, saying therapy treats mental illness and coaching promotes personal growth. Another concept that promotes coaching is that therapy is 'past-focused' and coaching is 'future-focused'. Coaching was also seen as an improvement in that it does not rely on the medical model as psychotherapy does. All these concepts are ways of trying to draw a distinction between mental health treatment and coaching.

But the fact is that coaching is not regulated anywhere in the country while clinical social work is regulated in every state and jurisdiction. The scope of practice for LCSWs does not specifically include coaching. Coaching does not include the DSM-5 or CPT codes. Both can involve exploring the past, understanding patterns, regulating emotions, and creating change, but only LCSWs are licensed, and subsequently regulated, to do so.

Recently other insurers have announced plans to begin offering enrollees treatment for mild mental health problems through coaches instead of licensed mental health clinicians. As Barbara Griswold states, “Insurers frame these coaching programs as providing faster access to care and “early intervention” for members with mild symptoms. But in practice, the line between “helpful support” and “clinical gatekeeping” may be getting blurry — especially when coaches are operating without the clinical training that therapists bring to the session.” (Griswold, B. “Is UHC Replacing Therapists With Coaches?”, September, 2026)

Most of the articles that attempt to distinguish between psychotherapy and coaching claim there is a difference in their purposes and goals. Thus, it is up to the individual LCSW to clearly describe how they define that difference. (Forbes, https://www.forbes.com/sites/meganbruneau/2026/06/01/therapists-are-rebranding-as-coaches-and-its-dividing-the-profession/) This lack of regulatory clarity has led to confusion both for patients and LCSWs. Since LCSWs are regulated, it is important to remember that a complaint filed against an LCSW will be adjudicated by the LCSW scope of practice, even if the LCSW claims they were doing coaching.

National Institutes of Health offer definitions of the differences between psychotherapy and coaching as follows:

A reasonable expectation these days is that any psychotherapy will explore intrapsychic connections among emotions, beliefs, past experience, behaviors, and bodily health. The depth of this exploration and the remedial processes are limitless in principle. If done well, they are guided by the evidence base of what works well for whom, by the therapist's sense of the client's tolerance for feeling vulnerable, and by the need for control of maladaptive behavior between sessions. Posttraumatic stress is explored and processed, including that around illness.

In health coaching, even when intrapsychic and interpersonal forces are noted, they are not the primary focus as they are in psychotherapy. Likewise, affect and behaviors are noticed, acknowledged, and appreciated with empathy but are not deeply explored. “Diagnoses” are not offered, but further evaluation elsewhere is invited as needed. The exploration of the patient's emotions and relationships should not be limitless but only go as far as is needed to enhance awareness and provide the client with some relief, for example, about their particular ambivalence in a health decision or medication adherence process. (https://pmc.ncbi.nlm.nih.gov/articles/PMC3833547/)

Practice Implications for LCSWs

There seem to be three major reasons that insurers want to offer coaching for mental health problems over psychotherapy.

- Finances: when coaching is offered, it is at a lower reimbursement rate than payment for psychotherapy

- Methodology: coaching is based on giving advice and solving specific behavioral problems, so the treatment is likely to be shorter and more goal-oriented than some kinds of psychotherapy

- Patient Fit: some patients are opposed to being diagnosed and want to focus on specific problems which can be done through coaching

The primary problem with the above goals being addressed by coaches is that treating patients with trauma histories or complex issues that go beyond changing a specific behavior. For example, most patients with personality disorders have behaviors and symptoms that a coach is not qualified to identify or treat.

Any LCSW that wants to identify as a coach should be aware that coaching is not part of most clinical social work scopes of practice and could lead to sanctions for working outside the LCSW’s scope of practice and/or sanctions for providing clinical social work in a state in which they are not licensed. It is prudent for LCSWs to consult with their professional liability carrier before self-identifying as a coach. It is also prudent to have clear written descriptions of the work being done as a psychotherapist and the work being done as a coach, though that may not be enough to protect an LCSW in the case of an actionable complaint. As for working for an insurer as a coach, this decision should be carefully considered and there should be clear agreed-upon guidelines with an insurer about the difference between providing psychotherapy and coaching, including the fact that coaches cannot diagnose. Therefore, CSWA does not recommend that members include coaching in their practices unless it is included in the scope of practice for LCSWs in their home state.