August 6, 2021

By Laura Groshong, LICSW, CSWA Director of Policy and Practice

Though we are in the dog days of summer, there are many things going on that affect our clinical practices. CSWA is pleased to offer information on the following four topics that are currently affecting us: (1) ways to determine what the COVID risk is in your area are by county; (2) a template for writing letters that confirm medical necessity when insurers question the validity of our treatment; (3) an update on the Physician Fee Schedule which will affect our reimbursement in 2022; and a (4) a member survey to determine where people stand on the decision to return to in-office practice and additional topics to gauge ways to better support members.

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COVID Issues

The rise in COVID-19 cases due to the new Delta variant and others is cause for concern. But in this case, as in much of the pandemic, all concerns are not created equal. To understand the risk we face on the personal and professional level, it is necessary to get information that is specific to our location. The CDC has just created a new data base that provides the current level of infection for every county in the country. The COVID Data Tracker is updated daily and can be found at https://covid.cdc.gov/covid-data-tracker/#county-view CSWA suggests that whether you live in an area that is a hot spot for infection or one with low levels of infection, it is prudent to continue to wear masks and maintain social distance of 6 feet in public indoor areas.

The topic of whether to return to seeing patients in person is also on the minds of LCSWs. Please see the two hour webinar I recorded on July 22 to get detailed information on how to make your own decision about what is best for you. You can find it at https://www.clinicalsocialworkassociation.org/CSWA-Webinars#ToBe in the Members Only section.

To give members an overview of the way others are viewing returning to the office, CSWA is asking all members to take the short anonymous Survey to gather this information:

Please click here to complete the survey.

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Medical Necessity

More and more often, LCSWs are receiving letters questioning the “medical necessity” of our treatment. To address these often baseless conclusions, CSWA has developed the response template which you may use to explain the validity of your treatment decisions. Click here for the MEDICAL NECESSITY LETTER [Template].

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Physician Fee Schedule

As happens every August, the Center for Medicare and Medicaid Services (CMS) has issued potential changes to the rules that govern all medical practice which includes clinical social work practice. The CSWA Government Relations Committee is developing comments on this year’s PFS and will send them to members before the August 23 deadline for review.

Thanks for your support of CSWA and have a great summer!

July 20, 2021

There is much information coming out about the level of risk we face at this time to the COVID-19 virus. There are several new variants, particularly the Delta variant, which are spreading quickly. The unvaccinated population varies widely and is a major factor in the likelihood of infection, even for those that have been vaccinated.

This surge, which just resulted this weekend in Los Angeles returning to mask-wearing in public places, comes at the same time that many LCSWs are starting to consider returning to seeing patients in person. CSWA is offering a 2-hour webinar on this complex topic on July 22, 2021, at 1 pm EDT (see www.clinicalsocialworkassociation.org to register).

While it is very difficult to fully assess the level of risk that LCSWs face in going back to our offices or other small spaces like restaurants, we can educate ourselves about our own city/region. Here are some articles to help with that process:

Currently, 48.9% of the US population has been fully vaccinated and another 7.6% have been partially vaccinated. The US COVID-19 new case and fatality rate 7-day averages have doubled in the last two weeks (see "Coronavirus in the U.S.: Latest Map and Case Count" at (https://www.nytimes.com/interactive/2021/us/covid-cases.html).

Despite growing evidence that vaccination curbs mutation (see "COVID-19 Vaccines May Be Curbing New Virus Mutations", (https://www.medscape.com/viewarticle/954621), the political (and largely regional) rift between the vaccinated and unvaccinated is growing (see "Coronavirus latest: Chicago adds Delta-variant hotspots Missouri and Arkansas to advisory list" (https://www.ft.com/content/95716f06-c92d-4f9a-b2f7-30e30ce7cb22).

WHO Director-General Tedros Adhanom Ghebreyesus said " The Delta variant is ripping around the world at a scorching pace, driving a new spike in COVID-19 cases and death," noting that the highly contagious variant, first detected in India, had now been found in more than 104 countries, deaths are again rising and many countries have yet to receive enough vaccine doses to protect their health workers (see " WHO Says Countries Should Not Order COVID-19 Boosters While Others Still Need Vaccines" (https://www.medscape.com/viewarticle/954643).

Where COVID restrictions are loosening, anxiety is increasing according to this Medscape article: https://www.medscape.com/viewarticle/954793. New psychotherapy patient calls (already at a record high since the pandemic began) have risen dramatically during the past week.

July 15, 2021

Please visit the CSWA Position Papers page to view the Position Paper on Voting Rights. 

May 14, 2021

Several members have pointed out the part of the CDC guidance that is aimed at health care providers:

“The guidance reiterates the need for health care providers to continue using personal protective equipment (PPE) in health care settings. Continuing to use telehealth strategies while maintaining high-quality patient care remains the prudent option in many circumstances.”

This guidance is likely to apply to hospitals and high-volume medical offices. In the typical LCSW office, LCSWs are vaccinated, patients are seen one at a time, waiting rooms and restrooms are often still not being used, HEPA filters are still being used in the office, and patients who are not vaccinated are not being seen in person. Under these circumstances, the risk of passing on COVID-19 by seeing patients in person who are vaccinated is low.

As noted in the previous post, LCSWs with weakened immune systems should continue to use masks and have patients do so as well, if patients are seen in person.

May 13, 2021

Today the Centers for Disease Control (CDC) announced new guidance on the use of masks indoors. This guidance has a direct impact on the way LCSWs practice psychotherapy.

The CDC now recommends that people who are fully vaccinated can meet indoors without wearing a mask or physical distancing. This is a relatively sudden shift from two weeks ago and is reflective of the increased level of vaccination that has occurred, About 117 million US citizens are now vaccinated and 154 million have received one vaccine dose. The recent expansion of vaccination for 12-15 year old children will further increase the number of citizens who are vaccinated. COVID-19 variants should be stopped by the vaccines available.

There is no mention of whether building air filtration systems or in office HEPA filters are useful. It may be a good idea to maintain the use of HEPA filters until herd immunity has been reached.

One factor that may lead to continued use of masks and physical distancing are for people who have immunosuppressed or weakened immune systems from organ transplants, cancer treatment or for other reasons. This of course applies to us as LCSWs as well as patients.

Let me know if you have any questions about the recent CDC guidance on protections against COVID-19.

- Laura W. Groshong, LICSW, CSWA Director of Policy and Practice

April 29, 2021

Many members have been asking questions about the Medicare coverage of telemental health. This is an important topic because most commercial insurers follow Medicare policies regarding coverage of telemental health, as well as other coverage issues.

Medicare has covered telemental health videoconferencing for our usual and customary psychotherapy codes since March, 2020, a major expansion of telehealth coverage. Medicare also agreed to cover audio only psychotherapy in April of 2020. Both were tied to the Public Health Emergency (PHE) being in effect. The PHE was extended in three month increments until April of 2021 when CMS announced that telemental health videoconferencing would be extended until the end of 2021. Audio only treatment would be covered as long as the PHE was in effect. See https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes for more information.

In other words, separation of telemental health videoconferencing and audio only coverage have been part of the expansion of psychotherapy coverage since the pandemic began. The current intention from the current administration is that the PHE continue through 2021, which would make the difference between the two delivery systems moot.

At this point, I believe that LCSWs can reasonably expect coverage of telemental health and audio only treatment to last through 2021. There are several bills in Congress which would make this policy permanent. Our Government Relations Committee is working hard to see one of these bills pass. Stay tuned.

- Laura W. Groshong, LICSW, CSWA Director of Policy and Practice

April 21, 2021

We at CSWA collectively breathed a sigh of relief yesterday as the guilty verdicts for ex-officer Derek Chauvin were read by the judge. We acknowledge the monumental task of the prosecution team, the on-going protests by people around the world, each sign posted on a lawn or in a window, each hashtag crying for justice for George Floyd. This decision, after years of police murders of Black and Brown people with no accountability, is one to celebrate. The guilty verdicts serve many purposes; they break the long-standing policy of acquittal for police who have murdered Black and Brown people. They affirm what was a matter of fact – that George Floyd’s life was taken without cause. They provide a way forward that is necessary in dismantling unjust, rogue policing that has created a justifiable mistrust in institutions we all should feel protected by.

CSWA stands in support of these verdicts. We consider it the duty of all citizens, and clinical social workers in particular, to repudiate institutionalized racism and support policies that further encourage police accountability. One such potential law is the George Floyd Justice in Policing Act of 2020 introduced in June, 2020, passed by the House last month. A summary of H.R. 7120 is listed below.

This bill addresses a wide range of policies and issues regarding policing practices and law enforcement accountability. It includes measures to increase accountability for law enforcement misconduct, to enhance transparency and data collection, and to eliminate discriminatory policing practices.

The bill facilitates federal enforcement of constitutional violations (e.g., excessive use of force) by state and local law enforcement. Among other things, it does the following:

H.R. 7120 would also create a national registry—the National Police Misconduct Registry—to compile data on complaints and records of police misconduct. It establishes a framework to prohibit racial profiling at the federal, state, and local levels.

Finally, H.R. 7120 establishes new requirements for law enforcement officers and agencies, including to report data on use-of-force incidents, to obtain training on implicit bias and racial profiling, and to wear body cameras. CSWA will be advocating for passage of this bill.

Today the Department of Justice has announced a full investigation of a “possible pattern of misconduct” of the Minneapolis Police department. CSWA welcomes this investigation and hopes it will be one step forward, with many more needed, in the fight for a socially and racially just America.

- Kendra Robeson, LICSW, CSWA President

April 20, 2021

The project sponsored by Department of Defense and Council of State Governments to create an interstate compact for clinical social workers is moving along. CSWA is one of the three main stakeholders. The formal kickoff will be on May 20 at 2 pm EDT. All CSWA members are invited to attend. This meeting is informational but will be helpful in giving an overview of how the project will move forward.

The event is free but you must register which you can do at https://csg-org.zoom.us/meeting/register/tZUqdOqqpz8jE9JjZpkwTn2_gHKIuCbtRmpN.

To see the original announcement of the event go to https://www.defense.gov/Newsroom/Releases/Release/Article/2537098/dod-receives-approval-for-grants-to-develop-interstate-compacts-for-licensure-p/

I hope to “see” you at this Zoom event. Let me know if you have any questions.

- Laura W. Groshong, LICSW, CSWA Director of Policy and Practice

April 16, 2021

Good news on the Medicare fee-for-service sequestration front! The 2% cut which was scheduled for April 14, 2021, has been suspended until December 31, 2021. See the announcement from CMS below:

The Coronavirus Aid, Relief, and Economic Security (CARES) Act suspended the sequestration payment adjustment percentage of 2% applied to all Medicare Fee-for-Service (FFS) claims from May 1 through December 31, 2020. The Consolidated Appropriations Act, 2021, extended the suspension period to March 31, 2021. An Act to Prevent Across-the-Board Direct Spending Cuts, and for Other Purposes, signed into law on April 14, 2021, extends the suspension period to December 31, 2021.

Medicare Administrative Contractors will:

For more information, go to https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2021-04-16-mlnc#_Toc69394754

Let me know if you have any questions.

- Laura Groshong, LICSW, CSWA Director of Policy and Practice

March 24, 2021

Today CSWA had its first meeting with members of the Council of State Governments, sponsored by the Department of Defense. For more information, see the original post sent on March 15.

The goal of building a compact for states that want to have reciprocity for clinical social workers was outlined. This project will take approximately 12-16 months to develop and will then be presented to the legislatures in the states and jurisdictions. Therefore, this project will require at least 2-3 years to be implemented.

CSWA is very pleased to have the support of DoD and CSG. We will keep you you apprised of the progress of the compact development.