Laura Groshong, LICSW, CSWA Director of Policy and Practice

Good news from CMS!  CMS announced on November 2, 2021, the first group of many rules regarding the Physician Fee Schedule, which CSWA, and many of you, GWSCSW members, commented on in August.  Our voices made a difference.  CMS will extend coverage of telemental health and audio-only psychotherapy until the end of 2023. 

CMS also changed the requirement that patients be seen in person from every six months to every 12 months starting in January of 2022.  CSWA will continue to get this restrictive and unnecessary rule eliminated.

The announcement from CMS on rules for telemental health raised some questions which I will answer below:

1. Does the new rule mean that LCSWs are able to freely use telemental health to see patients in states where we are not licensed? No. That is what CSWA is working on through the Compact.  All state restrictions about licensure still apply.  Check with the state social work Board if you wish to see a patient who resides in a state in which you are not licensed.  A few states still have relaxed reciprocity standards, but others are ending their willingness to extend the ability to practice without licensure.
2. Does the rule mean that private insurers will automatically agree to extended coverage of telemental health and audio-only psychotherapy? No. Private insurers often follow Medicare rules, but there is no guarantee.  There appeared to be some changes in the way that private insurers were going to cover telemental health before the rule was announced; the rule may affect those changes and others going forward.  Check with individual insurers or have patients check.
3. Does the state in which the patient resides still dictate the necessity of an LCSW to be licensed in their state to treat the patient? In general, yes.  Check with the state social work Board where the patient resides as noted in #1.
4. Will this rule cover Medicaid as well as Medicare? All Medicaid decisions will continue to be made by states. This rule may encourage some states to cover telemental health in Medicaid.
5. Will LCSWs still be required to see patients in person every six months as previously required? No, this requirement has now been changed to every 12 months.  CSWA will be working to eliminate this requirement as we did to eliminate the six month rule.

Thanks to everyone who participated in this effort.  Let me know if you have questions.

Contact: lwgroshong@clinicalsocialworkassociation.org