Clinical Social Work Association Announcements: All items

[Article Digests for Psychology & Social Work]

Clinical Social Work Association Announcements

 

(https://www.clinicalsocialworkassociation.org/Announcements/13235076) CSWA-NASW - Draft Clinical Social Work Standards - 7-29-23
Jul 29th 2023, 10:09

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) 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  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13226935) Social Work Compact Update - July 12, 2023
Jul 12th 2023, 14:27

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.

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=5bEk61dWwHgxP5G%2FjhU%2BWRHO26USf8FIfeROY8rdH0Y0TiPg3qSY%2FdmUGrnf10l3CgWlKpPy6FFjVsgLZRfur67ierRNqiqCzGo9DEDvM1w%3D) SB 670 was sponsored by Senator Travis Fitzpatrick and Senator Lauren Arthur, and (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=iHwu0bSzO9XhxYptDATzwnC7eWxeb%2FdnjBBpw8bzAN9HwcIM55WCTRtUslbK2ecsXBnNO%2FjaF74wQYkMR44EeoxDLY8wFPsuiycVPadmHXE%3D) 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/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=oMgRo2nlJAbKOi3bDzCYdSUgAZLSX4gKpe2pCe9jQY5jST26IcYMmoplJfL6F4L225DPeWuuX0mL7enJg28UMgspxb57R1P%2BYsDfTNDxz4I%3D) 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

(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13217988) Organizations that Offer Support for Trans People - 6/20/23
Jun 21st 2023, 09:10

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.

ACLU is one of the main organizations opposing bills to limit trans rights. Below is a link to an effort to protect a trans woman in prison in DC and a map that shows which states have the most bills to limit trans rights:

  (https://www.acludc.org/en/cases/hinton-v-district-columbia-challenging-department-corrections-policy-discriminatorily-housing) 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.aclu.org/legislative-attacks-on-lgbtq-rights

Them.us has an excellent list of 100 organizations in all 50 states that are fighting anti-trans rights:

  (https://www.them.us/story/orgs-fighting-back-anti-trans-legislation) https://www.them.us/story/orgs-fighting-back-anti-trans-legislation

Npr.org has a report on anti-trans legislation in sports:

  (https://www.npr.org/2022/11/28/1138396067/transgender-youth-bills-trans-sports) https://www.npr.org/2022/11/28/1138396067/transgender-youth-bills-trans-sports

Here and Now on NPR has a discussion of the impact of anti-trans campaigns on the mental health of trans youth in particular:

  (https://www.wbur.org/hereandnow/2023/06/16/anti-trans-laws-mental-health) https://www.wbur.org/hereandnow/2023/06/16/anti-trans-laws-mental-health

CNN has a graph showing the increase in anti-LGBT bills.  In 2018 there were 42 bills filed in state legislatures; in 2023 there were 412:

  (https://www.cnn.com/2023/04/06/politics/anti-lgbtq-plus-state-bill-rights-dg/index.html) https://www.cnn.com/2023/04/06/politics/anti-lgbtq-plus-state-bill-rights-dg/index.html

Here is a newly published article by Allan Barsky, PhD, that offers some ideas about the ethical responsibilities of clinical social workers to oppose anti-trans bills: 

  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) 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  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(mailto:lwgroshong at clinicalsocialworkassociation.org) 


(https://www.clinicalsocialworkassociation.org/Announcements/13212620) CSWA - Compact Lobbying Materials - 6-8-23
Jun 8th 2023, 12:28

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. 

Many thanks,

Laura Groshong, LICSW, CSWA Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/resources/Documents/CSWA%20-%20Background%20on%20SW%20Compact%20-%206-23%20final.pdf) Background on SW Compact 6-23

(https://www.clinicalsocialworkassociation.org/resources/Documents/CSWA%20-%20LCSW%20Compact%20-%20Lobbying%20-%206-23%20final.pdf) LCSW Compact - Lobbying 6-23
(https://www.clinicalsocialworkassociation.org/resources/Documents/CSWA%20-%20SW%20Compact%20-%20Bullet%20Page%20-%202023%20final.pdf) SW Compact - Bullet Page 2023

(https://www.clinicalsocialworkassociation.org/Announcements/13209613) Medicare In-Person Telemental Health Requirements - 6-2-23
Jun 2nd 2023, 08:07

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:

Monthly End-Stage Renal Disease (ESRD) visits for home dialysis.

  Services for diagnosis, evaluation, or treatment of symptoms of an acute stroke wherever you are, including in a mobile stroke unit.


Services to treat a substance use disorder or a co-occurring mental health disorder (sometimes called a "dual disorder"), or for the diagnosis, evaluation or treatment of a mental health disorder in your home. ((https://www.medicare.gov/coverage/telehealth) https://www.medicare.gov/coverage/telehealth)

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  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13206728) More Information on Coding and Practice after the End of PHE - 5-25-23
May 25th 2023, 15:50

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) 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 PracticeClinical Social Work Association(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13187172) CSWA - After PHE - Part2 - 5/1/23
May 1st 2023, 18:02

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) 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) 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) 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) 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) 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:Laura Groshong, LICSW, (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13150632) ASWB Exam - 3-23
Mar 30th 2023, 10:37

        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.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Xpd1QMTunSjfVY9Snxb6mAPmUlnVjnxdEeSERNrLew%2B1Z9oabxe%2FengD1iL1r15mEgtlUnB363UewvH3CIN88kbYpLww3VcA0H8q3LPo6Js%3D) 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:


Provide guidance to graduate programs: Develop clinical competencies for the social work community in graduate programs.


Aid in test preparation around skills and content: Develop options to provide low-cost or free test prep for members.


Increase access to clinical supervisors and mentors: Invite CSWA members to add their supervision credentials to their profiles to enable clinical social workers to find support for preparing to take the ASWB examination.


Provide targeted training: Prepare clinical social workers for the ASWB examination and specific subject matter areas key to clinical practice.


Increase CSWA Members' Internal Communication: Develop peer consultation communities (listservs, community forums, etc.) that are moderated by CSWA members.

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.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Xpd1QMTunSjfVY9Snxb6mAPmUlnVjnxdEeSERNrLew%2B1Z9oabxe%2FengD1iL1r15mEgtlUnB363UewvH3CIN88kbYpLww3VcA0H8q3LPo6Js%3D) 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(mailto:lwgroshong at clinicalsocialworkassociation.org) president at clinicalsocialworkassociation.org

        Laura Groshong, LICSW, CSWA Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13134039) Telemental Health Coverage when PHE Ends - 3-16-23
Mar 16th 2023, 12:05

Telemental Health Coverage after PHE Ends

Laura Groshong, LICSW, Director, Policy and Practice

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:

Coverage of Telemental Health – The Consolidated Appropriations Act of 2023 extended Medicare coverage of telemental health until December 31, 2024, which is good news. While most commercial insurers tend to follow CMS guidance, this time it appears that this may not be the case. Some insurers have already begun to limit telemental health coverage; this may increase after May 11. It is not too early to have patients check with their insurers about the likelihood that telemental health will be limited/no longer covered going forward.


Meeting In-Person – The CMS requirement that Medicare patients be seen in person at least once a year when the PHE ends has been delayed until December 31, 2024.


Audio-Only Telemental Health – CMS coverage of Medicare patients through audio-only telemental health will continue until December 31, 2024.

  If a patient’s insurer is planning to stop telemental health or audio only coverage in some way, it would be helpful to have patients talk to their HR person about keeping telemental health coverage in place. It may also be helpful to file a complaint with state insurance commissioners if insurers are unwilling to continue coverage of telemental health treatment.
There may be other questions that members have about the way that the end of the PHE will affect LCSW practices. Please let me know if you do.  For more information on these topics go to (https://telehealth.hhs.gov/providers/policy-changes-during-the-covid-19-public-health-emergency/policy-changes-after-the-covid-19-public-health-emergency#permanent-medicare-changes) https://telehealth.hhs.gov/providers/policy-changes-during-the-covid-19-public-health-emergency/policy-changes-after-the-covid-19-public-health-emergency#permanent-medicare-changes . CSWA will be tracking these changes for members.

(https://www.clinicalsocialworkassociation.org/Announcements/13121460) Update regarding Compact Web Links - 3-6-23
Mar 6th 2023, 12:17

We have become aware that the Compact webpage and associated links that were sent out to you on February 27th have not been working for everyone. The Council of State Governments (who is responsible for that website) is aware and has their technology team actively working on resolving the issue.

To assist those individuals having trouble loading the pages, we have downloaded the majority of the information from the Compact website to our own CSWA website. You can access that information (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=g72uB2NRtMscpllVF%2BNNFjWPuHcGgismvZZjH3hZ0ToMM13elJNTeMyq3VXxVZ9ZdbngVMQCfK1yQrnSEXWn%2B4jU8Wb%2BZfFuQHbgQOHv6kY%3D) HERE. Please check back and try the (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=7bF8ataFX6BsIhYazyrfVRttBJFEOaEGW7jXCYDl8yhF41MHp9KgNE8UFkuS8Cp3IbuAggDYADV4P%2BD2XPUCAt6%2BZcJcoBRM8mO9fs%2FIpxM%3D) Compact website when you get a chance, however, as some fixes have already been put in place by the Council of State Governments' team. 

(https://www.clinicalsocialworkassociation.org/Announcements/13112828) Social Work Compact - 2-27-23
Feb 27th 2023, 16:59

Here is the long awaited Social Work Compact Bill which will allow:

LCSWs to join the Compact, after their home state has joined the Compact;

  LCSWs to practice in all Compact states without becoming licensed there separately;

  LCSWs that join the Compact to essentially have a multistate license.

The Compact will not be operational until at least seven states’ legislative bodies have passed the Compact into law in their states. Once this happens, the Social Work Commission will be created to oversee the Compact and individual LCSWs can join.

This is the basic information that explains the Compact: (https://swcompact.org/) https://swcompact.org/

The actual language of the Social Work Compact Bill is here: (https://swcompact.org/wp-content/uploads/sites/30/2023/02/Social-Work-Licensure-Compact-Final.pdf) https://swcompact.org/wp-content/uploads/sites/30/2023/02/Social-Work-Licensure-Compact-Final.pdf OR (https://www.clinicalsocialworkassociation.org/resources/Documents/Social-Work-Licensure-Compact-Final.pdf) HERE. 

I will be sending lobbying suggestions shortly.

In states which have a session that is ending soon, the bill will probably have to wait until next year. Some states are ready to drop the bill today. We hope to reach the seven state threshold by next year.

Let me know if you have any questions.

Laura Groshong, LICSW, Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13097516) Remembering Margot - 2-2023
Feb 14th 2023, 12:56

        Remembering Margot - February 2023

        It is with great sadness that we announce that our long time Deputy Director of Policy and Practice, Margot Aronson, passed away on January 30. We are honored to have been a part of Margot's legacy and send our deepest condolences to her loving family and extensive network of friends. 

        Margot's family has requested that donations be made to her favorite charities in lieu of flowers. They are the (https://erinlevitas.org/) Erin Levitas Foundation, (https://savewright.org/) Frank Lloyd Wright Conservancy and (https://www.dcappleseed.org/) DC Appleseed Center.

        In Margot's honor, the Clinical Social Work Association has newly established the Margot Aronson Legislative Warrior Award. The recipient of this annual award will be given to someone from the State Societies who manifests the same kind of energy that Margot had for being an advocate for Social Justice and a leader in engaging legislative action. CSWA will award this honor every year at the Fall Summit for State Affiliates. 

        Please see below for two special tributes to Margot. 

        Margot Aronson: A Remembrance

        by Laura Groshong, LICSW, CSWA Director, Policy and Practice

        I first met Margot at the Clinical Social Work Federation meetings in 2004. She was President of the Greater Washington Society for Clinical Social Work and I was working on the CSWF Government Relations Committee. We were just getting to know each other when CSWF morphed into the Clinical Social Work Association in 2006; I was asked to lead the CSWA Government Relations Committee. Living in the “other” Washington, I quickly realized I would need someone in Washington DC to attend MHLG meetings, briefings, and other DC based events. Knowing that Margot had spent about 5 years doing advocacy for GWSCSW, I asked her if she would like to serve as my Deputy in DC. She quickly agreed and our partnership blossomed. We wrote papers together (she was a master editor), developed policy positions, lobbied together during my quarterly trips to DC, and often talked daily about the many issues we covered. We worked with about eight CSWA Presidents and created the Policy and Practice Committee where she also served as my Deputy.

        I loved Margot for many reasons, including the times my husband and I spent with her and her late beloved husband, Ed Levin. Losing Ed five years ago left a hole in Margot’s life that led to a deepening of our personal relationship. I encouraged her to get involved with PsiAN, a new organization in Chicago, where she joined the Board and became as indispensable to them as she was to me.

        I never gave up hope that Margot would recover when she started having health problems a year ago, but it was not to be. Her daughter Stephanie (a social worker) did a wonderful job taking care of her for the past year. Her son, Jeff, and other daughter, Ali, were also devoted to her.

        A light has gone out in the world, but I hope we all can recognize the incredible gifts that Margot brought to our field and the ways she made clinical social work stronger. I will miss her more than I can say.


        A Tribute to Margot Aronson

        by Judy Gallant, LCSW-C, GWSCSW Director of Legislation and Advocacy

        There are many people our Society is indebted to for our success in achieving legislative goals, but, sadly, we have lost one of our most committed, beloved and active members, Margot Aronson, who passed away on January 30, 2023, at the age of 81, after a year of coping with various illnesses.

        As several of our members have commented, she was “a force to be reckoned with.” From her ability to encourage, cajole and support members to become more active in the Society’s work, to her enthusiasm for progressive and social justice causes, and to the detailed work she would do to make sure Clinical Social Workers were included in Federal legislation, she was always able to move things along in the right direction.

        Margot’s experience growing up in New Jersey was the basis of her lifelong interest in and support of a group dedicated to Frank Lloyd Wright’s architecture. Her parents were teachers whose goal for their family was to live in a house built by Wright. Now called “The Richardson House,” it is a “Usonian” house. These homes were built for the working class, with the goal of building affordable, functional homes for those with more limited budgets. Margot’s mother and father wrote to Frank Lloyd Wright with their wishes, and they collaborated with him to get the home built.

        After attending college in NY, Margot worked for a number of years with the Peace Corps and treasured those experiences, including editing their magazine at the time. This helped her feel comfortable with taking on her first major role in our Society, editor of our newsletter.

        After marrying and starting a family, she eventually found her way to Social Work, graduating with a Master’s degree from the University of Maryland’s School of Social Work. She worked for many years with children, adolescents and their families at the Regional Institute for Children and Adolescents (RICA) in Montgomery County, MD. She also joined GWSCSW, where in addition to being our newsletter editor, she became President (2002-2005), and Vice President for Legislation and Advocacy (currently named Director of L&A).

        It was in this last role that Margot tapped on my shoulder and drew me in to working on our MD Legislation and Advocacy Committee. We drove to Annapolis together countless times, thought through strategies to accomplish our goals, and discussed how best to write testimony together with our lobbyist at the time, Alice Neily Mutch. I learned that I could actually talk to legislators (they are people!), as well as provide testimony in committee hearings. I was nervous, but Margot was a calming, informative, and for me, a necessary presence.

        When Margot became more involved with CSWA, becoming the Deputy Director for Policy and Practice, she and then-President Nancy Harrington asked that I step into the role of Director of L&A. I did so and continued to consult with Margot for her sage advice and experience, which was vast.

        Margot would do things like sit with a Congressional bill for several days, painstakingly marking up the bill in every place where a Clinical Social Worker should have been included (It passed in that form). In 2014, along with Janice Berry Edwards and Eileen Dumbo, Margot organized a “Training for Cultural Competency: A Colloquium for Social Work Educators.” Along with her other accomplishments, Margot pulled people in to collaborate and form coalitions to get things done.

        She also shared other parts of her life, including her and her husband at that time, Ed Levin’s, involvement in the DC Appleseed Center for Law and Justice. Ed, along with Ralph Nader, was a founding member of the national Appleseed network. Margot and Ed were strong supporters of the DC Center and their efforts to make DC a better place to live, including supporting DC statehood, and providing pro bono legal assistance to achieve many of their goals.

        Margot’s support of the DC Appleseed Center for Law and Justice, as well as her family raising her in a Frank Lloyd Wright Usonian house, were of importance to her. They show an overarching theme in her growth and thinking about social justice from exposure to those ideas even at an early age. Margot was a many-faceted, strong, and principled woman, a staunch friend, a “woman of valor.” She was formally recognized as such in different ways, for example, as the NASW Social Work Advocate of the Year and as the first recipient of the GWSCSW Frances Thomas Award for Legislative Excellence. I will always carry her with me, treasuring her principles, joie de vivre and her love.

(https://www.clinicalsocialworkassociation.org/Announcements/13095070) Questions and Answers about the Social Work Compact - 2-13-2023
Feb 13th 2023, 09:11

Questions and Answers about the Compact

February 13, 2023

Laura Groshong, LICSW, Director, Policy and Practice

The information about the Compact development has led to a number of questions which I will try to answer here. However, there are some basic misunderstandings about the way that CSWA functions which need to be clarified first.

The Clinical Social Work Association is an independent membership organization; to have access to staff and the materials that CSWA has created, LCSWs need to join CSWA. State Societies are affiliated with CSWA and receive some materials for all their members, even those who are not CSWA members. This causes some confusion because being a member of a state Society does not mean you are a member of CSWA. You can join CSWA if you are a member of a State Society for a reduced rate at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=7oiedgEdFb5OpHjy%2BxxYHCE16INwX7YnUPRxX1M7cahM2zBpmzkzLNccg0hLs4ZhiPXUN%2BV%2BFsZh0znRkgXR5cnKGeeH1mFw%2FRIpvAbB%2FB4%3D) www.clinicalsocialworkassociation.org. You can also join CSWA as an individual member if you are not a member of a State Society. This underlying structure is one that has been hard to grasp at times. I hope this clears it up. Now on to the questions that have been raised by the Compact information.

Compact Questions and Answers

CSWA members who reached out to me had mixed emotions about the outcome of the Compact meetings this week. In general, the outcomes were consistent with the goals that CSWA has explained to members for the past year and a half during the development of the Compact. Please review the information on the CSWA website for more background on how CSWA has worked to implement the Compact during this time.

One important piece of information is that NO STATE OR JURISDICTION belongs to the Compact yet. We are in about step three of a process that has many more to go and will require up to two years to accomplish. We will need seven individual states/jurisdictions to sign on before we can begin the process of establishing a Commission to oversee the Compact. Thus, we will need everyone’s help to get the Compact passed in as many states as possible and eventually in each state/jurisdiction. Once the final language of the Compact bill is available on February 27, CSWA will be explain how to advocate for the Compact in your state/jurisdiction.

In no particular order, here are the questions that have come in about the Compact and answers to them:

How would we know if our state legislature is interested in pursuing the compact? Do you reach out to legislators or should we? I’m in Florida. When the final draft of the Compact bill comes out on February 27, I will send it to all CSWA members with instructions on how to advocate to your legislators to create a bill and pass it in your state.


Any idea how much the fee for social workers will be? The fees will be determined by the Commission.


My question is around the licensed home state issue as I was initially licensed in Delaware in 2018, but in 2021 moved to Georgia. Would my move impact my ability to be a part of the compact? I still have an office in Delaware, would that count? You will only be able to have one home state for purposes of the Compact; your home state must be the state in which you are licensed AND the state in which you reside.


I have been able to obtain an LCSW licensing in Georgia and Louisiana but would like the opportunity to work in other states as a client moves but would like to maintain the relationship. Your ability to do so will depend on which states join the Compact.


Do you know which states are planning on joining? Can you get the multistate approval if your state is not joining? You can only join the Compact if your home state joins.


Do PhD's have to sit for an exam? That depends on your state laws. No one who became licensed without taking the exam will have to take it to join the Compact, if the LCSW has no actional complaints.


I received my MSW in 1984. When ASWB came up with its exam, I was grandfathered in. After 39 years of clinical practice, am I understanding the above memo to say that in order to join the Compact, I would now have to take the ASWB exam? The language of the bill says that those who were grandfathered into licensure and have no actionable complaints do not have to take the ASWB exam now.


While it's hard to say as we haven't seen final language yet  and are unsure whether Illinois will even be eligible to join the Compact, we join the national NASW office in not supporting the Compact so long as it continues to codify the ASWB exam. There was much discussion about whether states that do not have licensure and/or an exam requirement at the BSW or new MSW levels will be able to join the Compact. The final decision was that it will be optional for each state to offer the ASWB exam at these levels for those who wish to join the Compact, even if the state does not require the exams and/or licensure at these levels. 


It sounds like having already completed the clinical licensing exam for your state of residence is not going to be enough to qualify for participation in the Compact, and that those of us who are already clinically licensed in our state will need to take the ASWB exam. See #7. You will not have to take the exam if you were licensed without taking it.


I am an acquaintance of my State Senator. What do I need to do to move this compact forward to her? I just sent her a message on Facebook. Do you have a list of the states that are currently included in the Compact? Do you have information about Michigan specifically? No states are currently in the Compact as the language for state legislators is not available yet. All these questions will be answered when the final language comes out on February 27, along with guidance on how to make legislators aware of the Compact.


I am glad about the progress with the Compact but very disappointed about the requirement of the ASWB exam. I passed the NY CSW exam in 1982. I was later grandfathered into the licensure when it became available in 1991 in NJ. I have been actively practicing since with advanced qualifications. There has been a lot of confusion about this issue. See #7 and #10.


What to do about differing standards of care. A member state might forbid a clinician from discussing abortion or a member state might require a clinician to provide conversion therapy to queer folks. The conveners simply ignored the concerns and I haven’t heard a thing about that since. I hope this has been worked out—does anyone have new information on this topic? The language of the Compact deliberately says nothing about state laws and regulations or scopes of practice. These are left to the states, though they may be problematic.


I have been following all of these but not closely. The most recent email talks about a possible requirement that people would have to have taken or take the national exam or demonstrate competency. I am wondering what ways one could demonstrate competency. See answers to #7, #10, and #11.

ASWB Report

ASWB has put out a report on the ways that they intend to correct the disparities in the pass rates for the exams. See below for their update, or find it on their website at this link: (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=F2Bt9juP2EfIYr9%2BvnqIG6o35JmYZ63OSLhY42pZxuL2jpNIYVCRjU0bS0%2Ber9H402CSripQCGvz40r7E7MkUrHCdrnOmlPcIvrbczeIMz8%3D) https://www.aswb.org/aswb-social-work-examination-update/

As we enter 2023, the Association of Social Work Boards wants to provide an update on our social work licensing examinations. Last year, we took the groundbreaking step of publishing the national, state, and school exam pass rate data to contribute to and lead engagement in profession-wide conversations around diversity, equity, and inclusion.

The data highlighted disparities in exam pass rates for different demographic groups. For Black test-takers and older test-takers, pass rates were particularly low. The discrepancies seen in the data are unacceptable. Recognizing that multiple factors impact a test-taker’s performance and need to be addressed, we remain committed to doing our part and working with other members of the social work community to address the societal inequities that are reflected in the pass rate differences.

We are actively exploring the causes of these gaps with educators and practitioners and are already taking action to better prepare all social workers for licensed practice while continuing to support our members—social work regulators—with their public protection mandate.

We welcome the chance to share our latest efforts with the profession. The initiatives outlined below build on our previously communicated pledge to include a (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=HY5mJL1AXSyfaLz9oHr8Ryv%2F651PfSwJ0m8rIw1x3w7BJTLsku39%2B0ggDwFpRvyeQBATOYe0azo1VFF3zOST6LvT41L4di0NkEp8zbBFJzE%3D) more diverse set of voices in our exam development process and recent efforts to (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=yjdiS4UFo1%2FCswSYzC6dJfoaJXYcEvlLkmFSQhHgqCNw0KqKAxaW9%2FBeGHiwC53J4QyeCKlpOIMcRgyy9kOCvJfRyE7cfMWqXhMwJqC3Z%2F4%3D) provide support and resources for educators and supervisors as they prepare licensing candidates.

ASWB is taking seriously the feedback we have received from the social work community and is committed to continue listening. ASWB has engaged (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=wwNyQiWsSFzMvVidGHr%2FO6NHODovl0qMpyAIt9tBoGurNuxLQjyDevfbHSxYmdlC%2BOah7b5%2Bwm3pZp%2F4Ukw392AboZCKHHy67ngfqRiBMOI%3D) HumRRO, an independent nonprofit research and consulting firm, to collaborate with community partners in facilitating inclusive and productive conversations about the social work licensing exams. This (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=wv%2B8ycsVBWuksSF0FebSsT3msTGTk%2BVPus5ebNb3NdRxwvbJKITcPdGpE1vXwiBvxyhOKFIjqA%2F%2Bx3q7iMWcS7YUn%2B1Nl8TEZT4QgOTSRGQ%3D) series of community conversations launched in January and will continue through May. The sessions are designed to gather information to be used as we develop exams for the future of social work. For anyone not able to participate in a session, we are also offering a self-paced online survey to gather additional feedback and ensure the largest possible number of voices can be heard.

We are also exploring additional or alternative assessments, in line with our (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=ryR%2FhKeFnUw5mZs8p7c%2BzhqU6UQvNdlbsu5Sv47fWGftjGRs5qnj4cUvGa8jV5jTRUJHPUU51VPi30OX9VryB9rcWygK%2FXdravQbdPb9U88%3D) strategic framework. As we re-envision competence assessment, we are looking at ways that candidates can demonstrate competence beyond the use of a multiple-choice examination format. We are carefully weighing the feasibility of numerous assessment options. Our primary concern is to ensure the validity and reliability of any assessment format we choose; however, we are also reviewing the impacts of changes on test-taker well-being and the potential for cost increases for test-takers. We anticipate that qualitative data gleaned from the community conversations will influence decision making.

In addition, we are (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=PuGsfxaWQRpVXzCdaQpdevqVae%2FbGsYyR%2BIh9pxEDNyg%2BHELXm6yxTmMSUQvZ4%2BP1a9JYOzC9g8hv7n5vpiLoKhI%2BvRiC%2FRbqs46IWuNZWM%3D) continuously reviewing our exam administrative policies and procedures. We are considering, for example, the possibility of offering secure, remote proctoring of examinations. As each possibility is explored and measured, the goal of keeping the exam fair and accessible for all will remain at the forefront.

Finally, we will (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=s6paKd%2FkZdfbw%2ByvXdeZhwzbC7IzXNMECnuJmt6jKfGVA3%2Bd1N%2B0Dqu327%2FCik5hn4kBoorHFXbY2xQKdtUJELPL0Nzn8BNH2iKcDz%2B%2BDzo%3D) issue a call for proposals for third-party research in March. ASWB will provide data sets and limited funding for approved proposals through its research arm, the American Foundation for Research and Consumer Education in Social Work Regulation. ASWB has committed to investing in this important work. Areas that would benefit from research include exploring how the professional standard of competency is defined and measured and gaining a more complete understanding of pipeline variables that account for differences in pass rates.

While these important research initiatives are underway, ASWB is continually evaluating other ways of supporting test-takers that are appropriate to our work as stewards of a professional competency assessment program. In January, we began (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=LtRJ3bmt0rvYlMcmoYHn8j84aGjawup2KCPfyoid8%2Bx%2BzNQ0YYpZG8vvvMD%2BRCfjb9yNKecTjVl5oZ%2FRvr5QzAIUrYoh8eaTS%2BZGQzduB3w%3D) piloting a free test mastery program for test-takers who did not pass the social work licensing exams. We have engaged Fifth Theory, an independent firm with expertise in helping individuals understand and develop the test mastery mindset required to succeed on high-stakes exams. Rather than teaching specific exam content, Fifth Theory provides tools that strengthen general skills needed to pass important exams, like anxiety reduction and preparation strategies. ASWB will solicit feedback from users during this pilot phase of the initiative.
We look forward to more collective conversations and action in the future. Look for updates on (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Rx2zwge2HfKElyDNYQ1dpCnm534VD%2BdwEo7e45AGFlw3TJpqZms%2FKbN84nPbRp%2BzOrYob5%2BnFVIB4sztKmSmGGxtgFmkWO4w6rM3bGDlSsk%3D) aswb.org.


(https://www.clinicalsocialworkassociation.org/Announcements/13091068) Expanded Summary of Compact Meetings - 2-9-23
Feb 9th 2023, 10:28

Summary of Compact Technical Assistance Group Meetings

February 7-8, 2023

Laura Groshong, LICSW, CSWA Director, Policy and Practice

 

Kendra Roberson, CSWA President, and I attended 12 hours of meetings about the Social Work Compact sponsored by the Council of State Governments (CSG) this week. We are part of the Technical Assistance Group (TAG) which has been working to develop the Compact language for the past 18 months. There were 20 TAG members with representatives from major social work and clinical social work organizations at these meetings.

There has been general agreement that the benefit of the Compact would be to allow LCSWs, licensed new MSWs, and licensed BSWs (in states where they are licensed) to work across state lines in any state that joins the Compact. Nurses, physicians, counselors, and about 10 other professions have already set up Compacts, sponsored by CSG. Funding is provided by the Department of Defense which started the project to give military spouses the ability to work in multiple states; they have now expanded this option to all licensed social workers whose home state is a member of the Compact.

Examinations

One of the main topics under discussion at these meetings was the requirement that all licensees have passed a national examination or other demonstration that they have met competencies for their licensure level’s scope of practice. Currently the only way these criteria can be met is by taking the ASWB examination. There has been great concern by CSWA and other groups about the ASWB report issued in August of 2022 which showed disparities in pass rates between white applicants and BIPOC applicants; older applicants; and applicants who had English as a second language. There were several ASWB representatives at the meetings who outlined what ASWB is doing to remove these existing disparities which are:

They have hired an organization called Fifth Theory which will help any applicant who fails an examination improve their test taking skills

  They are planning to continue to gather detailed data to assess whether the disparity gap closes, and to release this data every year

  They are considering allowing applicants to only retake the parts of the examination that they have failed

  They are reducing multiple choice questions from 4 to 3 choices to decrease test taker fatigue and burden (see their website for details on this)

  They will continue to engage in Practice Analysis

  They will create an RFP to conduct research on their data, relative to the pass/fail rates

  They may make the examinations optional for new MSWs and BSWs who wish to join the Compact

The TAG was somewhat pleased by these changes, but felt more information is necessary to determine whether they will resolve the disparities.

 

Oversight of the Compact

All Compacts are run by a Commission which is created when seven states have passed the Compact into law. The Commission will have nothing to do with defining scopes of practice or changing any existing state laws and regulations. There will be one representative from each state that joins the Compact and four ex officio members from national social work associations and regulatory bodies. Many of the details of running the Commission will be developed by the Commission when the Commission is created.

There will be a fee for states to join the Compact. There will also be a fee for individual LCSWs (and other licensees) to join the Compact.  Every LCSW must have a home state, which is also the state in which the LCSW resides. One of the requirements for a state joining the Compact is that they accept the language of the Compact as developed. One of the most helpful items is that if an LCSW moves from one state in the Compact to another state in the Compact, they will automatically be licensed in the new state.

 

Next Steps

The language for the Compact will be available on February 27, 2023. While this may be too late for most 2023 legislative sessions, it should be possible to reach the seven state threshold by 2024.

I will be sending information about how to lobby your state legislatures in the next two weeks. CSWA will provide guidance as the process moves forward. We know there is a lot of interest in making the Social Work Compact ‘real’ and have made state passage a priority.Please let me know if you have any questions about the meetings or the passage of the Compact in your state.

(https://www.clinicalsocialworkassociation.org/Announcements/13090201) Social Work Compact Statement - 2-8-23
Feb 8th 2023, 16:45

After a successful meeting with the Social Work Compact Document Team and Technical Assistance Group, CSG and partners are proud to share that compact language will be finalized and ready for state enactment by February 27, 2023. The compact must be enacted into state law by at least seven states. Once the Social Work Compact Commission and additional infrastructure is established, multistate licenses will begin to be issued. If your state legislature is interested in pursuing the compact this legislative session or would like additional information, please contact (mailto:socialworkcompact at csg.org) socialworkcompact at csg.org  or (mailto:matthew.shafer at csg.org) matthew.shafer at csg.org. 

Pictured here are most of the members of the Technical Assistance Group, including our own Director of Policy & Practice, Laura Groshong, bottom right. TAG members include national social worker organizations, State regulators, CSG staff and counsel.

(https://www.clinicalsocialworkassociation.org/Announcements/13082275) The End of CareDash
Feb 2nd 2023, 10:27

The End of CareDash

February 2, 2022

Laura Groshong, LICSW, Director Policy ad Practice

As you will recall, last August there was an attempt by a company called CareDash, in connection with BetterHelp, that co-opted our practices by getting all our NPI numbers and sending potential patients to clinicians that were on the CareDash panel and directing them away from any clinician that was not on their panel. Their information was incorrect and harmful to many CSWA members.

As a result of CSWA’s immediate response, and those of other mental health organizations, BetterHelp removed its name from the project and CareDash changed the most egregious procedures they had in place.  CSWA talked with Bloomberg News and sent information to numerous news outlets. Our members sent hundreds of Legislative Alerts to members of Congress and state legislators. Many of our members also filed complaints with the Attorneys General in their state. CSWA spoke with the Federal Trade Commission about the threat this represented to our practices.

Yesterday it was announced that CareDash and the company which ran it, NuFit, Inc., have ceased operation. CareDash and NuFit no longer have websites. We thank all members who participated in this effort and hope it will serve as a warning to other companies who attempt to take over our practices.

(https://www.clinicalsocialworkassociation.org/Announcements/13081320) The End of the Public Health Emergency: Impact on LCSWs Providing Telemental Health
Feb 1st 2023, 14:48

Implications of the End of the Public Health Emergency For LCSWs providing Telemental Health and Our Patients

February 1, 2022

Laura Groshong, LICSW, Director of Policy and Practice

As you have no doubt heard, the Public Health Emergency (PHE) will end on May 11, 2023. Continued coverage for telemental health treatment may depend on the insurance your patient holds when the PHE ends. Here is what we know currently.

Federal Government

CMS, which oversees Medicare and Medicare Advantage, has already announced that these programs will cover telemental health through December 31, 2024. CMS is reviewing the use of telemental health treatment and will make a decision, along with DHHS, about the future of expanded telemental health coverage after the end of 2024.

Some members of Congress are wanting to end the PHE immediately. The Senate and the President will not agree to this, so it is extremely unlikely that this will happen. Regardless, it will not affect the coverage of telemental health by Medicare and Medicare Advantage at this time.

Medicaid

All 50 states and DC expanded coverage and/or access to telehealth services in Medicaid during the PHE. When the PHE ends, coverage for telehealth services may be tied to federal and/or state PHEs. Most states have made, or plan to make, some Medicaid telehealth flexibilities permanent. 

Commercial Insurers

It is likely that some commercial insurers will no longer cover telemental health after May 11, 2023. I have heard that LCSWs have been told that telemental health will no longer be covered by commercial insurers NOW. Those companies should be reported to your Insurance Commissioner. As long as the PHE is in effect, telemental health should be covered.

Communication about commercial insurance has been spotty, so have patients check with their insurers. Some states, but not all, are putting laws into effect that will require commercial insurers to cover telemental health treatment.

Free Vaccines and COVID-19 Tests

Separate from the coverage of telemental health, the end of the PHE creates changes about who may receive free vaccines and COVID-19 test kits. A good summary of the changes that are coming has been put together by Kaiser Family Foundation at (https://www.kff.org/coronavirus-covid-19/issue-brief/what-happens-when-covid-19-emergency-declarations-end-implications-for-coverage-costs-and-access/#coverage-costs-and-payment) https://www.kff.org/coronavirus-covid-19/issue-brief/what-happens-when-covid-19-emergency-declarations-end-implications-for-coverage-costs-and-access/#coverage-costs-and-payment .

The Possible Impact on LCSWs

Many of us have converted our practices to exclusively provide telemental health and some us no longer have physical offices. The end of the PHE may require us to reconsider these decisions if telemental health does not continue in the way that we have been using it.

There is a lot of uncertainty at the moment, and CSWA will do our best to give you timely and accurate information about the situation.

(https://www.clinicalsocialworkassociation.org/Announcements/13075590) Update on Compact - 1-27-23
Jan 27th 2023, 15:09

Update - Social Work Interstate Compact

January 2023

Laura Groshong, LICSW, CSWA Director of Policy and Practice

Judy Gallant, LICSW, CSWA Deputy Director of Policy and Practice

As most of you know, CSWA has been working for over 2 years on a project funded by the Department of Defense and led by the Council of State Governments to develop the Interstate Compact for Social Workers for occupational licensing portability. Representatives from CSWA, NASW and ASWB have been working with the National Center for Interstate Compacts (part of the Council of State Governments) on the framework and language for a Compact to be put into place.

One question that has come up frequently is which levels of social work practice will be covered by the Compact. The answer is that all forms of licensed social work practice will be eligible to join the Compact, i.e., licensed clinical social work; licensed associate social work; and licensed bachelor social work practice. The only way a licensed social worker will be eligible to work through the Compact is to abide by the scope of practice established in the Compact language. For clinical social workers this means having met the standards for clinical social work licensure in their home state.

Another question that has come up often is whether LCSWs who have not taken the ASWB Clinical Examination will be able to join the Compact. If an LCSW was grandparented into licensure in their home state without taking the Examination, they do not need to take the examination to join the Compact.

The Compact, once finalized, will be distributed to stakeholders in each state and a campaign started to inform state legislatures and Boards of Social Work about the compact. The Compact will need to become law in at least 7 states in order for Social Workers to be able to participate in states that agree to accept it. Once we have a finalized document, we will also be informing you, our members, how you can best help advocate for this to be enacted within your state.

Unfortunately, even though we were expecting the Compact to be finalized by the beginning of 2023, this has not yet happened. Kendra Roberson, PhD, CSWA President, and Laura Groshong, LICSW, CSWA Director of Policy and Practice, along with others who have been working in the Technical Assistance Group, will be attending a meeting in DC in early February in order to finalize the Compact language. We are hopeful that the Compact will be sent to all states and jurisdictions shortly after that.

Because many state legislatures meet for limited amounts of time, frequently at the beginning of each year, it is unlikely that legislatures will be able to approve the Compact within 2023. It is more likely that legislatures will be considering, and hopefully, voting the Compact into law, in 2024. Once at least seven states have voted to approve the Compact, a Commission will be formed for the administration of the Compact. After the Commission is formed, additional states can still join the Compact.Although this is not the timeline we would have hoped for, the compact is slowly but surely moving in the right direction. CSWA will update you as we get more information.

(https://www.clinicalsocialworkassociation.org/Announcements/13056160) Legislative Updates – 1-13-23
Jan 13th 2023, 12:57

There are two issues which have been causing some confusion in the past couple of weeks that I would like to clear up:

Compact Delay – as you know, the Social Work Compact, which would allow LCSWs to practice in any state that joins the Compact, has been in development since October of 2021. CSWA President, Kendra Roberson, and I are members of the Technical Assistance Group (TAG) which has provided information about what the Compact should look like, along with representatives from other clinical social work and social work organizations. The process is being overseen by the Department of Defense and Council of State Governments. DoD and CSG had told us that the document, which will be submitted as bills to state legislatures, would be ready at the end of 2022. Unfortunately for several reasons, that deadline could not be met. Correspondingly, Kendra Roberson and I will be attending a meeting in Washington, DC in early February to finalize the document. We are hopeful that the document will be ready by early spring and will keep you posted on how to support the compact in your state legislatures when it is ready. CSWA knows how many members are looking forward to the Compact, as is CSWA.


Medicare Rules – there are two issues regarding new Medicare rules that have caused confusion. First, the need for in-person meetings with patients will not be put in place until 151 days AFTER the end of the Public Health Emergency. With many regions seeing increases in COVID and other viruses at this time, it is unlikely that the PHE will end any time soon. Second, the ability to see Medicare beneficiaries across state lines will not be in place until the end of the PHE as well. Please keep this in mind.  We are all looking forward to the ability to work across state lines. CSWA will let you know when that becomes a reality.

Please let me know if you have any questions on these issues.

Laura Groshong, LICSW, Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13034565) UPDATE - Medicare Coverage and MORE - 12-23-22
Dec 23rd 2022, 19:18

UPDATE: Medicare Coverage and Parity Changes for LCSWS

There continue to be questions about the change to Medicare policy about treating patients across state lines. Different regions have different policies in this regard. Look at the section in yellow below and call your MAC to get information about a region you wish to practice in. Here is more detailed information on the telehealth changes: (https://telehealth.hhs.gov/providers/billing-and-reimbursement/medicare-payment-policies-during-covid-19/) https://telehealth.hhs.gov/providers/billing-and-reimbursement/medicare-payment-policies-during-covid-19/

Telehealth Policy Changes

The federal government announced a (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=ZRmFoILNvo4FYnumhj0NZY1cnxPyvnKf3yPzQYDdR7FIff4fOa9eM9L5y6aZp9DRbOQFkNOkJJxCoa8WCXoN3LALY72ulVVjAZNYfr0ZvWg%3D) series of policy changes that broaden Medicare coverage for telehealth during the COVID-19 public health emergency.

Some important changes to Medicare telehealth coverage and reimbursement during this period include:

Location: No geographic restrictions for patients or providers

  Eligible providers: All health care providers who are eligible to bill Medicare can bill for telehealth services, including Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)

  Eligible services: See the (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=b2kXcWPL3RRWn%2FHQPUivsGrvD8ls92xWBjCVgdJ1kdNxzEo%2Bl3MGTY8i62wWEO3BfXnZjoOM2oXiI0FutPBS90nbtWS%2B0%2BFPIbSw%2BS829z8%3D) list of telehealth services from the Centers for Medicare & Medicaid Services

  Cost-sharing: Providers can reduce or waive patient cost-sharing (copayments and deductibles) for telehealth visits


Licensing: Providers can furnish services outside their state of enrollment. For questions about new enrollment flexibilities, or to enroll for temporary billing privileges, use this list of (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=q%2FeJQwhRJrAMkqs0Q68MeCKmpJmtlQJ%2BxQplW6DzjKOxtqiAH1fnKvj%2B6wTzF4Ak7oPyX0o0Xtjf2Ys%2Bz9tHAjGh120bdzX8lWPD8rHK8lc%3D) Medicare Administrative Contractors (MACs) to call the hotline for your area

  Modality: The 2022 Physician Fee Schedule has codified the ability for behavior health services to do audio only. It is still required to complete an in-person appointment every 6 months.

Mental Health Parity

There is one more piece of good news in the omnibus bill. You may recall that when the parity act passed in 2008 there was a loophole that allowed public plans to opt out of having a mental health benefit at all. That meant that they did not have to have a benefit AT PARITY with medical/surgical benefits. That loophole has been closed in the omnibus bill. This means a million more people will have mandated mental health treatment. More information can be found at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=%2FmGG4pFVy%2FtxXA8Ev1plLRSOX2Bfya8WhMQA8hFwbpstQBTvSA85MqDfHtiUEg0hp0EEme%2FLn6kxHZuNMN875GH28eitflNnUmxFFzubHwg%3D) https://www.thekennedyforum.org/blog/these-major-employers-have-opted-out-of-providing-adequate-mental-health-addiction-coverage/

H.R. 432, Mental Health Access Improvement Act

The Mental Health Access Improvement Act passed as part of the omnibus bill. This means that LMFTs and LPCs are now Medicare providers. Their reimbursement rates will be 75% of psychologist rates, like LCSWs, or 80% of their usual and customary rates, whichever is less. This is possibly more than what LCSWs are paid and CSWA will be looking into keeping LCSWs at the same reimbursement level.

These changes were passed by the House this morning so the President should be signing the bill shortly.

Happy Holidays!

Laura Groshong, LICSW, Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13032157) Medicare in $1.7 Trillion Spending Bill – Effect on LCSWs - 12-21-22
Dec 21st 2022, 10:52

Congress just passed a $1.7 trillion spending bill which has some impact on LCSWs through Medicare coverage. Now it is up to the President to sign it. Here are the ways that our practices will be affected if all these changes take place on January 1, 2023:


Medicare Rates – We had anticipated a 4.5% cut to Medicare reimbursement in 2023 and instead, this cut was 2%. It is better than expected. We will continue to advocate for a change to the RVU that determines what LCSWs are paid through Medicare, which is currently 25% less than what psychologists and psychiatrists are reimbursed for the same psychotherapy codes we use.


Telemental Health Extension – Coverage of telemental health was supposed to end 151 days after the end of the Public Health Emergency. There is a new extension of telemental health (and all health care) until Dec. 31, 2024. This is a positive development which increases the likelihood that telemental health will be made permanent.


Practicing Across State Lines – There is a provision that ends the requirement that providers be licensed in the same state as the patient receiving care, allowing more types of practitioners to provide telemental health services, including audio-only services.  This change is one that CSWA has been advocating strongly for and hopes will remain in place.


Delay In-Person Requirement – There is a delay in the requirement to see patients in-person via telehealth. The previous requirement had been that patients would have to be seen 6 months or 12 months every year in-person. For the foreseeable future, there is no need to see patients in person that are being seen virtually.


Telemental Health Services in FQHCs and RHCs - The bill would also extend telemental health services through 2024 for federally qualified health clinics and rural health clinics.

This two-year extension is not without future implications. The bill instructs the Secretary of Health and Human Services to study how telehealth has affected Medicare beneficiaries’ overall health outcomes and whether there are geographic differences in use. It also calls for a review of medical claims data. The initial report is due by Oct. 1, 2024. 

One more item – the Good Faith Estimate is supposed to be given to patients every year so look at when you gave your patients their first GFE and prepare to repeat the process.

Please let me know if you have any questions about these changes.

Laura Groshong, LICSW, Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

UPDATE: The rule addressing working across state lines is for LCSWs who are Medicare paneled and working with Medicare beneficiaries. This does not apply to LCSWs who are opted out, or not opted in or out. The rule does not apply to commercial insurers. 

(https://www.clinicalsocialworkassociation.org/Announcements/13028777) Medicare Coverage Follow-up - 2023 - 12-17-22
Dec 17th 2022, 14:53

CSWA would like to clarify information about the rules that CMS and Congress will be putting into place when clinicians provide telemental health treatment under Medicare when the Public Health Emergency ends.

No one knows when the Public Health Emergency (PHE) will end.  When it does, the following rules go into effect 151 days after the PHE ends.

Until 151 days after the PHE ends, you do not need to see anyone in person in order to provide telemental health treatment. After that time, CMS Guidelines require that you see a new patient one time in person before beginning to see that patient virtually. After that, you will need to see the patient in person once a year.

  For patients you already see through telemental health treatment, you need to have seen them at least once in person within the past 6 months in order to continue seeing them virtually. If you have not seen them in person within the past 6 months, you will need to do so the first time you see them when the rules go into effect. After that initial in person session, you will need to see them again in person at least once per year.

While there is no requirement that the rules will apply to commercial insurers, they often follow the Medicare rules. At this time, there are no insurers who have said they will require the above rules.

Some of us no longer have a physical office anymore, are concerned about getting COVID, or want to avoid in-person meetings for other reasons. CSWA is working with the (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Har36Gyr%2BM5vyAFnhhwKp8QwWZLQDduo5Ph975TOb4G1rcF5V1fZxqZq2xqT1ZrsFxZ9VvwoUgC5bsSfoPR1X8TlV9VyixJtUYsQhTUvx8c%3D) Mental Health Liaison Group (MHLG) and Congress to eliminate the requirement to see patients in person.

In short, there is no need to see patients in person currently. CSWA will let members know when or if this requirement goes into effect.

Happy holidays,

Laura Groshong, LICSW, Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/13027855) Medicare Coverage - 2023 - 12-16-22
Dec 16th 2022, 11:00

LIST OF CHANGES TO MEDICARE TELEHEALTH SERVICES:

January 1, 2023  (updated November 1, 2022)

Here is some new information on Medical Telemental Health Coverage in 2023.

Postponing the Effective Date of the Telemental Health In-Person Six-Month Rule

In 2020, Congress imposed new conditions on telemental health coverage under Medicare, creating an in-person “exam” requirement alongside coverage of telemental health services when the patient is located at home. Under the rule, Medicare will cover a telehealth service delivered while the patient is located at home if the following conditions are met:

The practitioner conducts an in-person exam of the patient within the six months before the initial telehealth service starting 151 days after the end of the Public Health Emergency.

  The telehealth service is furnished for purposes of diagnosis, evaluation, or treatment of a mental health disorder (other than for treatment of a diagnosed substance use disorder (SUD) or co-occurring mental health disorder); and

  The practitioner conducts at least one in-person service every 12 months of each follow-up telehealth service starting 151 days after the Public Health Emergency.

While there is no requirement that this will apply to commercial insurance, they often follow the Medicare rules. At this time there are no insurers who have said they will require the above rules.

Behavioral Health
A new proposal is being finalized to create a new HCPCS code (G0323) describing General Behavioral Health Integration performed by clinical psychologists (CP) or clinical social workers (CSW). This code is to account for monthly care integration where the mental health services provided by a CP or CSW are serving as the focal point of care integration.

New Telemental Health Codes (Audio Only)(https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes) https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

The following is a list of behavioral health ICD-10 codes that CMS will cover by audio-only through 2023 OR for 151 days after the end of the Public Health Emergency (PHE). To read the CMS statement go to the link above. Videoconferencing will be covered during the Public Health Emergency for the same codes that are used for in-person and also have 151 days after the end of the Public Health Emergency (PHE). 

There are two new codes – 0362T And 0373T – which are connected to integrated medical and behavioral health care.

Code     Short Descriptor of Telemental Health Codes for Audio-Only CPT Codes   

0362T   Bhv id suprt assmt ea 15 min      Available Through December 31, 2023       

0373T   Adapt bhv tx ea 15 min                Available Through December 31, 2023     

90785   Psytx complex interactive            Available Indefinitely            

90791   Psych diagnostic evaluation        Available Indefinitely   

90832   Psytx w pt 30 minutes                 Available Indefinitely 

90834   Psytx w pt 45 minutes                 Available Indefinitely 

90837   Psytx w pt 60 minutes                 Available Indefinitely 

90838   Psytx w pt w e/m 60 min             Available Indefinitely 

90839   Psytx crisis initial 60 min             Available Indefinitely 

90840   Psytx crisis ea addl 30 min         Available Indefinitely 

90845   Psychoanalysis                           Available Indefinitely 

90846   Family psytx w/o pt 50 min         Available Indefinitely 

90847   Family psytx w/pt 50 min            Available Indefinitely 

90853   Group psychotherapy                 Available Indefinitely 

Please let me know if you have any questions about these changes to Medicare mental health coverage.

Laura Groshong, LICSW, Director, Policy and Practice  Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12997101) The Aware Advocate - November 2022
Nov 21st 2022, 10:43

The Aware Advocate is an occasional summary of issues that affect LCSWs. Comments and updates are courtesy of CSWA Director of Policy and Practice, Laura Groshong, LICSW.

There are many issues affecting clinical social workers at this time, some of which are still being determined. This summary will address the recent issues that members have had questions about, even if the outcomes are not clear.

National Elections

At this point, the election results for the House of Representatives are still not complete. The Senate will remain in Democratic hands. This means there will be a better chance that the two issues which CSWA has been working on for LCSWs, i.e., improving the CMS RVU rates for Medicare and getting student loan forgiveness for CSWs will have a better chance of passage.

CMS Coverage of Telemental Health

The bills which are addressing telemental health will continue to be developed but are not clearly defined yet.

The current policy of CMS is that coverage of psychotherapy through videoconferencing and audio only will continue for 151 days after the end of the Public Health Emergency (PHE). There is no imminent attempt to end the PHE, as COVID continues to mutate and is still a major problem in many areas. It is unlikely that the PHE will end before next spring at the earliest.

BetterHelp

Many CSWA members have been receiving requests to join the BetterHelp panel, as well as being bombarded with ads to use BetterHelp clinicians on NPR, in magazines, on TV, and just about everywhere. While the short-lived partnership with CareDash that BetterHelp formed last summer has ended, there have been other problems with the way that BetterHelp provides services. Dr. Marlene Maheu, the Executive Director of Telebehavioral Health Institute, has found that BetterHelp is a multi-billion dollar company despite putting most of the burden of liability on the clinician (TBHI Newsletter, 11/22).

Social Work Compact

After a few months of little activity on the Compact – which would allow participating clinicians to be automatically licensed in other states – it appears that the draft bill that will need to be passed in any state that wants to participate will be ready by the beginning of 2023! I will be sending you the bill and some information on how to get the bill through state legislatures.

I hope you all have a wonderful holiday season!

(https://www.clinicalsocialworkassociation.org/Announcements/12993098) LCSWs by State
Nov 17th 2022, 12:12

Licensed Clinical Social Workers (LCSWs) are the largest group of licensed mental health clinicians in the country, working in the public and private sector, providing psychotherapy and counseling on an individual, family and group basis in every state and jurisdiction. The acronyms below are the titles used in each state/ jurisdiction to designate independent clinical social work practice in that state.

Here is a list of the number of LCSWs in each state with the exact title used in that state. This data was collected from state social work Boards and administrators in September 2022. All LCSWs have requirements of two-three years post-graduate supervised experience and have taken a national examination. Most LCSWs are licensed to diagnose all mental health disorders in the Diagnostic and Statistical Manual-5-TR and future editions, and treat these disorders when appropriate. 


(https://www.clinicalsocialworkassociation.org/Announcements/12958786) Letter from CSWE - 10-18-22
Oct 18th 2022, 14:30

The following letter from the Council on Social Work Education (CSWE) was sent to all social work schools, programs and social work regulators on October 3, 2022.

As you know, CSWA has taken a stand on the recent ASWB report which noted alarming, disparate pass rates between white and Black MSWs, as well as between younger and older MSWs and between English speaking and bilingual MSWs (the whole position paper can be found here: (https://www.clinicalsocialworkassociation.org/Announcements/12908309) https://www.clinicalsocialworkassociation.org/Announcements/12908309). While we believe that a Clinical Examination must be kept in place and that the CSWE recommendation that new MSWs no longer take the examination for new graduates be carefully reviewed, we are actively working toward engaging social work stakeholders and identifying viable and equitable solutions to this critical issue.

Please let us know if you have any questions about the ASWB controversy and/or recommendations about how to address these disparities.

Kendra Roberson, PhD, LICSW, President
Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) president at clinicalsocialworkassociation.org

Laura Groshong, LICSW, Director, Policy and Practice  
Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

------------------------------------------------------------------------------------------------------

October 3, 2022

As president and chief executive officer of the Council on Social Work Education (CSWE), I write to you on behalf of social work education programs across the country. As you are likely aware, the Association of Social Work Boards (ASWB) recently released a report documenting examination pass rates across different levels of the social work profession.

Although the data needs further analysis, the descriptive statistics suggest alarming disparities for exam takers in several categories. The most egregious disparity impacts Black test takers. In addition, Indigenous, and other People of Color also pass at lower rates than White test takers; those that speak English as a second language pass at lower rates than native English speakers; and older test-takers pass at lower rates than younger ones.

Given that the ASWB exam is the only national licensing examination available, these data raise grave concern that the need for a diverse health, behavioral health, and social service workforce (of which social workers are a considerable portion of providers1) is being significantly impeded.

As the national body for social work education in the United States, Puerto Rico, and Guam, the CSWE urges you to:

a. Suspend the use of the ASWB exam until a thorough analysis has been completed which will suggest evidenced based recommendations to correct for inequities.

b. Consider graduation from a CSWE Accredited social work education program evidence of beginning competence to practice social work as a professional social worker (granting all graduates licensure or pre-licensure status).

c. The only exception to the above involves the license to practice clinical social work. CSWE supports the need for a post-graduate process to license practice at this level, however if the ASWB exam remains central to this process, further analysis of the descriptive data must also occur for this category to identify possible issues.

d. Consider the action taken by the state of Illinois (January 1, 2022) through the Public Act 102-0326, whereby a licensing examination is no longer required for licensure as an Illinois Licensed Social Worker (LSW).

e. Consider decoupling the Interstate Compact, currently in development, from the ASWB licensure exam.

Thank you for your consideration. I would be happy to engage with you further about the concerns and/or recommendations I offer.

Sincerely,

Darla Spence Coffey, PhD, MSW  
President and Chief Executive Officer  
dcoffey at cswe.org

1 U.S. Bureau of Labor Statistics (bls.gov) 2020 report indicates there are 715,600 social workers that work in Child, Family, School, Healthcare, Mental Health, and Substance abuse treatment settings.

(https://www.clinicalsocialworkassociation.org/Announcements/12945160) Mental Health Matters Act - 10-6-22
Oct 6th 2022, 14:20

The U.S. House of Representatives just passed the Mental Health Matters Act, a bill that could significantly improve access to mental health and addiction care in this country.

There are two critical provisions within the bill: Strengthening Behavioral Health Benefits Act (Title VI) and the Employee and Retiree Access to Justice Act (ERISA, Title VII):

The Strengthening Behavioral Health Benefits Act (Title VI) would provide civil monetary penalty authority to the U.S. Department of Labor (USDOL) to enforce the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), which required insurers to cover mental health and addiction treatment at parity with treatment for physical health. The problem is that USDOL currently has one investigator for every 12,500 plans. USDOL has asked Congress to give it this authority with more funding for investigators.

  The Employee and Retiree Access to Justice Act (Title VII), would better protect the 136 million Americans enrolled in private sector employer (ERISA) health plans. This legislation would prohibit ERISA plans from inserting mandatory arbitration provisions into plan policies that prevent consumers from using the courts to challenge wrongful coverage denials. The Employee and Retiree Access to Justice Act also addresses “discretionary clauses” into their plan policies, which allows plans to decide what treatment is medically necessary when they consider adjudicating benefits under these policies.

Hopefully the Senate will take up this bill and we will see the kind of changes that are necessary to make mental health parity a reality. I will let you know when we need to support the bill in the Senate.

To see a summary of the Act go to: (https://edlabor.house.gov/imo/media/doc/mental_health_matters_act_fact_sheet2.pdf) https://edlabor.house.gov/imo/media/doc/mental_health_matters_act_fact_sheet2.pdf

Laura Groshong, LICSW, Director, Policy and Practice  
Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12911833) Announcement on Social Work Compact – 9-8-22
Sep 8th 2022, 18:53

As those of you who have attended the CSWA webinars on the Social Work Compact know, there is one more week to send your comments to the Council of State Governments on the draft document. Please visit

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=6QUQ8lgihW3HY4PvsKn57mahtloHedtBDZg8Zfu5NUJA2UwYls%2F2sLontsG%2BkR26yV%2BJAEE1Zw%2BHDtopESubuEtACX4kXktH%2FOqemXC%2FVhM%3D) https://www.clinicalsocialworkassociation.org/Announcements to see information on the Social Work Compact.

To see the whole draft document, please visit (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=RSxT%2FBh5GBu5YArvmsyhMWP9mNsXwbRdxYkybM%2FxX1OsnS3BRyNYHCOcrDvY78miBvhuXrsylbXC27qoIGqmkrJ46JV4p9diEpXnzml%2BOFo%3D) https://compacts.csg.org/compact-updates/social-work/.

To send comments on the draft document, please visit 

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=oPxhSG%2FduM6GZi8O8GMtnVU1B394KI2CJb%2FoYnghMK9B44rh6%2BlspLYFdbZeAtta6oLGXzapR%2FWy9QeyUG1U8CD5rjg7JWSLYScS66ImMv4%3D) https://www.surveymonkey.com/r/socialworkcompact.

The final date for sending comments is close of business on September 16, 2022.

Let me know if you have any questions.

Laura Groshong, LICSW, Director, Policy and Practice  
Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12908309) CSWA Commentary on ASWB Report - 9-2-22
Sep 6th 2022, 11:37

On August 5, 2022, the Association of Social Work Boards (ASWB) published data on pass rates for the Clinical Social Work Examination, which it oversees, as well as data on the other three levels of social work licensure ((https://www.aswb.org/aswb-releases-data-analysis-on-social-work-licensing-exam-pass-rates/) 2022 ASWB Exam Pass Rate Analysis for Social Work Licensing Exams [aswb.org]). Publication of this initial data was long overdue. The noted disparities in pass rates, which vary by almost 40% for white and Black social workers were striking. Here CSWA provides historical context and suggestions for steps ahead.

History of Clinical Social Work Licensure

The clinical social work examination has been the national standard for independent clinical practice since 19­­­­­­­­­­­­­50 when ASWB (formerly AASWB) began creating examinations and states began licensing clinical social workers (formerly called psychiatric social workers), beginning with California. As clinical licensure became the norm over the next 54 years (the last state to achieve licensure was Michigan in 2004), the profession established a general standard for licensure based on four elements: 1) obtaining an MSW at an accredited school of social work; 2) having 2-3 years of supervised experience, post-MSW; 3) passing the ASWB Clinical Examination; and finally, 4) having a social work licensure law approved by each state legislature and overseen by each state’s Board of social work. All four areas have different oversight mechanisms and little connection to each other. Correspondingly, there are no two states that have the exact same standards.

There is now a nationwide patchwork system which makes transferring licensure from one state to another problematic. The Council on Social Work Education (CSWE) has overseen schools of social work, but the standards for doing the work that leads to an MSW are quite elusive. Similarly, specific standards for supervised experience vary widely across the states.

Clearly, clinical social work is a young profession. LCSWs were approved to provide psychotherapy through Medicare in 1965, yet, there has been much fragmentation in the field. Efforts to standardize and integrate all parts of clinical social work were understandably set aside by stakeholder organizations in favor of creating licensure in all states and jurisdictions and achieving vendorship for clinical social workers.

Next Steps

There has been a widespread condemnation of ASWB for withholding information about the pass rates and/or being indifferent to the way that the clinical exam has yielded disparate pass rates for BIPOC and older clinical social workers. CSWA is in discussions with the new ASWB Executive Director, Stacey Hardy-Chandler, PhD, about the ways that ASWB, CSWA, and other stakeholders can work together to improve not only the clinical examination, but also the collective preparation of pre-licensed social workers to ensure an equitable exam experience. To this end, ASWB has also issued a statement about their intentions following the release of their report, which includes the following:

“Continuing to evaluate all aspects of the licensing exam development process, beginning with an in-depth review of item generation, and then implementing a comprehensive, user-centered investigation of test-takers’ experiences

  Offering a collection of free resources designed for social work educators to help them understand the exams and candidate performance so they can better prepare their students for the exams and to increase access to exam resources

  Bringing a greater diversity of voices into the exam creation process through the Social Work Workforce Coalition

  Hosting community input sessions to expand the range of perspectives involved in the creation of the next iteration of the exams

  Launching the Social Work Census, an in-depth survey of social workers, to better understand who today’s social work practitioners are and what they do”

Need for the Clinical Examination

CSWA is aware of strong opinions of many, including LCSWs, that the clinical examination should be eliminated. There are three key reasons that CSWA does not support this idea:

1. In order to practice independently, LCSWs need to substantiate they have sufficient expertise to practice psychotherapy independently. The examination is a primary means of assessing that ability.

2. Passing the examination is written in to each states’ and jurisdictions’ laws and regulations.

3. The Social Work Compact, currently in development, which would allow LCSWs more flexibility to work in states with a multi-state license, will require LCSWs to pass a national examination.

Summary

CSWA believes that ASWB is now poised to attend to the inherent inequities exposed in the ASWB Clinical Examination process. We hope to work with ASWB toward that goal and encourage others to do so as well. Additionally, CSWA will press forward to advocate for meaningful integration of our education programs and licensing boards, efforts that can significantly impact ways the clinical examination is approached and regarded.

Contacts:

Kendra Roberson, PhD, LICSW, President
Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) president at clinicalsocialworkassociation.org

Laura Groshong, LICSW, Director, Policy and Practice  
Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12875298) CSWA - Statement from CareDash - 8-6-22
Aug 6th 2022, 09:12

Earlier yesterday I sent you the BetterHelp statement which said that they were ending their connection to CareDash.

Now I am pleased to send you the news that CareDash is backing off their harmful stance toward clinical social workers in private practice, as well. While there are still some problems to be resolved, CareDash has 1) stopped their deliberate confusion about LCSW availability; 2) removed their “book an appointment” option which directed potential patients away from LCSWs who were not part of the CareDash network; and 3) clarified that their information comes from the NPI list of clinicians and has nothing to do with the quality of those clinicians. To see the whole CareDash statement, click (https://twitter.com/caredash/status/1555658652786348032?s=20&t=0wbvSA8XI46b1egY3gvpjg) HERE.  

I am fairly certain that the outstanding response of CSWA members to the demeaning policies of CareDash had a major impact on their decision to back off their original stance. Thanks to all of you for your great contributions to this effort.

CSWA will continue to insist on the rights of all LCSWs in private practice to have access to all patients who want to see them without interference by any external organizations.

Laura Groshong, LICSW, Director, Policy and Practice  Clinical Social Work Association   (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12875038) Bloomberg Law Article and CSWA - 8-5-22
Aug 5th 2022, 20:48

Here is a link to an article published today in Bloomberg Law today about the CareDash situation which mentions CSWA:

(https://www.bloomberg.com/news/articles/2022-08-05/shadow-profiles-from-therapist-directory-spark-startup-backlash?sref=yqJvNODh) https://www.bloomberg.com/news/articles/2022-08-05/shadow-profiles-from-therapist-directory-spark-startup-backlash?sref=yqJvNODh

Keep sending your complaints to your state consumer protection agencies and the FTC. The original post and template can be found (https://www.clinicalsocialworkassociation.org/sys/website/system-pages/?pageId=18010) HERE. 

Let me know when you have sent them, as always.

Laura Groshong, LICSW, Director, Policy and Practice  Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12854067) 9-8-8 Suicide and Crisis Lifeline - July 2022
Jul 19th 2022, 14:22

 

    July 16, 2022 was the roll-out date for ”9-8-8”, the new US network for people looking for help with suicidality or other emotional crises. This phone number is designed to be used for text or for telephone access to volunteers who will provide initial assistance to callers, then triage them to LCSWs and other licensed clinicians.

      Ultimately, 9-8-8 will become the National Suicide Prevention Lifeline (1-800-273-TALK); the new number will be easier to remember and access. This older hotline will remain in effect for an as yet undetermined period of time while 9-8-8 becomes fully operational. 

       There is no question of need: there has been an exponential increase in suicides and suicide attempts since the pandemic began almost three years ago. Here is what LCSWs should know about the implementation of this new system.

Funding

The $400 million set aside in Federal funding for 9-8-8 is about half of what will be needed to fund the services in every state. So far, the only states that have provided the needed state funding are Colorado, Nevada, Virginia and Washington. Nine states have legislation in progress to provide this funding; 37 states have no plan to provide funding. CSWA encourages members to ask their state legislators to find the state funding for 9-8-8 so that it can be fully functional as soon as possible. To see what your state’s plan is for funding 9-8-8, go to (https://reimaginecrisis.org/map/) https://reimaginecrisis.org/map/.

Current Statistics

How serious is the issue of suicide? Here are the number of suicides in the most recently recorded year, 2020:

In 2020, the U.S. had one death by suicide about every 11 minutes

  Suicide was the leading cause of death for individuals between ages 10-34 in 2020

  Over 100,000 individuals died from drug overdoses in the nine months from April 2020 to the end of the year

While 2020 actually saw a decrease in suicides from 2019 overall (17.7%, (https://suicidology.org/2021/04/02/2020data/) https://suicidology.org/2021/04/02/2020data/), of grave concern is the fact that there was an increase for young adults and BIPOC communities of all ages in 2020 ((https://www.webmd.com/mental-health/news/20211103/suicide-rates-2020-cdc) https://www.webmd.com/mental-health/news/20211103/suicide-rates-2020-cdc) .

More Information

The Substance Abuse and Mental Health Services Administration has prepared a toolkit to further explain the need for 988. For FAQs and Fact Sheets, go to

(https://www.samhsa.gov/find-help/988/partner-toolkit) https://www.samhsa.gov/find-help/988/partner-toolkit. Also feel free to contact me for more information.Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/Announcements/12845065) Information about the Compact - 7-11-22
Jul 11th 2022, 17:08

Dear CSWA,

As you know, CSWA has been involved in the development of a Compact which would allow clinical social workers to practice in all states that join the Compact without having to become licensed in individual states. For the past 8 months, Laura Groshong, CSWA Director of Policy and Practice, and I have attended the Social Work Compact Technical Advisory Committee meetings monthly, sponsored by the Department of Defense and Council of State Governments.

A document for the Compact has been created which is now available for review by the public, including CSWA members. I encourage all CSWA members to attend one of the two webinars which will be held on July 30 at noon ET and September 8 at 3 pm ET for more detailed information on the Compact. Keith Buckhout and Matt Shafer of the Council of State Governments will be available to explain the process and answer your questions. Registration for these webinars will be on the website shortly.

Among the issues that will be addressed are:

What is an interstate compact?

  How do states use interstate compacts?

  How do states join a compact?

  How many states are required for a compact to be in effect?

  What are the benefits of a compact?

  How do compacts preserve state sovereignty?

  Where do states obtain legal authority to enter compacts?

  How are compacts administered and enforced?

  What are the steps in the compact development process?

  How long can it take to implement a compact?

  How are compacts funded?

To review the document before the webinars, go to (https://compacts.csg.org/compact-updates/social-work) https://compacts.csg.org/compact-updates/social-work/

To submit comments or feedback on the draft, please fill out the online survey at (https://www.surveymonkey.com/r/socialworkcompact) https://www.surveymonkey.com/r/socialworkcompact

Please let Laura know if you have any questions and watch for an email later this week from our new Administrator, Angela Katona, regarding how to sign up for one of the two webinars.

Kendra Roberson, PhD, LICSW

CSWA President

president at clinicalsocialworkassociation.org

Laura Groshong, LICSW

CSWA Director, Policy and Practice

lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12842325) Mental Health Treatment and Texting - 7-8-22
Jul 8th 2022, 09:49

CSWA members have expressed concerns about the way that companies like Betterhelp are providing a kind of mental health treatment based on texting. The lack of direct contact is cause for concern. The asynchronous nature of Betterhelp limits emotional communication.

A new article from California Healthline written by award-winning journalist Harris Meyer, has just come out and has echoed some of these concerns. The article, “Digital Mental Health Companies Draw Scrutiny and Growing Concerns”, can be found at (https://californiahealthline.org/news/article/digital-mental-health-companies-scrutiny-concerns/) https://californiahealthline.org/news/article/digital-mental-health-companies-scrutiny-concerns/.

Both Marlene Maheu, PhD, who presented a webinar on telemental health for CSWA, and Laura Groshong, CSWA Director, Policy and Practice, are quoted in the article.

(https://www.clinicalsocialworkassociation.org/Announcements/12808777) End Gun Violence - 6-7-22
Jun 7th 2022, 13:48

Below is a Letter to Congress on gun violence that CSWA signed on to with 9 other national organizations which was published in USA Today this morning. ~Laura Groshong, LICSW, Director, Policy and Practice, (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org, 6/7/22

(https://www.clinicalsocialworkassociation.org/resources/Pictures/Open-letter%20USA%20Today%20FINAL.jpg) 

(https://www.clinicalsocialworkassociation.org/Announcements/12793555) Call for Papers Announcement from the Clinical Social Work Journal Life After the MSW
May 25th 2022, 13:36

The Clinical Social Work Journal (CSWJ) is pleased to announce a call for papers for a special issue called: Life After the MSW. This special issue will be co-edited by the Editor in Chief of the journal, Melissa D. Grady, PhD and Kendra C. Roberson, PhD, the President of the Clinical Social Work Association (CSWA). In this issue we will be seeking manuscripts that offer readers a mix of historical/scholarly information about the topic, as well as concrete and practical information for soon to be and/or recent MSW graduates. The aim of this special issue is to offer practical advice to newer professionals in the field. We hope that the articles within this special issue can be used by faculty members and supervisors who are helping to train new social work practitioners, as well as by the graduates/students themselves. 

Some examples of topics for this special issue could include, but are not limited to issues related to post-masters education, clinical supervision considerations, navigating and/or preparing for the licensure process, practicing clinical social work with a social justice lens, and potential career paths as a clinical social worker.

Interested authors should submit an abstract of no more than 750 words describing the proposed manuscript. Those that are chosen will then be invited to submit full manuscripts that will be between 10-15 pages in length. 

Each abstract should include the following:

Introduction of the topic AND its relevance to soon to be and/or recent MSW graduates

  How the authors will provide practical information for the intended audience (e.g., bullet lists of areas to consider, tips for accessing information, resources that would be useful for further exploration, pros and cons of the issue, lists of questions that readers could consider for themselves)

In addition to the above, full manuscripts will also require

Background information on the topic (e.g., historical background, any scholarly information on the topic)

  Expanded practical information section as described above

Deadlines for process:

Abstracts should be submitted by Oct 1, 2022

  Invitations for full manuscripts will be sent out by Dec 31, 2022

  Full manuscripts will be submitted by Mar 1, 2022
For any questions, please contact Melissa D. Grady at (mailto:grady at cua.edu) grady at cua.edu or Kendra Roberson at (mailto:kacey at uw.edu) kacey at uw.edu.

(https://www.clinicalsocialworkassociation.org/Announcements/12757569) Update on POS Codes for Medicare – 4/27/22
Apr 27th 2022, 15:14

I have received a deluge of emails from you about the use of POS “10” for Medicare and other insurers.  This guidance that Medicare has provided about this policy is complicated.

The current guidance from CMS is that:

POS “11” should be used until the end of the Public Health Emergency, timing of which is currently unknown, even though this is not what the POS “11” is for. 

  And, as of April 4, 2022, there is some variation according to Medicare Administrative Contractors (MACs) about whether or not to move to POS “10” as initially stated by CMS. 

  Check with YOUR MAC to clarify  which POS code is being accepted currently if the patient is being seen through telemental health in their home; for example, technically, if a patient is in their car, the POS code should be “02”. 

  You can find your MAC contact information at the CSWA website under “(https://www.clinicalsocialworkassociation.org/Clinical-Practice-Support) Clinical Practice”.

  The Medicare Modifier for POS codes is still 95. This may seem counterintuitive as 95 is supposed to be for telemental health but it is the only combination that currently works.

Be sure to check with EACH private insurer for a patient to find out what combination of POS and Modifier are being requested so that claims will not be denied.

I hope this resolves the confusion about POS codes.  Let me know if there are any other questions.

POS Codes as of 4/1/22 – Medicare

There has been some confusion about what Point of Service (POS) Codes should be used for Medicare and other insurers as of April 1, 2022. 

As you know, there were changes to POS codes that were announced as of January 1, 2022 to be “available” for Medicare as of April 1, 2022.  POS “10”, a new POS code for telemental health services that are provided when the patient is in their home, and the LCSW is in their office or elsewhere.  Other POS Codes are “2” which is used when a patient is not in their own home and receiving telemental health services from an LCSW or “11” which is used when seeing a patient in the LCSW’s office.

The Medicare modifier is 95 for any of the above codes.

It appears that the POS 10 is now being used instead of POS 2 for Medicare for reimbursement.  All other insurers, public and private, should be contacted about the POS codes that are required for reimbursement of claims. The same goes for which modifier is being used – check with the individual insurer.

For more information, go to (https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set) https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set  If you have other question, contact me at (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org.

(https://www.clinicalsocialworkassociation.org/Announcements/12741892) POS Codes as of 4/1/22 – Medicare
Apr 24th 2022, 20:27

There has been some confusion about what Point of Service (POS) Codes should be used for Medicare and other insurers as of April 1, 2022. 

As you know, there were changes to POS codes that were announced as of January 1, 2022 to be “available” for Medicare as of April 1, 2022.  POS “10”, a new POS code for telemental health services that are provided when the patient is in their home, and the LCSW is in their office or elsewhere.  Other POS Codes are “2” which is used when a patient is not in their own home and receiving telemental health services from an LCSW or “11” which is used when seeing a patient in the LCSW’s office.

The Medicare modifier is 95 for any of the above codes.

It appears that the POS 10 is now being used instead of POS 2 for Medicare for reimbursement.  All other insurers, public and private, should be contacted about the POS codes that are required for reimbursement of claims. The same goes for which modifier is being used – check with the individual insurer.

For more information, go to (https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set) https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set  If you have other question, contact me at (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org.

(https://www.clinicalsocialworkassociation.org/Announcements/12684179) Position Paper – Support for Trans-Gender Children
Mar 28th 2022, 14:47

Transgender children have been in the crosshairs of conservative groups in the legislature and elsewhere for the past decade.  Amongst legislative attempts to discriminate against them, there have been attempts to ban them from gender-specific bathrooms or from participating in sports consistent with their gender identity.  Support for transphobic attitudes and actions has grown. Now there is an attempt in Texas to lay blame on parents who affirm their child’s gender identity. This bill is one of the most harmful to trans children, but is the tip of the iceberg; there have been over 235 state-based bills that limit the rights of trans children in 2022 ((https://www.msn.com/en-us/news/us/nearly-240-anti-lgbtq-bills-filed-in-2022-so-far-with-most-targeting-trans-people/ar-AAVhMSa) https://www.msn.com/en-us/news/us/nearly-240-anti-lgbtq-bills-filed-in-2022-so-far-with-most-targeting-trans-people/ar-AAVhMSa) . The current law that has passed in Texas, abhorrently describes parental support of trans children as child abuse; though, for now, it has been placed on hold by a Texas appeals court.

CSWA believes that gender identity is an integral aspect of our intersectional identities and that children’s rights to express their identities, and to participate in everyday activities of childhood, regardless of this expression, should be protected.  LCSWs work with trans-children and adults who have been harmed because their trans identities. To our affiliated colleagues in the Texas Society for Clinical Social Work, we send our support and encouragement to stand strong.  No law can persuade us to ignore our ethical stance on respecting the identity of any individual child, and for parents that support and affirm their children.  Also notable, the Texas law does nothing to prevent the violence directed toward trans BIPOC youth for being themselves. This violence has increased at alarming rates in the last few years.

As reported by Forbes, 30 trans youth were killed in 2020, including 23 that were BIPOC youth. (Forbes, “Transgender America: 30 Killed And Fatally Shot Already In 2020”, 10/2/20, https://www.forbes.com/sites/jamiewareham/2020/10/02/30-trans-woman-have-now-been-violently-murdered-in-america-in-2020/?sh=296cb38564a4). The work of groups like GLAAD (glaad.org), the Trans Youth Equality Foundation (http://www.transyouthequality.org/), and the Transgender Law Center ((https://transgenderlawcenter.org/) https://transgenderlawcenter.org/) are crucial to educating the public and advocating across multiple domains to prevent transphobic violence and discrimination against trans youth and their parents.  CSWA supports the work of these groups in preventing harm and protecting trans children.

(https://www.clinicalsocialworkassociation.org/Announcements/12633827) President Biden’s Comments on Mental Health
Mar 1st 2022, 16:40

President Biden’s State of the Union address tonight will have a major focus on the need for more mental health funding and services.  A few of the areas he will discuss are:

A vision to transform how mental health is understood, perceived, accessed, treated, and integrated – in and out of health care settings. The American Rescue Plan laid the groundwork, providing critical investments to expand access to mental health services. Now, far more is needed to ensure that everyone who needs help can access care when and where they seek it.

  A national mental health strategy to strengthen system capacity, connect more Americans to care, and create a continuum of support –transforming our health and social services infrastructure to address mental health holistically and equitably.


Expand the supply, diversity, and cultural competency of our mental health and substance use disorder workforce – from psychiatrists to psychologists, peers to paraprofessionals – and increase both opportunity and incentive for them to practice in areas of highest need. 

  The President’s FY23 budget will invest $700 million in programs – like the National Health Service Corps, Behavioral Health Workforce Education and Training Program, and the Minority Fellowship Program – that provide training, access to scholarships and loan repayment to mental health and substance use disorder clinicians committed to practicing in rural and other underserved communities.

To see a complete summary of what the President will discuss regarding mental health go to: (https://www.whitehouse.gov/briefing-room/statements-releases/2022/03/01/fact-sheet-president-biden-to-announce-strategy-to-address-our-national-mental-health-crisis-as-part-of-unity-agenda-in-his-first-state-of-the-union/) https://www.whitehouse.gov/briefing-room/statements-releases/2022/03/01/fact-sheet-president-biden-to-announce-strategy-to-address-our-national-mental-health-crisis-as-part-of-unity-agenda-in-his-first-state-of-the-union/

CSWA will provide a message to send to Congress, who will have to approve the funding and policy measures regarding mental health, on the issues that most affect clinical social workers following the State of the Union speech.

Laura Groshong, LICSW, Director, Policy and Practice 
Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org


(https://www.clinicalsocialworkassociation.org/Announcements/12289969) Medicare In-person Meetings-01202022
Jan 20th 2022, 17:47

In the rush to figure out the Good Faith Estimate, another important issue has been on the back burner.

As you know, the No Surprises Act also had a provision that we see every patient at least once every 12 months.  This was extended from the previous rule which required this provision every 6 months.

With recent guidance from CMS, it is now clear that this requirement will go into effect after the end of the Public Health Emergency (PHE).   That is not likely to be before the end of 2022 at the earliest.

CSWA is hoping to work with many other mental health groups to eliminate this rule. We will keep you posted.

Laura Groshong, LICSW   
Clinical Social Work Association   
Director, Policy and Practice  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org  

(https://www.clinicalsocialworkassociation.org/Announcements/12206805) Focus on 2022 Medicare Changes
Dec 20th 2021, 14:03

The Aware Advocate: Focus on 2022 Medicare Changes 

December, 2021  Laura Groshong, LICSW, CSWA Director, Policy and Practice

There are a number of issues that are affecting LCSW practices in the waning days of 2021, particularly in the area of Medicare (which we know affects commercial insurance heavily). These issues are:  1) giving patients a “Good Faith Estimate” of what the treatment we provide will cost; 2) elimination of 2022 cuts to Medicare reimbursement; 3) telemental health coverage; and 4) DCEs. Discussion of each of these follows.

Good Faith Estimates

This rule requires us to give a “good faith estimate” (GFE) to a patient of what our services will cost and how long they may last.  While this policy is part of most of our informed consent forms, signed by the patient already, it is prudent to review what the GFE is more formally requesting we include in our information to the patient. The main difference about past practices and the GFE is that it applies to private pay patients as well as insured patients and uninsured patients.

For more information and a template of what belongs in a GFE, (https://www.clinicalsocialworkassociation.org/Templates) go to the CSWA website under “Templates” in the Members Only section.

Medicare Cuts Stopped

LCSWs can take a deep breath as Congress has acted to prevent the trio of Medicare payment cuts that were set to take effect at the beginning of 2022—a 3.75% cut due to scheduled changes in the Medicare Physician Fee Schedule (“PFS”), a 2% cut for Medicare sequestration, and a 4% Statutory Pay-As-You-Go Act (“PAYGO”). These Act cuts would have slashed Medicare payments by nearly 10% during a tumultuous time for healthcare. Instead, tThe Protecting Medicare and American Farmers from Sequester Cuts Act ((https://www.congress.gov/117/bills/s610/BILLS-117s610enr.pdf) S. 610) was approved by the U.S. House of Representatives on December 7 and passed the U.S. Senate on December 9, 2021.  The bill has been sent to President Biden’s desk for his signature.

The Protecting Medicare and American Farmers from Sequester Cuts Act includes:

A one-year increase in the Medicare PFS of 3%;

  A delay in resuming the 2% Medicare sequester for three months, followed by a reduction to 1% for three months;

  Erasure of the 4% Medicare PAYGO cut; and

  Prevention of additional PAYGO cuts through 2022

This is the second year that a last-minute change stopped a substantial reimbursement cut for LCSWs.  CSWA will be encouraging CMS and Congress to stop these attempts to balance the Medicare budget on the backs of clinicians moving forward.

Telemental Health Coverage

As you know, CMS issued a new rule last month to expand telemental health and audio only psychotherapy through 2023. You also know we are still unable to practice across state lines unless we are licensed in the state where the patient resides and/or there is still increased reciprocity in the state where the patient resides.  CSWA is still working with Department of Defense and the Council of State Governments to create a “Compact” that will make it much easier to work across state lines; it should be ready to begin implementing in early 2023.

The requirement that LCSWs see patients in person every 6 months has been extended to every 12 months. This is a still a hardship for some patients and LCSWs who have given up a physical office.  CSWA will be working to eliminate this requirement.

For more information go to the CSWA website under “Legislative Alerts”.

Medicare Direct Contracting Entity

Over the past decade, over 50 models of delivering health care through Medicare have been explored, with the goals of lowering costs for dual-eligibles; eliminating access to care, based on economic disparities; and, moving away from a fee for service (FFS) payment model.  The last goal has an impact on LCSWs in private practice who have used the FFS model for some time.

A new model has been emerging called the Medicare Direct Contracting Entity (MDCE).  It is similar to the Accountable Care Organizations that have been in use for the past five years, but is run by commercial for-profit agencies. CMS has started to ‘assign’ beneficiaries who are in traditional Medicare to MDCE plans without consent.  There is concern that this could lead to the privatizing of Medicare which would have the same difficulties that commercial insurance for-profit plans have, i.e., the focus on profit leads to diminished health care services.

Surgeon General Report on Youth Mental Health

U.S. Surgeon General Vivek Murthy, MD, released an advisory statement on December 7 to highlight the urgent need to address the nation’s youth mental health crisis. (https://www.hhs.gov/sites/default/files/surgeon-general-youth-mental-health-advisory.pdf) “Protecting Youth Mental Health” (PDF, 1.01MB) . This excellent document outlines the COVID-19 pandemic’s harm to the mental health of America’s youth and families, as well as the mental health challenges that had accumulated before the pandemic began. CSWA is delighted to see the Surgeon General paying attention to this increasingly difficult situation.

CSWA wishes you a happy and healthy holiday season!

Laura Groshong, LICSW, Director, Policy and Practice  Clinical Social Work Association   (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org


(https://www.clinicalsocialworkassociation.org/Announcements/12193411) CMS Regulations – “Good Faith Estimates” |  December 14, 2021
Dec 14th 2021, 21:38

I want to call your attention to a new rule from CMS that will go into effect on January 1, 2022.  This rule requires us to give a “good faith estimate” (GFE) to a patient of what our services will cost and how long they may last.  While this policy is part of most of our informed consent forms, signed by the patient already, it is prudent to review what the GFE is more formally requesting we include in our information to the patient about the course of their treatment.  The main difference about past practices and the GFE is that it applies to private pay patients as well as uninsured patients.

There is a CMS template for providing this information which can be found at (https://www.apaservices.org/practice/legal/managed/good-faith-estimate-notice.pdf) good faith estimate (PDF, 130KB) . However, this 8-page document is more applicable to hospital stays and procedures.  It may be more helpful for LCSWs to make sure they have the following information in their informed consent or verbally transmitted and documented.

Here is a list of what belongs in the GFE (which can also be part of an informed consent or disclosure statement) for private practitioners:

The patient’s name and date of birth;

  A description of the psychotherapy or other service(s) being furnished to the patient;

  An itemized list of items or services that are “reasonably expected” to be furnished;

  Expected charges associated with each psychotherapy session or other service(s);

  Your name, National Provider Identifier, Tax Identification Number, office location where services will be provided;

  A disclaimer that there may be additional items or services that you recommend as part of the treatment that will be scheduled separately and are not reflected in the good faith estimate;

  A disclaimer that the information provided in the good faith estimate is only an estimate and that actual items, services, or charges may differ from the good faith estimate; and

  A disclaimer that the good faith estimate does not require the private pay patient to obtain psychotherapy or other services from you.

This information can be transmitted orally but should be given to the patient as soon as possible. For ongoing patients, there should be a new informed consent or GTE statement provided with the information above.  CSWA will provide a template for this shortly.

Laura Groshong, LICSW, Director, Policy and Practice  Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/12126379) CSWA - Senate Finance - NHMH -11-12-21-1
Nov 14th 2021, 13:11

Next Tuesday the Senate Finance Committee will have a hearing on funding for mental health and substance use programs. While this does not affect Medicare reimbursement or private insurance rates directly, increased funding will be helpful in those areas. 

(https://www.clinicalsocialworkassociation.org/resources/CSWA%20-%20Senate%20Finance%20-%20NHMH%20-11-12-21-1.pdf) Please read the attached statement which CSWA developed with other mental health groups.  We will keep you posted on the outcome of the hearing.

Laura W. Groshong, LICSW, Director, Policy and PracticeClinical Social Work Association (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org


(https://www.clinicalsocialworkassociation.org/Announcements/11591683) Report on Social Work Compact Meetings – October 4-5, 2021
Oct 18th 2021, 12:01

Report on Social Work Compact Meetings – October 4-5, 2021  Laura Groshong, LICSW, Director, Policy and Practice

The first in-person meeting of the Social Work Compact Technical Assistance Group (TAG) took place in the Hall of States in Washington, DC.  Kendra Roberson, PhD, LCSW, CSWA President, and I were the representatives from CSWA.  The development of a social work interstate Compact is sponsored by the Department of Defense and the Council of State Governments, a non-partisan agency which has many projects that work to facilitate interstate cooperation. What began as a way for military spouses to take a social work license to another state when a spouse was redeployed will become inclusive of all licensed clinical social workers. For more information on CSG go to (https://compacts.csg.org/compacts/) https://Compacts.csg.org/Compacts/  

Home State

Compacts require that the home state for an LCSW be the state of residence, not the state of practice.  Currently, if an LCSW wants to have licensure in a state separate from their state of residence, they must become licensed in that state. Under the Compact, if a clinical social worker is licensed in a home state that is a member of the Compact, the LCSW will be eligible to apply to practice in other states that also are in the Compact.

Work of the TAG

The TAG will now meet every three weeks to:

Promote licensure reciprocity across state lines

  Create more flexibility for reciprocity

  Discuss inclusion of telemental health and audio only in the Compact

  Determine other needs of interstate licensure

  Create the basis for the social work Compact Commission

  Avoid “Buyer’s Remorse” by considering the ways that the Compact may interfere with state laws

Next Steps
TAG will develop the following:

Purpose statement

  Description of access to care

  Notice of how public will be protected

  Statement on how to streamline regulations

  Definitions of Compact Privilege; Member States; State Boards; other key concepts

  Determine powers of member states and home states

  Notice of obligations of member states

  Statement of knowledge of sanctions for substance use; lack of cultural competency; sexual harassment

All the above should be ready for the Document Drafting Team by February, 2022.  TAG will meet every three weeks until Compact language is completed.  I will continue to send updates on the progress of the Compact.

(https://www.clinicalsocialworkassociation.org/Announcements/11198851) Social Work Compact Development Preview
Sep 24th 2021, 12:00

The Council of State Governments (CSG) is partnering with the Department of Defense (DoD) and a coalition of organizations, including the Clinical Social Work Association (CSWA), to develop new interstate compacts for the social work profession. These compacts will create agreements among participant states to reduce the barriers to license portability and employment. Participants will learn about the aspirations for the project; the function of interstate compacts and the development process; and the need for license portability in the social work profession.

Bios:

Dan Logsdon: Dan is the Director of the CSG National Center for Interstate Compacts where he provides technical support and consulting regarding the development and enactment of interstate compacts. In recent years Dan has worked with a number of professional associations to develop new interstate compacts for occupational licensing portability including the American Occupational Therapy Association, American Counseling Association, and American Speech-Language-Hearing Association.

Matt Shafer: Matt is a program manager in the CSG Center of Innovation where he manages a portfolio of grant funded projects including the cooperative agreement with the Department of Defense to create new interstate compacts for occupational licensing portability. Matt also managed two Department of Labor grants focused on state occupational licensing policy and has extensive experience developing and building consensus on policy options for state leaders.

Keith Buckhout: Keith is a research associate in the CSG Center of Innovation and is primarily responsible for supporting the DoD Interstate Compacts project. Keith came to CSG after several years of working with licensure issues in state government in Kentucky.

Learning Objectives:

Learn the goals of the compact and the timeline for its implementation

  Learn the benefits of a compact for working across state lines

  Understand the ways that the Council on State Governments and Department of Defense are involved with CSWA in this project

CEs: No

(https://www.clinicalsocialworkassociation.org/Announcements/10983871) CSWA Position Paper on Texas Abortion Law
Sep 6th 2021, 12:23

No matter what one’s position about abortion might be, the Texas abortion law, SB 8, that became operational on September 1st must necessarily raise grave concerns.  This law, prohibiting abortions as early as six weeks after conception, not only denies women in Texas their constitutional right to health care, but criminalizes the participation of anyone who “aids and abets” a woman seeking an abortion. (To read the full text of SB 8, go to (https://capitol.texas.gov/tlodocs/87R/billtext/html/SB00008E.htm) https://capitol.texas.gov/tlodocs/87R/billtext/html/SB00008E.htm )

SB 8 poses an immediate threat to Texas LCSWs.  Using the consulting room to help clients work through the often traumatic decision to abort may now be seen as “aiding and abetting” in Texas.  Texas law is indirectly telling us that LCSWs can no longer provide a compassionate safe place for our patients to discuss difficult choices when an unwanted pregnancy occurs (no exceptions for rape or incest) without risking a $10,000 fine and attorney’s fees.

Limiting what can be talked about in the therapy session undermines our ethical standards and the confidentiality we guarantee, but there is another element of this new law that is even more chilling: enforcement of this new law is placed in the hands of private citizens, incentivizing a ‘bounty-hunter’ approach designed to intimidate.  Further, a spouse or family member who perceives an LCSW as supporting an abortion could report the clinician to authorities.

Purposely drafted to make it difficult to challenge in court, SB 8 carries the stench of Jim Crow, disproportionately impacting people of color, people with low-income, and other historically marginalized communities.  Nonetheless, legislatures in several other states are already drafting copycat legislation.

The disappointing refusal of the US Supreme Court in a 5-4 decision to consider the Texas law - with vigorous dissent from Chief Justice Roberts and Justices Sotomayor, Kagan, and Breyer - leaves the law in place for now.  However, some of the organizations actively fighting this blatantly unconstitutional law include the Lilith Fund, Whole Woman's Health Alliance, Inc., Texas Equal Access Fund, Jane's Due Process, Clinic Access Support Network, Support Your Sistah at the Afiya Center, West Fund, Fund Texas Choice, Frontera Fund, and The Bridge Collective, and the ACLU.  New challenges have already been filed.CSWA supports all efforts to stop Texas from interfering in the work of clinical social workers, and will be working with our Texan colleagues who are clearly at risk if they treat women seeking abortions.  We are gathering information about the protection that may be available through malpractice insurance and other potential resources, if indeed other states follow the Texas lead.  We urge members to consider signing the petition prepared by Texas social worker Dr Monica Faulkner, PhD, LMSW, at (https://www.change.org/StandWithSocialWorkers) https://www.change.org/StandWithSocialWorkers, and to pay close attention to what is happening in your local state legislatures.

(https://www.clinicalsocialworkassociation.org/Announcements/10838352) The Aware Advocate -- August 2021
Aug 6th 2021, 20:45

The Aware Advocate

An occasional newsletter from CSWA on topics that are relevant to clinical social work practice

August, 2021

Laura Groshong, LICSW, Director or 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.

==================================================

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) 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) 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:

(https://docs.google.com/forms/d/e/1FAIpQLScas3RrgHzg1syi5-0aV-Os4PwTx2CzWinKQashpJbZQ-HNCA/viewform?usp=sf_link) Please click here to complete the survey 

=====================================================================

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. (https://www.clinicalsocialworkassociation.org/resources/Documents/MEDICAL%20NECESSITY%20LETTER%20%5BTemplate%5D.docx) Click here for the MEDICAL NECESSITY LETTER [Template]

 ====================================================

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!


(https://www.clinicalsocialworkassociation.org/Announcements/10764723) The Current State of COVID-19 Risk
Jul 20th 2021, 23:09

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 (about:blank) 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 ((about:blank) 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",   ((about:blank) 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" ((about:blank) 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" ((about:blank) https://www.medscape.com/viewarticle/954643  ).  

Where COVID restrictions are loosening, anxiety is increasing according to this Medscape article: (about:blank) 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. 

(https://www.clinicalsocialworkassociation.org/Announcements/10502812) CSWA - Follow Up to CDC Guidance – 5-14-21
May 14th 2021, 10:32

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.

Laura W. Groshong, LICSW, Director, Policy and Practice  Clinical Social Work Association 
(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org 


(https://www.clinicalsocialworkassociation.org/Announcements/10480403) CSWA - New CDC Guidance on COVID-19 - 5-13-21
May 13th 2021, 16:59

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, Director, Policy and Practice  Clinical Social Work Association(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/10336883) CSWA - CSG Kickoff for Compact Development - 4-20-21
Apr 21st 2021, 21:10

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) 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/) 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, Director, Policy and Practice  Clinical Social Work Association  (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

CSWA
"The National Voice for Clinical Social Work"Strengthening IDENTITY, Preserving INTEGRITY, Advocating PARITY


(https://www.clinicalsocialworkassociation.org/Announcements/10336865) CSWA - Statement on Chauvin Guilty Verdicts – 4-21-21
Apr 21st 2021, 21:05

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 (https://www.congress.gov/bill/116th-congress/house-bill/7120) 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:

lowers the criminal intent standard—from willful to knowing or reckless—to convict a law enforcement officer for misconduct in a federal prosecution,

  limits qualified immunity as a defense to liability in a private civil action against a law enforcement officer or state correctional officer, and

  authorizes the Department of Justice to issue subpoenas in investigations of police departments for a pattern or practice of discrimination.

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, President Clinical Social Work Association (mailto:president at clinicalsocialworkassociation.org) president at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/10114324) Review of Telehealth Laws by State - 2-18-21
Feb 18th 2021, 15:38

Below is an excellent summary of the legal protections for telehealth services, including behavioral health treatment, in all 50 states and District of Columbia (seven states do not have laws about telehealth coverage including AL, ID, PA, NC, SC, WI, WY) put together by the law firm of Foley and Lardner.  The link is (https://www.foley.com/-/media/files/insights/publications/2021/02/21mc30431-50state-telemed-reportmaster-02082021.pdf) https://www.foley.com/-/media/files/insights/publications/2021/02/21mc30431-50state-telemed-reportmaster-02082021.pdf

The areas covered include state laws about coverage for telehealth and audio-only treatment; reimbursement requirements; how long coverage will last; the actual language of the laws in each state; and more. 

Even if you think you know your state’s laws about telemental health, this is a good review and offers ways to improve telemental health laws based on what other states have done.

Let me know if you have any questions about this information.

Laura Groshong, LICSW, Director, Policy and Practice
Clinical Social Work Association(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/10037066) CSWA - Anti-Racism Executive Orders--1-26-21
Jan 27th 2021, 11:37

CSWA is thrilled to see President Biden’s new executive orders today which will be huge steps toward anti-racism and true equity in our country.  They are:

To require fair housing policies and eliminate ‘red-lining’ of housing for BIPOC individuals and families

  To end private prisons which have consistently promoted discriminatory policies and actions toward BIPOC incarcerated individuals

  To combat the xenophobia that exists toward Pacific Islanders and Asian Americans

  To strengthen nation-to-nation relationships with Native Americans and Alaska Natives

In addition, President Biden is embedding racial equity in all Federal agencies.  The President wants his team to serve as a model on diversity, including hiring, purchasing, data and access. He has called racial inequality one of the four “converging crises” facing the nation.

To hear the President’s complete remarks on his new policies go to (https://www.whitehouse.gov/briefing-room/speeches-remarks/2021/01/26/remarks-by-president-biden-at-signing-of-an-executive-order-on-racial-equity/) https://www.whitehouse.gov/briefing-room/speeches-remarks/2021/01/26/remarks-by-president-biden-at-signing-of-an-executive-order-on-racial-equity/ .

CSWA is about to begin a series of six presentations on “Racism and the Clinical Process” in a virtual collaborative format on Wednesday evenings.  For more information go to (https://www.clinicalsocialworkassociation.org/event-4134868) https://www.clinicalsocialworkassociation.org/event-4134868.

CSWA encourages all members to join us in the anti-racism effort which is finally being addressed at the Federal level.

Kendra Roberson, PhD, LCSW, President
Clinical Social Work Association(mailto:cswaorg.pres at clinicalsocialworkassociation.org) cswaorg.pres at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/9828534) CSWA Response to the January 6 Riot
Jan 10th 2021, 14:48

CSWA leadership has been trying to come to terms with the hatred unleashed by our President and his followers on January 6, the very real threat to our democracy, and the blatant racist actions that were on full display.

CSWA first reached out to our members, mindful of the traumatic impact experienced by those near the riot and desecration of the Capitol and of the secondary trauma affecting those watching on TVs, phones, and computers.  The immediate message was a reminder that we must take care of ourselves, emotionally and physically.  As we all know, unless we take care of ourselves, we will have difficulty continuing to treat our patients.

What the so-called “racial-reckoning” of the past summer taught us, was that unjust, unfair treatment of Black and Brown people has, tragically, always been an issue in America. The country, with its obvious privileges for White citizens, has a shaky foundation built on the premise that it is acceptable to colonize and steal Indigenous land, enslave Africans and subjugate anyone non-White, or otherwise marginalized, to second class citizenship.  This foundation allowed Trump’s rhetoric and hate speech to be successful in riling a literal lynch mob to storm the Capitol. The Confederate flag, the White supremacy slogans, and the disturbingly tepid response of the Capitol police to the rioters all conveyed these ideas.  As more comes to light, CSWA will continue working to learn, to educate, to advocate, and to stand with you against institutional and systemic racism and for undisputed equity.

Our actions now must be to hold the President accountable for his role in promoting the riot, in promoting racism, in promoting police and National Guard brutality in BLM protests throughout 2020, and in undermining the electoral process.  Impeachment will thus create a lasting record of his unlawful behavior and prevent him from holding further federal office.  CSWA encourages all members to notify their members of Congress immediately that the President be impeached for his actions.

Here is a possible way to send that message: “I am a member of the Clinical Social Work Association and a constituent.  Given the President’s reckless fomenting of destructive acts on the Capitol, police and our elected officials, I believe he should be impeached.“  Email addresses and phone numbers can be found at (https://www.congress.gov/members?q=%7B%22congress%22%3A117%7D&searchResultViewType=expanded) https://www.congress.gov/members?q={%22congress%22:117}&searchResultViewType=expanded

As always, let me know when you have sent your messages.

Laura Groshong, LICSW, Director of Policy and PracticeClinical Social Work Association(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/9761463) CSWA - CMS 2021 Medicare Coverage - 1-8-21
Jan 8th 2021, 12:14

Below is a summary of the way that the CMS Physicians’ Fee Schedule Rule will impact Medicare psychotherapy reimbursement and telemental health services for LCSWs in 2021. The final Rule was implemented at the end of December, 2020.

CPT Code Reimbursement Changes

90785 Interactive Complexity -10.2%

  90791 Psychiatric diagnostic evaluation +15.7%

  90832 Psychotherapy, 30 minutes with patient +3.0%

  90834 Psychotherapy, 45 minutes with patient +1.5%

  90837 Psychotherapy, 60 minutes with patient -0.1%

  90839 Psychotherapy for crisis; first 60 minutes -8.7%

  90840 Psychotherapy for crisis; each additional 30 mins -8.4%

  90845 Psychoanalysis -9.2%

  90846 Family psychotherapy (no patient present), 50 minutes -11.1%

  90847 Family psychotherapy (w/ patient present), 50 minutes -11.1%

  90849 Multiple-family group psychotherapy -10.2%

  *90853 Group psychotherapy -9.0%

*Group Psychotherapy, 90853, has been added to the permanent list of telemental health services.

In short,

diagnostic evaluation, 90791, has the largest increase in reimbursement. 

  Individual psychotherapy codes, 90832 and 90834 have a slight increase while 90837 has a tiny decrease. 

  Family therapy codes, 90846 and 90847, have the largest decrease over all, while psychoanalysis and group psychotherapy have a somewhat smaller decrease in reimbursement.

  Crisis codes and interactive complexity also have a decrease in reimbursement. 

  Remember that the actual reimbursement varies by region, so consult your Medicare Administrator Contractors if you have questions.

Telemental Health Services

Telemental health videoconferencing services have been extended indefinitely which is great news.  Audio only telemental health services, however, will only be covered through the Public Health Emergency, currently scheduled to end on January 20, 2021.  CSWA is working with the Mental Health Liaison Group to have Congress make audio only treatment covered indefinitely as well.  CMS believes that Congress must make a legislative change before audio only services can be covered.  It is likely that the Public Health Emergency will again be extended past January 20th, but has not been extended yet.

In summary, the cuts were not as severe as had been planned for individual psychotherapy, but somewhat more difficult for family and group therapy and psychoanalysis.  To reiterate: Stay tuned for the extension of the Public Health Emergency, which will allow the continuation of audio only treatment, but videoconferencing has been extended indefinitely.

(https://www.clinicalsocialworkassociation.org/Announcements/9730814) CSWA - Message to Members - 1-6-21
Jan 6th 2021, 19:57

Dear CSWA Members,

Given the chaos of the situation in Washington, DC, I wanted to let you know that CSWA is thinking of our many members who live in and around the area.  It is very disturbing and frightening to watch from a distance; it would be exponentially worse to be in proximity to the destruction that has been inflicted on the heart of our democracy.

Please take care of yourselves.  We hope this misery will come to a quick conclusion.  On top of the pandemic, this traumatic situation will only escalate the anxiety and depression we are seeing in our practices.  We must take care of ourselves so that we can take care of others. CSWA is here for you.

Kendra Roberson, LICSW, President
Clinical Social Work Association(about:blank) kroberson at clinicalsocialworkassociation.org

Laura Groshong, LICSW, director, Policy and Practice
Clinical Social Work Association(about:blank) lwgroshong at clinicalsocialworkassociation.org


(https://www.clinicalsocialworkassociation.org/Announcements/9520583) CSWA - COVID Vaccines for LCSWs - 12-30-20
Dec 30th 2020, 17:07

Since The Aware Advocate article, (https://www.clinicalsocialworkassociation.org/resources/Documents/CSWA%20-%20TAA%20-%20TMH%20and%20LCSWs%20(final3)%20-%2012-28-20.pdf) Nine Months into the Pandemic: Practical Telemental Health for LCSWs, came out yesterday, I’ve received several questions about whether LCSWs are essential workers and when will they be eligible to get the COVID vaccines.  I hope this will clarify this complicated situation.

The Centers for Disease Control and Prevention (CDC) has made recommendations about who should have access to the vaccines and in what order.

There are two Phases, but Phase 1 is divided into three parts when it comes to rolling out the vaccines:

 Phase 1a: essential workers who work in hospitals and long term care facilities. 


Phase 1b: is for all essential workers not working in 1a facilities, including police firefighters, postal workers, teachers, as well as anyone over 75.


Phase 1c: is for all other essential workers such as food service, tech workers, law, public safety, public health, among others, and anyone either between 65-74, and anyone between 16-64 with underlying health conditions. 


Phase 2: will be everyone else. 

These recommendations can be found at (https://www.cdc.gov/coronavirus/2019-ncov/vaccines/recommendations.html) https://www.cdc.gov/coronavirus/2019-ncov/vaccines/recommendations.html .

Note: LCSWs are considered essential workers but whether we fall in 1a, 1b, or 1c depends on where we work and the way that the state we live in is organizing the vaccinations. If we work in a hospital or skilled nursing facility it is pretty clear we would be in the 1a group.  Those of us who are over 75 are clearly in the 1b group.  But all the other factors that affect us make it impossible to say for sure when we you will get be eligible to be vaccinated.

I recommend that everyone google “COVID Vaccination in [your state/jurisdiction]” and find out which state agency is organizing the distribution and policies for how the vaccines will be available.  It may also be prudent to contact your PCP and ask when they may be able to vaccinate you. As you know, some of the vaccines require special refrigeration and may not be storable in doctor’s offices.

Keep in mind vaccination alone may not necessarily make us immune to COVID, but it may certainly help.  Keep following all guidelines for masking, staying 6 feet apart, washing hands, and not spending time in closed spaces with people you do not live with until CDC/HHS say it is safe to stop these practices.  To those of you who have reservations about getting vaccinated, use your judgment and if you choose not to get the vaccine, keep following all the guidelines above.

We will get through this pandemic and are getting closer, even though we may be many months away.  Happy new year to all.

Laura Groshong, LICSW, Director, Policy and Practice
Clinical Social Work Association(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/9430345) CMS Comparative Billing Reports
Dec 14th 2020, 21:50

Since the Affordable Care Act went into effect in 2011, there have been new forms of treatment reviews through Medicare called Comparative Billing Reports (CBRs).  They are designed to identify which LCSWs are considered “outliers” in psychotherapy practice; psychologists and psychiatrists are also receiving CBRs for psychotherapy.  This paper is designed to explain how CBRs are developed, what areas are being used in preparing CBRs, and offer suggestions as to how LCSWs may want to respond to them. 

There are several companies, called Health Information Handlers (HIHs), which create CBRs for the 14 Medicare Administrative Contractors (MACs) in the country, including CIOX, Ability Network, Chartfast, and others.  For more information see (https://www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Systems/ESMD/Information_for_Providers) https://www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Systems/ESMD/Information_for_Providers .

As LCSWs know, psychotherapy treatment can take several months or even years of weekly psychotherapy sessions.  There can be great variation in the areas assessed by CBR companies.  These include 1) how frequently a patient is seen; 2) the average number of sessions for each beneficiary; and 3) how  long each session is/how much reimbursement has occurred.  For LCSWs, these areas are primarily determined by the diagnoses a patient has as found in the DSM-5, and the treatment methods the LCSW uses to treat these conditions.  For example, complex PTSD and complex grief can take longer to treat than adjustment disorders; cognitive behavioral therapy generally takes less time in treatment than psychodynamic psychotherapy. 

To find information on the three areas noted above, the HIH preparing the CBRs reviews all psychotherapy provided by providers for a given MAC.  All LCSWs are compared to all other LCSWs providing psychotherapy. Any LCSW who is in the top 10% in at least two categories, who sees at least 10 Medicare beneficiaries for psychotherapy, is sent a CBR notifying the LCSW. Additional documentation may be required to explain the reasons for the high level of service and/or reimbursement.  

There are numerous evidence-based psychotherapeutic methods which treat different kinds of mental health or substance use disorders.  It is safe to say that the majority of Medicare beneficiaries are senior citizens who qualify for Medicare based on age.  LCSWs who understand the senior population’s emotional difficulties are likely to specialize in this kind of psychotherapeutic work and see more Medicare beneficiaries. It would be a false dichotomy to see LCSWs who see a high number of Medicare beneficiaries as outliers; this is their area of expertise and practice. 

Another difficulty for LCSWs in the development of the CBRs is the comparison of all mental health conditions to all other mental health conditions.  As noted above, there are numerous mental health diagnoses, some of which take longer to treat than others.  Diagnoses should be “apples to apples” if these comparisons are being made.

Thus the LCSWs who are most likely to receive a CBR are those who see a large number of Medicare beneficiaries; who see these patients in long-term therapy; and who use 90837 more often than other CPT codes.  Long-term psychotherapy has been shown to have multiple benefits.   Some studies that have validated this point of view are:

Studies that support a ‘sleeper effect’ for long term psychodynamic therapy in which there continues to be a course of clinical improvement following termination of therapy (Abbass et al., 2006; Anderson & Lambert, 1995; de Maat et al., 2009; Leichsenring & Rabung, 2008; Leichsenring et al., 2004; Shedler, 2010).   

  For patients with a broad range of physical illnesses, there is evidence that short term psychodynamic therapy decreases utilization of health care resources.  Abbass, Kesely, & Kroenke, (2009) did a meta-analysis of 23 studies involving 1,870 patients who suffered from a wide range of somatic conditions (e.g., dermatological, , neurological, cardiovascular, respiratory, gastrointestinal, musculoskeletal, genitourinary, immunological) and found a reasonable effect size of .59 in diminishing the severity of their health disorders.  Shedler notes a similar robust finding stating “Among studies that reported data on health care utilization, 77.8% reported reductions in health care utilization that were due to psychodynamic therapy – a finding with potentially enormous implications for health care reform” (Shedler, 2010, p.101). 

  With respect to more chronic mental health conditions, Leichsenring (2008) comments in this study that a considerable proportion of patients with chronic mental disorders or personality disorders do not benefit from short-term psychotherapy.  This meta-analysis showed that long-term psychodynamic psychotherapy (LTPP) was significantly superior to shorter-term methods of psychotherapy with regard to overall outcome, target problems, and personality functioning.  Furthermore, some cost-effectiveness studies suggest that LTPP may be a cost efficient treatment (Bateman, Fonagy, 2003; de Maat, Philipszoon, Schoevers, Deffer, de Jonghe, 2007).

CSWA hopes that this paper is helpful to LCSWs in understanding the CBR and responding to them.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/Announcements/9367989) CSWA - TAA - LCSW Reciprocity - 11-15-20
Nov 16th 2020, 11:40

The Aware Advocate: LCSW Reciprocity

November 2020

Laura Groshong, LICSW, CSWA Director Policy and Practice

In these difficult COVID times, the issue of being able to practice across state lines has become increasingly important.  Most LCSWs* – not by choice – have become proficient in videoconferencing over the past eight months.  While this has presented challenges and frustrations, the upside is that we now have the technology skills to provide psychotherapy in this format. [See the three CSWA webinars in the Members Only section on the website to review these issues.] With these skills comes the ability to practice with patients who are not close enough to meet with us in the office.  Those LCSWs who have tried to make lemonade out of this development, i.e., expanding their practices online, have found that there are many barriers to practicing across state lines without a license.

This issue of The Aware Advocate, CSWA’s occasional newsletter providing a deeper dive on current matters affecting clinical social work practice will explain the current state of affairs when it comes to practicing across state lines in the time of the pandemic.

History of Reciprocity

Clinical social work licensure laws are governed by the state social work board in that state (there are four states that have governance by a state agency).  These boards and agencies implement rules as to how the laws that created clinical social work licensure are implemented. Most states have rules that regulate which LCSWs may practice in each state.  The Association of Social Work Boards (ASWB) serves as the organization that develops the clinical social work examination and as a ‘home base’ for social work boards but does not have oversight over them.

Until last March, most boards had some process for becoming licensed in a new state.  Almost no states allowed LCSWs to practice without acquiring a license in each state, except in emergency situations (for more information see my book, Clinical Social Work Practice and Regulation: An Overview, 2009.)  Some states allowed an LCSW to become licensed in another state if their license had the same or higher standards of licensure than the state in which they were licensed without going through the whole licensure process of gathering supervised experience hours; the ASWB clinical examination only needs to be taken once and is transferable to any state. Some states do require completing supervised clinical hours again, an onerous task for established clinicians. 

* LCSWs is used to cover all clinical social work titles including LICSWs, LISWs, etc.

The small group of LCSWs that have chosen to become licensed in more than one state have more options for the patients that they can treat. Being licensed as an LCSW in more than one state means higher costs for being licensed in more than one state, different continuing education standards, and more complicated relationships with third party payers.

Current Clinical Social Work Policies on Reciprocity

Many of the laws and rules governing clinical social work licensure reciprocity have changed since COVID-19 has impacted our ability to see patients in person, roughly since March, 2020 when the State of Emergency was declared nationally. Beginning with Maryland, whose Governor allowed any LCSW licensed in another state to see patients in Maryland through videoconferencing without becoming an LSCW-C in Maryland, many states have relaxed the rules in place for which LCSWs can provide treatment in their state.  See my article “Guide to Telemental Health Across State Lines” on 11-11-20 for more details on how to find out the current standards on reciprocity for LCSWs in each state. A good link for this information is  (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=UVJT2Vo7QREOq1D50pLMcPH0nt0zDef4SrUZdOcxP9AEdT5jp51Xs9rT5BPt3ty73zr64aGqvQhIRafS6N5LvyNfX9i4cRfOr41fsN8EpDY%3D) https://www.naswil.org/post/state-by-state-guide-to-the-rules-laws-about-telehealth-services-across-state-lines. It is crucial to check these standards in the state in which you are currently licensed and the state in which a patient resides.

National Policies on Reciprocity

Another outcome of the pandemic is the increased pressure for national reciprocity for LCSWs.  Psychologists have been working toward this goal with a group of states that accepts the license of a psychologist from a state which is affiliated with a group of states who agrees on licensure standards, called PSYPACT.  This is a much easier task for psychologists because all   psychologists licensed as psychologists have a doctorate before they become licensed and that process is standardized.  NOTE: psychologists who have a terminal Master’s degree cannot become licensed as a psychologist and generally become licensed counselors.

The Master’s in Social Work is considered the terminal degree for clinical social workers, though there are several ways LCSWs continue to be trained for 2-3 years after receiving an MSW.  The laws and rules governing this training varies widely from state to state and each social work board has a vested interest in the standards that they have created.  Getting social work boards to agree on standards that would allow an LCSW to practice in another state is challenging.  Nonetheless, CSWA in collaboration with ASWB and NASW, is hoping to find a way to do so and have been working on this goal for the past 4-5 years.  There is a special urgency now because all the patients that we are seeing who we can now treat because of relaxed standards may be unable to continue their work with us, and have that work be covered by insurance,  when the State of Emergency ends.

Summary

For all the reasons noted above, there are problems for licensed clinical social workers in creating a way to use our licenses across state lines.   This may come about in time, but the nature of clinical social work licensing is state based and boards are reluctant to give up their right to create standards of practice for becoming licensed or for allowing reciprocity.  For now, the best way to practice across state lines through telemental health is to make sure you are in compliance with the rules of your own state and those of the patient’s location.  This is likely to change when the State of Emergency ends, likely within the next year.

Let me know if you have any questions at (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org.


(https://www.clinicalsocialworkassociation.org/Announcements/9358808) CSWA - Guide to Telemental Health Across State Lines - 11-11-20
Nov 11th 2020, 17:32

I have been getting many questions about current rules for LCSWs practicing telemental health in states where they are not licensed.  This used to be much simpler than it is now; pre-COVID most states did not allow an LCSW who was not licensed in the same state as the patient to practice there.  These rules were determined by state Boards and there is no national policy at this time.  There are some bills in Congress that would supersede state laws and rules, if they passed, about the ability to practice across state lines.

Since the pandemic began in earnest last March there have been many changes to state rules.  If you wish to practice across state lines, I recommend consulting the following up-to-date guide about this topic which has been developed by the University of Pennsylvania and University of Texas which covers all mental health disciplines: (https://utexas.app.box.com/s/r797qp7woupga5x65yob0ki2u7mbd84y/file/647374529609) https://utexas.app.box.com/s/r797qp7woupga5x65yob0ki2u7mbd84y/file/647374529609 .  It is in Excel format and should be downloaded to read more easily. You should be aware of the rules in the state where your prospective client is a resident as well as knowing emergency services. Additionally, you should keep in mind that the telemental health coverage that currently exists will possibly be eliminated when the State of Emergency ends.  Having a plan for how to manage the treatment around this possibility is part of good clinical practice.

Be sure you have changed your Informed Consent forms to include information about how to file complaints in your state and the state of the patient in addition to following the rules about practicing across state lines. This typically would include providing links to the social work Board of the state in which you are licensed and the social work Board where the patient is located.

Let me know if you have any questions about practicing telemental health across state lines.

Laura W. Groshong, LICSW, Director, Policy and Practice(mailto:lwgroshong at clinicalsocialworkassociation.org) wgroshong at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/9292017) CSWA - Questions about State of Emergency Extension - 10-8-20
Oct 8th 2020, 12:56

I’ve received several questions about the HHS extension of the State of Emergency which I will answer below:

Does the HHS State of Emergency affect reimbursement for telemental health or audio only treatment? No, this only applies to the coverage in some form of telemental health and audio only therapy by Medicare and Medicaid, which is determined by CMS. Reimbursement rates are the same as for in-person sessions.


Does the HHS State of Emergency extension affect coverage and reimbursement by commercial insurers?  The commercial insurers, e.g., Optum, Aetna, BlueCross/BlueShield, Cigna, etc., will develop their own policies about telemental health/audio only coverage.  Many have followed the direction that CMS takes so far.  Reimbursement is more varied.  Some states have required insurers that cover telemental health and audio only treatment to reimburse at the same level as in-person treatment.  Check with your Insurance Commissioner or Social Work Board.


Does the HHS State of Emergency extension affect the ability to provide treatment across state lines without being licensed in the state of the client? The extension does not address the ability to treat clients in states where the LCSW is not licensed. Some states have allowed LCSWs to get a temporary license, some allow temporary reciprocity if an LCSW is licensed in another state. There are a couple bills in Congress that would make this national policy if they are passed. For now, it is the responsibility of the individual LCSW to find out what the policy about treating clients in states where they are not licensed in that state, as well as in the state where they ARE licensed. 


What will happen when the State of Emergency ends to coverage of telemental health and audio only treatment?  That is currently unknown but unless there is a permanent requirement that telemental health and audio only treatment be covered as in-person treatment is, it is likely that insurers will only cover in-person treatment.

In short, coverage of telemental health and audio only treatment will now continue until January 21, 2021, for Medicare and Medicaid.  The reimbursement rates will remain the same for Medicare and Medicaid during this time.  Commercial insurers may follow this policy but are not required to.  The responsibility to find out what coverage is for commercial insurers is our responsibility as LCSWs to check.

Let me know if you have any other questions about the State of Emergency extension at (mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org. 

Laura W. Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/Announcements/9160613) CSWA - New CMS Provider Relief Funding - 8-12-20
Aug 12th 2020, 11:52

There have been several opportunities for LCSWs who are Medicare, Medicaid or CHIP providers to access additional funds if our income has been affected by COVID-19.  Through the Coronavirus Aid, Relief, and Economic Security (CARES-donation) Act and the Paycheck Protection Program and Health Care Enhancement Act (PPPCHE-loan), and the Provider Relief Fund (PRF-donation), the federal government has allocated $175 billion in payments to be distributed through HHS (administered by Optum).

Yesterday the fourth option was announced, the Provider Relief Fund Phase 2, which includes funding for LCSWs, and is detailed below. This is called the Phase 2 General Distribution funding.  This is a way to make up lost income, not a loan. To apply for these funds go to (https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html#key-facts-providers) https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html#key-facts-providersand complete the 6-step application process.

To date only a fraction of the $175 billion in funds has been claimed.  Therefore, CMS is extending access to these funds, which was supposed to end on August 9 for all behavioral health providers and other health care providers, including for LCSWs, until August 28, 2020. The funds distributed will be up to 2% of all income fromMedicare, Medicaid or CHIP in tax years 2017, 2018, or 2019 (not all three, just the highest one). 

HHS will host a webinar on Thursday, August 13, at 3PM EDT. (https://webex.webcasts.com/starthere.jsp?ei=1354695&tp_key=b56041b5d4) Register here  to learn more about the application process, which is somewhat cumbersome.

You need to be able to document lost income due to COVID-19 and provide the income that you received from Medicare, Medicaid or CHIP per your tax returns for one of three previous years to 2020.

I hope this will be somewhat helpful to members who work in these areas and help give some relief for those who have seen a decline in revenue during these difficult times.

Laura Groshong, LICSW, Director, Policy and PracticeClinical Social Work Association

(https://www.clinicalsocialworkassociation.org/Announcements/9087435) CSWA - Treatment Reviews - 7-7-20
Jul 7th 2020, 23:25

I have heard from many members about letters that they have received from a number of insurers in what is being called a “treatment review”.  You will recall that these reviews were part of the process that was put in place when the Affordable Care Act went into effect in 2010.  The basis for these reviews was left up to the judgment of the insurers.  These reviews generally occur every two years.

The last time this came up was in 2018 when Global Tech mailed out 10,000 letters to Medicare LCSWs,  questioning their practice based on three areas: how often a patient was seen; how long a patient was seen; and whether the 90837 CPT code was used regularly.  We are being compared to all other LCSWs in the insurance plan and identified as being ‘outliers’ in one or more of these areas.  As with the last round of reviews, this process is flawed as it does not take into account the conditions being treated.

The current letters are being sent by a number of private insurers including Anthem, Carefirst, and OPTUM (UBH).  Some of the companies are separate entities, such as CIOX like Global Tech.  Some are directly from the insurer.  It is necessary to comply with these reviews to avoid being penalized. 

If you have received one of these letters and would like some citations to support  length and frequency of treatment, here are some examples:

Studies that support a ‘sleeper effect’ for long term psychodynamic therapy in which there continues to be a course of clinical improvement following termination of therapy (Abbass et al., 2006; Anderson & Lambert, 1995; de Maat et al., 2009; Leichsenring & Rabung, 2008; Leichsenring et al., 2004; Shedler, 2010).   

  For patients with a broad range of physical illnesses, there is evidence that short term psychodynamic therapy decreases utilization of health care resources.  Abbass, Kesely, & Kroenke, (2009) did a meta-analysis of 23 studies involving 1,870 patients who suffered from a wide range of somatic conditions (e.g., dermatological, , neurological, cardiovascular, respiratory, gastrointestinal, musculoskeletal, genitourinary, immunological) and found a reasonable effect size of .59 in diminishing the severity of their health disorders.  Shedler notes a similar robust finding stating “Among studies that reported data on health care utilization, 77.8% reported reductions in health care utilization that were due to psychodynamic therapy – a finding with potentially enormous implications for health care reform” (Shedler, 2010, p.101).

  With respect to more chronic mental health conditions, Leichsenring (2008) comments in this study that a considerable proportion of patients with chronic mental disorders or personality disorders do not benefit from short-term psychotherapy.  This meta-analysis showed that LTPP was significantly superior to shorter-term methods of psychotherapy with regard to overall outcome, target problems, and personality functioning.  Furthermore, some cost-effectiveness studies suggest that LTPP may be a cost efficient treatment (Bateman, Fonagy, 2003; de Maat, Philipszoon, Schoevers, Deffer, de Jonghe, 2007).

Data on why it is necessary to use 90837 instead of 90834 is harder to come by, since there is only one minute difference between them.

While it is possible that there may be some audits after the treatment review, this affected a small number of LCSWs in 2018.  The treatment review itself is not an audit.

This process is a frustrating and anxiety-producing one, especially with the difficulties most of us have had moving to telemental health and dealing with the pandemic.  CSWA continues to work with CMS to accept the variations in practice without requiring these reviews.  It may require Congressional action as the ACA was approved by Congress.

Let us know if you have any other questions about this process.  Stay safe and healthy.

Laura Groshong, LICSW, Director, Policy and Practice (about:blank) lwgroshong at clinicalsocialworkassociation.orgClinical Social Work Association
The National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/9054825) CSWA Response to President Trump’s Executive Order:  “Safe Policing for Safe Communities”
Jun 22nd 2020, 11:40

The Clinical Social Work Association offers the following comments on the President’s recently signed Executive Order.

The overall intent of the Executive Order is to develop a federal approach to eliminate misuse of authority by police, as printed in Section 1: “Unfortunately, there have been instances in which some officers have misused their authority, challenging the trust of the American people, with tragic consequences for individual victims, their communities, and our Nation.”   CSWA supports the attempt to resolve the pervasive problem of overuse of force but notes that the Executive Order neither acknowledges the systemic racism that leads to the misuse of authority, nor does it provide a plan of action for enforcing needed change. To be clear, CSWA sees the Executive Order as a work in progress, and, as such, finds two of its main goals worthy of serious consideration.

Section 3 of the Executive Order focuses on information sharing: “The Attorney General shall create a database to coordinate the sharing of information between and among Federal, State, local, tribal, and territorial law enforcement agencies concerning instances of excessive use of force related to law enforcement matters, accounting for applicable privacy and due process rights”.  Such a database would potentially provide critical information for targeting problems to be addressed at the local level through required regular public reports.   

Section 4 would take steps to provide additional mental health and social services to citizens who have mental health and social needs that the police are currently encounter:  “Since the mid-twentieth century, America has witnessed a reduction in targeted mental health treatment…As a society, we must take steps to safely and humanely care for those who suffer from mental illness and substance abuse in a manner that addresses such individuals’ needs and the needs of their communities.”  As clinical social workers, we applaud promotion at the federal level of the use of appropriate mental health and social services as the primary response to individuals who suffer from impaired mental health, addiction, and homelessness. At this time, law enforcement does not offer expert training in mental health treatment or in providing complex social services. Because the police have been increasingly asked to respond to these cases, the result is uncounted wrongful incarcerations and deaths, as noted in the Executive Order. 

CSWA supports the concept of clinical social workers and law enforcement officers working as “co-responders” to address emotional distress and work to prevent wrongful deaths and incarceration. Indeed, at the local level, clinical social workers speak of successful examples of such partnerships: in protective services; on domestic violence calls; on Mental Health Crisis Teams; in prison settings; and more.  Such a pairing tempers the law officer’s militarized tactics, and, as one clinical social worker said, is what “brings a thoughtful calm to the crisis situation.”

A major barrier to the approach promulgated in the Executive Order is the exponential growth of funding for law enforcement, with emphasis on “warrior” attitudes and militarization, while at the same time there has been a concomitant defunding of mental health treatment and social services.  Little discussion of common interests and how to work together has taken place. We strongly believe that any integration of the services provided by law enforcement and clinical social work will need mutual oversight by both Department of Justice and Department of Health and Human Services, with more balanced funding, mutually determined by these agencies.

Having a more nuanced view of what behavior constitutes real danger and what behavior is an expression of unmet social needs has not been part of the law enforcement mindset, and CSWA would like to have an in-depth national discussion about how to facilitate this change.  Clinical social workers can offer expertise in helping create the changes that will help minimize over-zealous law enforcement by using our knowledge of deescalating potentially dangerous situations through access to mental health and social service care.  We welcome a forum for creating true integration of what law enforcement and clinical social work can provide.

Contact:

Britni Brown, LCSW, President(mailto:bbrown at clinicalsocialworkassociation.org) brown at clinicalsocialworkassociation.org

Laura Groshong, LICSW, Director of Policy and Practice(mailto:lwgroshong at clinicalsocialworkassociation.org) wgroshong at clinicalsocialworkassociation.org

Margot Aronson, LICSW, Deputy Director of Policy and Practice(mailto:maronson at clinicalsocialworkassociation.org) maronson at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/9010566) Stopping Racial Aggression in Our Communities | June 2020
Jun 2nd 2020, 17:50

The Clinical Social Work Association (CSWA) stands with the thousands of protesters throughout the country who are advocating for justice in the deaths of Ahmaud Arbery, Breonna Taylor, George Floyd and many others. We also condemn the militarized police tactics being used against protesters and the aggressive police practices used against Black and Brown people throughout the country every day.

Systematic injustices have broken our society, and our communities and clients are hurting. It is imperative that our members are supporting their clients and communities through this time of pain and protest. We are encouraging all of our members to 1) stay informed of current events, 2) read and research to ensure they understand the micro- and macroaggressions their clients face daily, and 3) continue to create environments where clients feel safe in expressing themselves and getting the support they need.

As clinical social workers, we have always advocated against injustices. This is the very nature of our work, and it requires we address both blatant and subtle racial hostilities, anti-blackness, demeaning attitudes towards people of color, and the White supremacist attitudes that our culture and society have tolerated for far too long. In support of this work, CSWA will share resources and information and offer support in a way to help our members support their clients and combat racial aggressions in their communities. We will continue to support you as you support your communities and clients.

Britni Brown, CSWA President

(https://www.clinicalsocialworkassociation.org/Announcements/8993429) Thoughts on Returning to Our Offices - 5-24-20
May 24th 2020, 12:28

Dear CSWA Members,

I have been getting many requests from members for how to safely consider returning to their offices. I will be doing two webinars on this topic on June 11 and 13 (details to follow). But before we start thinking about the understandable wish to get back to our offices, I would like to offer some thoughts about what losing the ability to work there has meant for me.

We tell our patients, rightly, that the office is the safest place there is to look at what has caused the hurt/troubled/traumatized feelings they have. We see ourselves as the owner of this safe space and feel safe there ourselves. Pre-COVID, if my patient or I was sick, it was not the potentially life-threatening issue that it is now.  Also pre-COVID, on the rare occasions that a patient or I was sick, I assessed how much of a risk there is for both of us if one of us gets a cold or the flu from the other.  I had never thought that one or both of us might be putting our lives at risk by being in the same room. 

Now I have those thoughts.  Much as I want to return to my office, it feels like there might be a serious physical risk to one or both of us (or all patients I see).  This feels like a dangerous situation.  I don't know how to be sure that my office is a physically safe space at this point, It doesn't feel like keeping a 6-foot distance, having the right air treatment machines, wearing masks, or all the other adjustments that many are considering will bring back the precious emotional and physical safety that we have lost until we acknowledge that loss.

Painful as it is to lose this safe space for me and my patients, it is a reality. I have been trying to explore this in myself and with my patients. Patients have made many comments about the room I am using at home when we meet online, how it isn’t like the office we used to share and what it means to them. This often leads to some feeling of loss.

To be sure, some CSWA members are more sanguine about working by telephone or videoconferencing. Some had already been working in these ways and did not feel the shift to videoconferencing solely was that different.  I support those of you who are doing well in this way of working and hope you understand that not everyone has the level of comfort with it that you do.

I will be offering members the multitude of issues to be considered when returning to our physical offices in the aforementioned webinars next month. In the meantime, please consider how much we have already lost.  Let’s honestly look at how much we feel that we and our patients have to protect ourselves from each other in the office. In my view, we have to achieve that before we can actually reclaim making our offices a safe space again. Hopefully the loss of our offices won't be going on too much longer, but I am trying to accept the pain that losing it has already caused.

Hope you are all weathering this difficult time as well as possible.


(https://www.clinicalsocialworkassociation.org/Announcements/8964351) “Normal” Psychotherapy: Past, Present, and Future
May 12th 2020, 16:40

by: Laura Groshong, LICSW, CSWA Director of Policy and Practice

May 12, 2020

Just as we are settling in with videoconferencing and (thank you, CMS!) audio psychotherapy, the possibility that we will no longer be forced to maintain the distancing that led to these forms of practice is beginning to emerge in some states . What we can expect in the near to later future is at best likely to vary from state to state and region to region. The range of options for how psychotherapy is conducted is likely be forever changed, as well as the reimbursement that goes with the different options.

LCSWs are flexible and we can process and make choices about all the new information we are getting that affect our practices. We can integrate the changes that we need to make to our well-honed skills to protect ourselves and our patients. Here are the issues (not exhaustive) that seem most important to consider at this point in time, whether you are planning to hunker down with your computer screen for a while, itching to get back to seeing patients in your office, or both.

Dealing with Insurance Issues in the Here and Now

I think it is safe to say that, while LCSWs used to feel frustrated by low reimbursement rates, lack of coverage for more than once a week treatment, and treatment reviews for psychotherapy that lasted more than a year, we now have a whole new set of frustrations.

Among these new frustrations are the variability of private and public insurance policies: first they agree to cover the co-pays, then they don’t; first they will pay the same amount for distance therapy as in-person therapy, then they won’t; first they ask us to use a certain POS code and modifier, then change them without notice while denying claims; and more. Spending hours tracking down provider liaisons about why our claim was denied, or paid at a lower rate, is painful and even scary. One remedy is to engage our patients in the process of finding out what their current co-pay coverage is. Another recommendation is to keep a list of POS and modifier guidance as it comes out, by insurer, and keep it updated. If you find inconsistencies, let your insurance commissioner and attorney general know. This is the best way to get action on insurers’ failure to pay us what they have agreed to when we have complied with stated policies.

Telemental Health Changes and Challenges

I have heard from clinical social workers from all over the country in the past 4 months: the vast majority tell me that they have moved from doing in-person psychotherapy to doing psychotherapy through videoconferencing and telephonic means. Most LCSWs struggled at first with the loss of the in-person office setting and the intimacy that usually goes with it. Staring at a screen for 5-8 hours a day is tiring as we try to maintain the level of empathic attunement that is optimal with what can feel like less emotional information coming through the screen for both patients and therapists. The good news is that the process becomes more ego-syntonic over time and many LCSWs report that they have adjusted to videoconferencing after about two months. Many have gotten training in telemental health (see CSWA website for training by Marlene Maheu of TBHI at www.clinicalsocialworkassociation.org in the Members Only section).

LCSWs have put in the time to explore the best videoconferencing platforms which have good connectivity, reasonable pricing, and adequate confidentiality. Similarly, many LCSWs want to find a different payment system since checks or cash can’t translate well to distance treatment; again, much information on the CSWA website home page – click the red bar.

Others wonder if they can wait the possible 3 months, 6 months, 12 months, or two years, all of which have been suggested as the amount of time it will be take to be safe from COVID-19, to return to office practice. Safety will be based on having ‘herd immunity’, e.g., most people have had it and are immune, or a vaccine has been found; most epidemiologists see this as a 12-18 month process at best. The lack of knowledge about how to plan our lives is anxiety provoking as is the thought that it could be 2-3 years before we can safely return to doing in-person psychotherapy.

CMS has given LCSWs the options to use videoconferencing and audio only psychotherapy to be covered at the same level as office psychotherapy, after much prodding by CSWA and other mental health associations. CSWA is looking at the widespread discrepancy that still exists among private insurers and ERISA plans in covering videoconferencing and audio psychotherapy at all; which insurers and ERISA plans are covering co-pays; and which insurers and ERISA plans will pay for videoconferencing/audio therapy at the same rate as in-person therapy.

What will our practices look like in another 8 weeks, in 6 months, in a year, or maybe three years from now? We have no idea. Different states are following different trajectories based on the way COVID-19 is impacting the people who live there. Some states are coping both with “Hot Spots” and with areas which are lowering the curve and returning to an acceptable level of infection (less than 1:1 increases). The devastating impact of the 15% unemployment rate, higher in some states, affects many of our patients. Fortunately, the Affordable Care Act is still in place so that patients can find insurance if they need it when they lose their jobs.

So far, our state and local governments have been trying to create guidelines that will protect as many people as possible, mainly through physical distancing, hand washing, wiping down all high touch surface, and masks. While this is the legal “frame”, all LCSWs still have to determine what we think is safe in doing our work in the present and moving forward.

Types of Psychotherapy Delivery

There are many questions to be answered by LCSWs as individuals to decide how we decide to practice from month to month and year to year as the pandemic runs its course. The answers may change depending on where we live, state restrictions, our own comfort with telemental health or audio therapy, coverage of these delivery systems and much more. Here is a list of considerations for making these decisions:

Comfort with Telemental Health – the surprise for many LCSWs is that telemental health is much more successful than they thought it would be. Some patients prefer it to in-person treatment, as do some therapists. Deciding whether you want to continue providing psychotherapy through telemental health is a decision that each LCSW will make as an individual.


Regulations by State – many state insurance commissioners and governors have required private insurers to cover telemental health and even audio therapy. It is unclear what will happen if and when COVID-19 is controlled by herd immunity or a vaccine. These solutions are likely to take 12-18 months. The longer that alternatives to in-person therapy continue, the more likely it is that they will be to covered when in-person therapy again becomes a viable option. Until then, following the restrictions of our states is a necessary part of how we practice, i.e., sheltering in place, even if we think we are safe to see patients in-person.


Regulations from Medicare – CMS has been a leader in covering telemental health and audio therapy. The same conditions apply to the continuation of these delivery systems as in the states. Whether we want to use these options will be a personal decision for each LCSW when it is safe to return to in-person therapy. Hopefully, CMS will collect data on the qualitative differences between in-person, videoconferencing, and audio psychotherapy and realize that there is a strong basis for continuing all three options.


Intersection of Diagnoses and Psychotherapy Delivery – there may be a difference in the success of psychotherapy delivery depending on the presenting problems, diagnoses, treatment method used, and length of treatment. There will be much more research into these topics. Each LCSW should consider the intersection of these items when deciding whether to see someone in-person, audio therapy or through videoconferencing.

Confidentiality Issues

CSWA has had several articles about the potential confidentiality problems with using telemental health (see (https://www.clinicalsocialworkassociation.org/sys/website/?pageId=18219) https://www.clinicalsocialworkassociation.org/sys/website/?pageId=18219 for complete list). The use of video platforms that are not HIPAA compliant has been relaxed but this should be taken with a grain of salt; state laws may still be more stringent than Federal laws and therefore apply.

Another confidentiality concern comes into play if and when we are see patients in-person. If, in spite of our best efforts to maintain a COVID-19-free office environment we discover that a patient has been infected, we will need to do contact tracing and notify every other patient who has been in our office within 14 days. Confidentiality is affected by COVID-19 in ways that are not usually a concern in the consultation room.

Safety of In-Person Psychotherapy

There has been increasing discussion about returning to in-person psychotherapy as some states begin to relax sheltering-in-place regulations. Many LCSWs understandably miss seeing patients in-person and are anxious to return to the office. Here are some safety issues to consider in making this decision. It goes without saying that LCSWs should comply with any state or federal laws about sheltering-in-place.

Office sanitization of doorknobs, chairs, tables or any other surface between each patient

  WHO safe distance of 2 meters/6 feet

  Negative pressure ventilation (if possible)

  Antiviral cleaning of any areas touched by patient in waiting room or restroom

  Virus air filtration (if possible)

  Office ventilation (if possible)

  Screen for any flu or cold symptoms

  Removal of porous objects such as stuffed animals, pillow, blankets

  No waiting area/limited waiting area

  Hand washing before entering

  80% alcohol sanitizer in dispenser in office

  Patient and therapist wear face masks

  Self-quarantine if exposed to patient with COVID-10

  Notify any other patient who has been seen the same day that a patient with COVID-19 has

DO NOT see patients who:

Have returned from international travel or from hotspots within the U.S. within the last 14 days

  Have a fever of 100.4°F or greater (consider taking temperature of patients)

  Have a cough, difficulty breathing, sore throat, or loss of taste or smell

  Had contact with a person known to be infected with COVID-19 within the previous 14 days

  Have compromised immune systems and/or present with chronic disease

  Refuse to abide by social distancing

Clinical Implications of Changes to In-Person Practice

While the changes we make to our practices, in-person or distance practice, are based on the real dangers we face, LCSWs need to be aware of the emotional meaning to our patients of such changes. Seeing patients while the LCSW and the patient are wearing masks may have a chilling effect on the office being a safe environment. Use of hand sanitizer and all the other preventive measures may similarly feel like an intrusion into the safety of the therapy setting. Nonetheless. to keep ourselves and our patients safe, we may decide to continue conducting distance therapy, no matter how frustrating it may be. The feelings that patients have about the changes that we make will be ‘grist for the mill’ as always. Of course, we must strive to process our own feelings about the pandemic enough to be able to somewhat objectively help our patients process theirs.

In short, use your own judgment about what form of psychotherapy feels safe for you and your patients. Keep letting insurers know that they need to be consistent and cover videoconferencing and audio therapy. And most of all - stay tuned.

(https://www.clinicalsocialworkassociation.org/Announcements/8938773) CSWA - Audio Only Psychotherapy for Medicare Confirmed! - 4-30-20
Apr 30th 2020, 22:40

I am pleased to confirm that LCSWs can now be reimbursed by Medicare for audio only psychotherapy sessions.  More details can be found at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=TAjKAfUr7AOT6OTe1vKJUw1SP%2FVBbZysPlVcCMA6QObPsXFaEvUFVQwyw7k8IGsu1ZcI0PUoeVRSaexLlZgaPgrdz9czk5fN6cJgbFLH0sA%3D) https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf

The CPT codes are the same as the ones that we use for in-person and videoconferencing sessions, e.g., 98034, 98037, 90791, etc. Any telephonic session that you have conducted since March 1 can be submitted for reimbursement.

The POS code should continue to be 11 as is has been for the past three weeks.  The modifier is 95.

This is the decision that CMS has made for Medicare coverage.  As we know, private insurers often follow the lead of Medicare policy, so there is a chance that we will see more coverage of audio only sessions by private insurers.  Do not take it for granted though, that this is the case. Continue to check the plan that each patient has if you wish to conduct treatment in an audio only format.

This also will not automatically apply to ERISA, or self-insured, plans.  We are continuing to pursue audio only coverage for those plans as well.

This is a big win for LCSWs and you all helped!  When we work together through CSWA, as well as with NASW and the American Psychological Association, we can accomplish great things.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/Announcements/8935598) Information on Second Round of Relief Funds for LCSWs - 4-29-20
Apr 29th 2020, 12:36

Many CSWA Members have wondered about the risks and benefits of applying for the second round of relief funds from the CARES Act General Allocation Fund.  Some of the guidance on applying for these funds is as ambiguous as the explanation for the first round of relief funds, but I will give you my understanding of what it means. 

First, tomorrow is the last day for accepting or rejecting the first round of funds, which did not require an application, as the second round does. The first round of funding went to any LCSW who saw Medicare patients in 2019. There is some confusion about what accepting these funds, either through active attestation or no response, will mean.  But anyone who does not actively reject the funds by tomorrow will be seen as eligible for the second round of funding. 

To be considered for these new General Allocation funds, information on filing the application can be found at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=2a1FQpcQyA4eDU9vUTAPpcXcgb4um4rX3MsG2d%2FjZvtf40j%2BqTjCvWiAbdg4Y%2BpAMwuQJ1CchG%2FVKZX7NYkkTdDAM4sJdA1KUczHU%2B5ORQ8%3D) https://chameleoncloud.io/review/2977-5ea0af98f0fd0/prod  .  A couple of changes are 1) you must file your 2019 tax return, and 2) you must estimate your lost income for March and April of 2020.  These funds will be available until they are exhausted and will go out as claims are validated.

There is no guarantee that you will receive these funds, or a formula for how they will be distributed.  The main thing to remember is that if you want to be considered for receiving them, apply sooner rather than later.  Giving our tax returns to HHS is a calculated risk.  If the information is accurate, there should be low risk; if not, there could be an audit of your tax return.  Estimating lost income may be difficult and could lead to problems if it is found to be overestimated.  But for some LCSWs, it may be worth the risks of applying for these funds because of the need for more income at this perilous time.

Remember - this is a separate source of funding from the Payroll Payment Protection (PPP) funds, which LCSWs are also eligible for. PPP allows businesses to borrow 2.5 times our average monthly “payroll costs”, a bit of a misnomer, because when you look at the actual definition payroll costs include self-employment income, e.g. net income reported on Schedule C.  This program applies to anyone with self-employment income and is a loan which must be repaid. 

I hope this helps you make the decision that is right for you about applying for these funds.  Let me know if you have any other questions.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/Announcements/8924403) CSWA - Helping Those in Need During COVID-19 - 4-23-20
Apr 23rd 2020, 15:09

I hope you are all making the adjustments that most LCSWs have made to preserve the safety and health of ourselves and our patients.

In addition, there are many people struggling to meet basic needs and solve the ways to prevent COVID-19.  Here are a few that could use your help in doing their good work:

CDC Foundation is an independent nonprofit created by Congress to mobilize philanthropic and private-sector resources to support the Centers for Disease Control and Prevention’s critical health protection work.((https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=GE4cXgBBYG3vTXOHTZlU%2BGGHMX5qLofNkNuO7x6FjUpu3wz09QI00HRunSxtdk6m8jylNwLch%2BfnBOmgikjA341vvDENrVBgeHbrZzCe1%2F4%3D) https://www.cdcfoundation.org/) 


Feeding America is a nationwide network of more than 200 food banks that feed more than 46 million people through food pantries, soup kitchens, shelters, and other community-based agencies.((https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=EW6M3LLEXoTF0dsDXiQRdb3om2BlPfpBopDe4D1hBHf3kio3UcmHbhKz3FKUb825f00xR1GCB1NDaGI3qZhhcvhC2xhnmynwLuzktYxM0dY%3D) https://secure.feedingamerica.org/site/Donation2?df_id=28150&mfc_pref=T&28150.donation=form1&s_src=Y20XP1B1Y&s_subsrc=c&s_keyword=feeding%20america%20donations&&gclid=CjwKCAjw-YT1BRAFEiwAd2WRtrjw_E_IYRzcDsp7_2McRYNkC8ldKLgm15WD4vlzlHIUzz11LnU6AhoCipgQAvD_BwE)


Meals on Wheels supports individuals who are elderly, disabled, chronically ill and home-bound by delivering nutritious meals, reducing hunger, improving health and promoting independence.((https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=zr0JXH453V%2FjXvgm1g5JcWDO4Fk9flIWv5U4O%2FaaAp5c1%2BdxMUtw0TuSL3yQbi1pMYnqctLqhTobkbREr2OFgnNbWQs7a64TVWb0t5mVGdE%3D) https://ams.mealsonwheelsamerica.org/eweb/DynamicPage.aspx?WebCode=globaldonate&site=mowa&CampCode=AnnualCampaign&AplCode=AnnCampWeb&_ga=2.86054296.1679140158.1542118140-1937589897.1533304096)


The National Domestic Works Alliance has set up a fund to provide immediate financial support for domestic workers, and enable them to stay home and healthy — protecting themselves, their families and their communities while slowing the spread of the Coronavirus.((https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=I866lV1%2B%2BKV2zHIOAm2qdxK5c7ieQq4O71RI0Imr4jCVq3T8oYDGOWuno8qEgpdpziISH0jPB93QmVvewwQasRA%2FVb4gSwvbr9JoyEJjVWo%3D) https://www.domesticworkers.org/)


One Fair Wage Emergency Coronavirus Tipped and Service Worker Support Fund provides cash assistance to restaurant workers, car service drivers, delivery workers, personal service workers and more who need the money they aren’t getting to survive.((https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=P8BLpcMsJtu7vAyWloRackVmVTDGlpVkiNtlE1a0gD%2FRRZ5FJ6RY1uFMVQ8dlqC35jqPPZKph7sc0IAOn3IuBN7JaYo%2FTPpcodT8W7i%2FYU0%3D) https://ofwemergencyfund.org/)

Helping others is a big part of our clinical social work values.  I hope everyone can find a way to chip in for those who are in need.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/Announcements/8909137) CSWA - Concerns about Relief Fund Payments - 4-18-20
Apr 19th 2020, 12:44

Dear CSWA Members,

There are several concerns about the potential risks of accepting the funds which many members have received as compensation for the potential loss of income due to COVID-19. There is no clear guidance on the meaning of the Relief Fund Payment Terms and Conditions, some of which are ambiguous, but the risk which accepting the funds causes seems less problematic than so have suggested. This is not legal advice, but my best guess about what the likely outcome of accepting the reimbursement will be and factors you may want to consider in making your decision.

Purpose of Funds – This statement in the Relief Fund Terms and Conditions is unclear when applied to psychotherapy: “The Recipient certifies that the Payment will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus.”  This can be interpreted in the broadest of terms, i.e., that there is anxiety and depression about the pandemic which almost all patient face even if that is not their primary reason for treatment, or in a narrower way, that the presenting problem is specifically emotional distress about being ill with COVID-19, having family members with COVID-19, or fears about this happening.  We must use our judgment about which way to interpret this section.

Meaning of UHC Involvement in Payments – this may be unusual in the way we are generally paid but this public/private partnership should not have any impact on our status as out-of-network providers, if we are. UHC is a pass through in this case, writing checks for HHS; Medicare does not accept out-of-network clinicians so there is no possibility of that option being limited for beneficiaries.

Out-of-Pocket Payments – finding LCSWs to provide services is challenging even without the additional burden of the emotional stress that has been created by the pandemic. Accepting the reimbursement requires us to agree that we have not charged anyone our out-of-network rates if we saw them outside of Medicare and that we will not do so going forward.

Consequences of Attestation – there may be some auditing of how the funds are used but it seems unlikely that the amount of money being distributed to LCSWs will be targeted. Signing the attestation that you have received the funds and intend to use them to treat Medicare beneficiaries with COVID-19 mental health problems seems like it is likely, to one degree or another. It is probably less risky if you affirmatively accept or reject the funds that you have received, after weighing all the factors involved.

Keeping the funds may be appealing and well-earned, but some members have decided to reject them because of the involvement with UHC, the ambiguity about whether the work we are doing meets the criteria for accepting the funds, and the possibility of being audited is not worth the risk.  Each of us will need to come to our own conclusions about this difficult decision.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=KUcKg5%2BEkqBeqrLt3Fks%2BrQ9IhqLe7iukIaFejQ%2FjamPUcPKVwaDFfyouE5H4nE3prnFflKR1LFhwDMZ8vEogzGtiDZOzCXRxgyEUQgDI1k%3D) www.clinicalsocialworkassociation.org

Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY


(https://www.clinicalsocialworkassociation.org/Announcements/8908076) CSWA - CMS Reimbursements for Medicare - 4-18-20
Apr 18th 2020, 16:14

Dear CSWA Members,

Many members have begun to get Medicare ‘reimbursements’ as a result of the CARES Act. This has caused some confusion which I will try to clear up here.

1.   Funding Source - These funds come from the from the $34 billion provided in the Coronavirus Aid, Relief, and Economic Security (CARES) Act through DHHS. The CARES Act appropriation is a payment that does not need to be repaid.

2.   Amounts Reimbursed - The amounts are based on the treatment that an LCSW provided to Medicare patients on a fee-for-service basis in 2019; this does not apply to Medicare Advantage patients. The amount is based on the LCSW’s share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.

3.   Reason for Reimbursement – Though these funds are primarily for services provided connected to COVID-19 issues, it applies to other mental health problems as well. It goes without saying that there is widespread anxiety and depression as a result of the pandemic which affects almost everyone in the country.

4.   United Health Care Role - The reimbursements are distributed by HHS through United Health Care in a public/private partnership. Most reimbursements are under $2000, many under $500 from what I have heard.

5.   Attestation - You can either ‘attest’ that you accept the funds directly at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Vaktee95xvGxs085Z%2BeX%2BUAEwIVsnWcXvCl8W762uVlo0cBDuDatIRo27bH1T8rbsczIytH2qJipLAJjdNumwU99sFx9PIx602U1QhzM76k%3D) https://covid19.linkhealth.com/  or do nothing which will be seen as an affirmative attestation in 30 days from distribution.  There is no penalty if an affirmative attestation is not made.

For more information go to (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=BhoRqU85%2BGZzumnPz9Kp25xJReo3vQ7cofQuRd%2BzL9sqUlj31e%2BevNjhDhYYYYwtTr9YWa5Sr%2BCGJZMEEY0rkLXdbvnd3pWZXeuGLANZyOI%3D) https://www.cms.gov/newsroom/press-releases/cms-approves-approximately-34-billion-providers-acceleratedadvance-payment-program-medicare , (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=2GgjwkVl55SaWy2z9xQ9LlNvMrUcAG3CBczv1%2Bg8Uz4Cv2uw9Xxhafr2I46kCkaxHTbHzTWlEHTSPZRd1%2Fbf0%2F%2B%2FHYD4TUbySc0rBKnu6CY%3D) hhs.gov/providerrelief  or call the CARES Provider Relief line at  (866) 569-3522.

There is another program which provides loans to LCSWs and other health care providers who need financial assistance as a result of the COVID-19 crisis. The CMS Accelerated and Advance Payment Program has delivered billions of dollars to healthcare providers, including some LCSWs. These accelerated and advance payments are loans that providers must start paying back within 120 days and complete paying back by 210 days. For more information on applying for these loans, go to (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=BhoRqU85%2BGZzumnPz9Kp25xJReo3vQ7cofQuRd%2BzL9sqUlj31e%2BevNjhDhYYYYwtTr9YWa5Sr%2BCGJZMEEY0rkLXdbvnd3pWZXeuGLANZyOI%3D) https://www.cms.gov/newsroom/press-releases/cms-approves-approximately-34-billion-providers-acceleratedadvance-payment-program-medicare

I hope this is helpful.  Let me know if you have any further questions.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=rzPgMcl%2BHYZHrRViF41WMzix2Zw9fVYxBGaRTrSUxpOTB5wH4EYktlVsWNDB1Dz2vMuad6joaYNak5G9LEgYf1Cu0Gz39nrgQQNrGGPixUY%3D) www.clinicalsocialworkassociation.org

Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/8904829) CSWA - Clinical Issues in Virtual Telemental Health Treatment - 4-16-20
Apr 16th 2020, 19:36

Many clinical social workers have noticed the way that our current shift to working through telemental health platforms has affected the treatment relationship and our own view of our work. This summary of the discussions that we have had in the CSWA "Open Webinars" may help us think through these changes. The summary can be found at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Bx1zst4GzHDdxT1PT2cOhq7kCHhmnppyY9P7eaYpJ68jnd%2B2YcZVUzmY%2Fu%2Fgt%2BewFZveps0GROvIHKZyPZzVBCLOltXWjLWd0I6t9vE1etU%3D) CSWA - Clinical Issues in Virtual Therapy - 4-16-20.docx .

Another "Open Webinar" will be held this Sunday at 2 pm ET/11 am PT.  This is an excellent way to connect with colleagues and navigate the brave new world (for some) of telemental health. All CSWA members can register at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=k2gjpqgpeNAf%2Bc2%2FF0eU3RQ37c7qGYbm51mG8WdLZS53CKqbq%2FIGnfzhY5XBsJzLpbUFx8y0R6tmI7MnjksKdaRnxPq%2B5YXx9vv3QFogGuM%3D) https://www.clinicalsocialworkassociation.org/event-3814579 . Hope to see you then.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=2CKfjlgai4gLCM5r8H80zsYXz%2FaKdLJHbqC47jwf7PBK0YYLPnUxwAsAHvEQH238OGHxSbFA9EItyITK5F%2Fbs27QsDx3zEILr1VONYw4ABo%3D) www.clinicalsocialworkassociation.org

Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY


(https://www.clinicalsocialworkassociation.org/Announcements/8888272) CSWA - Summary of Changes to LCSW Practice due to COVID-19 - 4-8-20
Apr 8th 2020, 19:30

Below is a summary of most of the changes LCSWs have faced in the past few weeks as we have moved to telemental health psychotherapy at (https://www.clinicalsocialworkassociation.org/resources/CSWA%20-%20Summary%20of%20COVID%20Changes%20for%20LCSWs%20-%204-8-20.pdf) CSWA - Summary of COVID Changes for LCSWs - 4-8-20.pdf

Please let me know if you have questions that are not addressed or corrections to the material presented.

Laura Groshong, LICSW, Director, Policy and Practice

(https://www.clinicalsocialworkassociation.org/Announcements/8887616) Updates on LCSW Practice Changes - 4-8-20
Apr 8th 2020, 12:59

Below is an update on issues related to the changes to LCSW practice since we started using telemental health practice.

I can't stress enough how important it is to let your members of Congress know about the harm being caused by the lack of access to patients who do not have computers or smart phones. The only way to conduct treatment with them, primarily Medicare beneficiaries, at this time is through telephonic sessions. HHS has the ability to allow expanded coverage of telephonic sessions under the CARES Act. We need to keep up the pressure that Sec. Azar make this change. See the suggested language below to send messages to him and members of Congress.

I thought you might like to see the letter sent by CSWA to Sec. Azar and CMS Administrator Verma which can be found at (https://www.clinicalsocialworkassociation.org/resources/Documents/Templates/CSWA%20-%20Letter%20on%20Audio%20Only%20Coverage%20-%204-7-20.docx) CSWA - Letter on Audio Only Coverage - 4-7-20.docx

As for those members who have had questions about small business loans for self-employed business owners, the programs that were set up under CARES are swamped. If you have applied, do not expect a response for about a month. Priority is being given to large corporations. I will provide more information on this topic as I have it.

Let me know if you have any other questions in these difficult times. Keep your patients and yourselves healthy, rested and safe.

“I am a constituent and a member of the Clinical Social Work Association. I have patients who are unable to meet with me in person for psychotherapy because of the COVID-19 crisis and do not have access to a smart phone or computer. The Centers for Medicare and Medicaid Services have not expanded coverage of psychotherapy to telephonic sessions, only videoconferencing; however, the only way I can provide services to these beneficiaries is by telephone.

Some enlightened insurers like Cigna and Aetna have already allowed some temporary coverage of telephonic psychotherapy sessions. Some states such as Texas, and Ohio have also required temporary coverage of telephonic psychotherapy sessions by private insurers.

Please tell CMS [and/or private insurers for state legislators and Insurance Commissioners] to approve coverage of telephonic psychotherapy sessions, sorely needed in these fraught times, for Medicare beneficiaries [and other enrollees privately insured] who may be isolated, emotionally fragile, and in need of mental health services."

You can find contact information for members of Congress at (https://www.house.gov/representatives) https://www.house.gov/representatives and (https://www.senate.gov/general/contact_information/senators_cfm.cfm) https://www.senate.gov/general/contact_information/senators_cfm.cfm. You can find email addresses for your state legislators and Insurance Commissioners by going to your state websites.

(https://www.clinicalsocialworkassociation.org/Announcements/8879371) Updates on Zoom and Medicare - 4-3-20
Apr 3rd 2020, 21:09

Below is an update on several issues related to our transition to telemental health services.

1. Zoom – There have been concerns raised about the security of the Zoom platform and Zoom is taking steps to address these issues. A more secure system will be in place by April 5 for the ZoomPro and other platforms Zoom offers.  Here is a summary of what will be happening:

Zoom

We’re always striving to deliver you a secure virtual meeting environment. Starting April 5th, we’ve chosen to enable passwords on your meetings and turn on Waiting Rooms by default as additional security enhancements to protect your privacy.

Meeting Passwords Enabled “On”
Going forward, your previously scheduled meetings (including those scheduled via your Personal Meeting ID) will have passwords enabled. If your attendees are joining via a meeting link, there will be no change to their joining experience. For attendees who join meetings by manually entering a Meeting ID, they will need to enter a password to access the meeting. 

For attendees joining manually, we highly recommend (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=0JGcU9aDMYX8RFFYtw8G%2BC9mtQ1739DQ9N0%2BHwV0jg4g3T%2FIlv%2FE%2BmJ%2F4bLAAOneO%2FpGlbk0nFRAT1fNtZhFdlt3zzMscfnEtoDMyZ5VJS8%3D) re-sharing the updated meeting invitation before your workweek begins. Here’s how you can do that:

Log in to your account, visit your (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=5FiqV2eYERtMd5i7%2BisI6oCpLhjI85LENR0qU3Y2dZ1j0YJqNJ1ekb95k5CkXgSdmKpeWwJ47jL62TSXPmXoZn8hZccSKzqZYxx75D2Sb%2FM%3D) Meetings tab, select your upcoming meeting by name, and copy the new meeting invitation to share with your attendees. For step-by-step instructions, please watch this (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=quadgtYhxaSkzztKmJEHRswAVe0R6gRGoYTgc9uLfF1MyEIrZkg6Wfpztb89fThx0Wj7jKJ3VZHBKRCO%2BVVo51pAwd8g4XhraCrsWrz9Sjw%3D) 2-minute video or (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=SMngTBDqgDmYfHWIl18rrDL8IIH7NP%2F3WS3BT%2BgjRafz4A1rBvljw8zV8dSQWkHWyrsI4KdVXCpwiEjRpsdMX5oJ55twhpJjrJfS%2BZ9Wduo%3D) read this FAQ.

For meetings scheduled moving forward, the meeting password can be found in the invitation. For instant meetings, the password will be displayed in the Zoom client. The password can also be found in the meeting join URL.

Virtual Waiting Room Turned on by Default
Going forward, the virtual waiting room feature will be automatically turned on by default. The (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=dr6rasUCJx8T9kff%2FkkPkcYqMoQQ9Yk5Af2HQlKllAbbfF1aT0RSQ%2BHhKeqXFcbdCDQdYFlUqh%2BwcumsHfIdw9729P85nH9bhFdOV8uWJSs%3D) Waiting Room is just like it sounds: It’s a virtual staging area that prevents people from joining a meeting until the host is ready. 

How do I admit participants into my meeting? 
It’s simple. As the host, once you’ve joined, you’ll begin to see the number of participants in your waiting room within the Manage Participants icon. Select Manage Participants to view the full list of participants , then, you’ll have the option to admit individually by selecting the blue Admit button or all at once with the Admit All option on the top right-hand side of your screen.  For step-by-step instructions, please watch this (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=UZvodeQR9j94MnsrZdSixb1DcIMwvkz2ChkpnvtgwkdCyGx8imliGPxL2TBdjM4x%2FBJXcq5oD%2BNiBfWtDll9xp3kB1T4G8N%2BwC6RjQOHdro%3D) 2-minute video.

Check out these resources to learn (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=dr6rasUCJx8T9kff%2FkkPkcYqMoQQ9Yk5Af2HQlKllAbbfF1aT0RSQ%2BHhKeqXFcbdCDQdYFlUqh%2BwcumsHfIdw9729P85nH9bhFdOV8uWJSs%3D) How to Manage Your Waiting Room and (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=BBHYezQVO6wT2m4agkf3wttyV9xCIrpF3fKq2wgAIMDTuJfyW%2FhAuPKGjKyaV%2FpkJtKG11ILZsL9M4qrUm60zSUZFLbV7b8UDr1BOiRTRf0%3D) Secure Your Meetings with Virtual Waiting Rooms.

For more information on how to leverage passwords and Waiting Rooms to secure your meetings, please visit our (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=SMngTBDqgDmYfHWIl18rrDL8IIH7NP%2F3WS3BT%2BgjRafz4A1rBvljw8zV8dSQWkHWyrsI4KdVXCpwiEjRpsdMX5oJ55twhpJjrJfS%2BZ9Wduo%3D) Knowledge Center, attend a (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=ErNQDCG8uH3tHVZhSYCeFy8PIG520rkEEr6dwOgD9Y%2F0r3mPW8aq4pM2a%2B4JLfUHtwfnb%2BJoHXTTibIB8o0k9Z%2Fl6kKF0rT8nBuFUmMn8Dg%3D) daily live demo, or visit our (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=68H0mpMhr0%2F2AB2tNPW2tzzYGCpNiK3LImEu8RcXVU65pj%2FUyHEBJVbw7b5tpLFNE6YKgForT8ofTGLROnwy%2FXEjLs41iURb5XB5kJuhbyY%3D) Blog.

Please reach out to our Support Team if you have any questions at (mailto:support at zoom.us) support at zoom.us.Medicare Issue

Medicare has made several changes in the past few days, revising some previous guidance. Below are some of the most important changes. To see the latest guidance, go to (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=DeP%2FSC%2F0ZPcKkoFEWcxuztPwDjT5msCvqDbAIudifE3dvzf79zFA%2BfvYscPZM6TLXVUjig5cVtWWshEi%2F9yvJfHFDIjqSyYpskDrpc753bg%3D) https://www.cms.gov/newsroom/fact-sheets/additional-backgroundsweeping-regulatory-changes-help-us-healthcare-system-address-covid-19-patient 

2. Medicare Coding – the Medicare coding for psychotherapy continues to be in flux.  Here is Guidance which came out today saying we should now use the POS we would have used had the service been provided in person, e.g., “11” for in-office psychotherapy, and the modifier “95”:

Billing for Professional Telehealth Distant Site Services During the Public Health Emergency — Revised (4/3/20)

This corrects a prior message that appeared in our (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=x2mDdzTe%2Fn2woWxnWXMpH6yHNAXkJhXVTfEDn9vD8YYOnRa6hv8o33FP4fPtFw%2BcNJW0fMTHPZxNAWPUqoSUUZ8saCeS4lrPQkfKH0IEPr0%3D) March 31, 2020 Special Edition.

Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with:

Place of Service (POS) equal to what it would have been had the service been furnished in-person

  Modifier 95, indicating that the service rendered was actually performed via telehealth

As a reminder, CMS is not requiring the CR modifier on telehealth services. However, consistent with current rules for telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:

Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology, use GQ modifier

  Furnished for diagnosis and treatment of an acute stroke, use G0 modifier

There are no billing changes for institutional claims; critical access hospital method II claims should continue to bill with modifier GT.

3. Medicare Reimbursement – this is the area that has seen the most confusion; previous guidance had stated that reimbursement would be the same for telemental health as in-person treatment.  So far, there have been payments made for telemental health that are 7-8% lower than previous reimbursement, some that have remained the same  This seems to vary by region. Contact your MAC to discuss if you have received a payment that is not consistent with previous reimbursement.

4.   Medicare Provider Enrollment - CMS is making it easier for providers to enroll in Medicare. Local private practice clinicians and their trained staff may be available for temporary employment since nonessential planned medical and surgical services are postponed during the pandemic. 

5. Telephonic Coverage – this is the area that has caused the most confusion based on the March 30 guidance: “Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. During the public health emergencies, individuals can use interactive apps with audio and video capabilities to visit with their clinician for an even broader range of services. Providers also can evaluate beneficiaries who have audio phones only.” The problem with this statement for LCSWs is that there is only one service that is expanded for psychotherapy, e.g., the E/M 10 minute evaluation, NOT psychotherapy sessions.  CSWA is still working hard to get coverage of telephonic sessions by Medicare.  At present, they are not covered. Continue to let your members of Congress know that this is a problem as noted below. 

CSWA will continue to provide information on regulatory changes to members that affect LCSW practices which will likely be continuing for the next month.

Please let me know if you have any other questions.Laura Groshong, LICSW, Director, Policy and Practice(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=RFULq%2BV%2BoM%2F%2B2JaLvNAf8Uu80VW24tRI7JCyXDSFaIipcgPck%2FyKFAI1Fk5MndMcMEvo4yTGdr9PD3eat7aDTMP2ruj26j9udwxUupiU%2FgA%3D) ww.clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/8871138) Emergency Reciprocity and More - 3-31-20
Mar 31st 2020, 19:53

Things are changing rapidly to give people better access to mental health services. Here is some more information that affects LCSWs.

First, a correction. Maryland has not required coverage of telephonic sessions; Gov. Hogan was one of the first states to allow emergency reciprocity for LCSWs not licensed in Maryland. Apologies for the error.

Along these lines, many states have followed his example and are now allowing LCSWs to practice in states where they are not licensed, as long as they are licensed in at least one state. There are many variations so make sure to read the emergency declarations carefully.  The list helpfully created by Shrink Space can be found at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=y8T%2FnSUQ73TDV58FXhjPtxarUvOSttvPG%2FQ9eyEv27%2Ff4aKMVIH0Snk%2BpzE3SPsLcGkUgUM%2BT6ld4zpUltBw9KUtpN6akZAXtHs9NPiKX4g%3D) https://theshrinkspace.blog/covid-19-teletherapy-across-state-lines/ . It is being updated daily.

Finally, sending a message like the one below to the President would be a good idea. You can send it to (https://www.clinicalsocialworkassociation.org/www.White%20House.gov) www.White House.gov.

I will be sending more information as it comes in. Let me know about any changes to practice in your state/jurisdiction.

“I am a constituent and a member of the Clinical Social Work Association. I have patients who are unable to meet with me in person for psychotherapy because of the COVID-19 crisis and do not have access to a smart phone or computer. The Centers for Medicare and Medicaid Services have not expanded coverage of psychotherapy to telephonic sessions, only videoconferencing; however, the only way I can provide services to these beneficiaries is by telephone. 

Some enlightened insurers like Cigna and Aetna have already allowed some temporary coverage of telephonic psychotherapy sessions.  Some states such as Texas, and Ohio have also required temporary coverage of telephonic psychotherapy sessions by private insurers.

Please tell CMS [and/or private insurers for state legislators and Insurance Commissioners] to approve coverage of telephonic psychotherapy sessions, sorely needed in these fraught times, for Medicare beneficiaries [and other enrollees privately insured] who may be isolated, emotionally fragile, and in need of mental health services."

(https://www.clinicalsocialworkassociation.org/Announcements/8862219) Summary of Telemental Health Basics Webinar
Mar 27th 2020, 11:08

The complete change to our personal and professional lives in the past two weeks as the result of the COVID-19 pandemic has been overwhelming.  It has led to feelings of helplessness about how to do our jobs as clinical social workers that many of us have not had to face for decades.

CSWA has tried to outline the changes that most private practitioners are facing and ways to adjust our practices.  Once we get past the shock of feeling disoriented, the shift to telemental health that we need to make for at least the next 2-3 months are manageable.  Below is a brief summary of the areas that should be considered.  The complete hour-long webinar can be found under the Members-only area of the CSWA website.

(https://www.clinicalsocialworkassociation.org/CSWA-Webinars) CLICK HERE TO ACCESS THE EMERGENCY TELEMENTAL HEALTH WEBINAR

Practice Considerations:

Find a private neutral space to use as a home office

  Encourage patients to find a private home space to ‘meet’ with you as well

  Change Informed Consent form to reflect policies about telemental health (template at (https://clinicalsocialwork.wildapricot.org/Informed-Consent-for-Telemental-Health) https://clinicalsocialwork.wildapricot.org/Informed-Consent-for-Telemental-Health)

  Change Communications Policy to reflect limits on access is needed (template at (https://clinicalsocialwork.wildapricot.org/Communication-Policy-Template) https://clinicalsocialwork.wildapricot.org/Communication-Policy-Template)

  Change payment method to use online payment system, IvyPay or direct credit card billing recommended (template at (https://clinicalsocialwork.wildapricot.org/Credit-Card-Authorization-Form) https://clinicalsocialwork.wildapricot.org/Credit-Card-Authorization-Form)

  Check reciprocity with other states - (https://www.aswb.org/regulatory-provisions) https://www.aswb.org/regulatory-provisions

  Check CMS Fact Sheet on Videoconferencing:  (https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet) https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

  Check CMS expanded simplified Medicare provider enrollment: (https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf) https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf

  Expanded use of telemental health platforms without BAA; no HIPAA enforcement

  Check each private insurer by patient as to coverage of telemental health, telephonic health, in-network only, out-of-network allowed

  Check with each private insurer as to which modifier needed on CMS-1500; make sure “02” is right place of service

  Advocate for coverage of telephonic psychotherapy sessions, needed for older patients

  Continuing education will change since in-person events not available

  Practicum requirements will change as students cannot meet directly with clients

  Access to ASWB tests will change, not clear how will be accessed
CSWA is offering more guidance on the changes created by this pandemic.  There will be two Open Webinars to discuss the questions LCSWs have and provide mutual support on March 28 and 29 (see Upcoming Events at CSWA website). There will be a two-hour conference on more detailed discussion of how to provide telemental health.  We want to be your partner in this time of flux and transition.

(https://www.clinicalsocialworkassociation.org/Announcements/8838214) CMS Guidance on Medicare Videoconferencing
Mar 17th 2020, 17:26

I spoke this morning with Karyn Anderson, CMS Technical Director as she was about to develop this guidance from CMS on telemental health services.  She was quite receptive to our concerns.

I am happy to report that CMS has approved an expansion of Medicare telemental health to cover anyone we see, new patients or ongoing ones.  Unfortunately, it does not include telephonic sessions. CSWA will keep working to get them included as well.  To see the FAQ on all the changes included see (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=HSuqJuJpwXl32XDXwmbGQ%2FOGUfUi6MHdS3zfyOreCfCTVSCORcZpBdrkO%2FV0O9dhCZi6qchFeIpIq2IEJBDegvxjE2CMBjtd5xLx8mETPWs%3D) 3.17.20 COVID 19 Telehealth Waiver FAQ Final.pdf(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=HSuqJuJpwXl32XDXwmbGQ%2FOGUfUi6MHdS3zfyOreCfCTVSCORcZpBdrkO%2FV0O9dhCZi6qchFeIpIq2IEJBDegvxjE2CMBjtd5xLx8mETPWs%3D)  

Please read this carefully and let me know if you have any questions.  

Laura Groshong, LICSW, Director, Policy and Practice, Government Relations ChairClinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/8837259) Info on Videoconferencing
Mar 16th 2020, 12:17

There have been many questions about how to establish a telemental health practice as we address COVID-19.  Here are some ideas about what to consider.

Take a course to understand the basic skills that are needed to provide telemental health videoconferencing. The TBHI Courses offered by Marlene Maheu are excellent and can be found (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=EFbjvZkWqN%2BBzuQ8mOPEs2atUPkcdvIgwHFWbD5WtFExC1tx%2Flf4KrWunsG1wmwC9Ep8jrahPAClJXpQrddK9022c%2FtPThsF%2BY5wV7nkuuk%3D) here.   There are many others, but Dr. Maheu has based hers in part on the ethical standards for clinical social workers.

  Read the Technology in Social Work Standards, that CSWA helped develop, which can be found (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=JpHHv3jIfa0Yq5v0AtWw3hy3wgzTqqVu8fQSkLpkXodHc%2F%2Bk9LhKSAS2aoQlBamM00mwFP%2BV38zt9ydJ2iH9970MzwuhO2DzEXqz5JPKNw0%3D) here .

  Find a platform to use for your videoconferencing work. There are several available but the ones that seem to be the best are VSee, Zoom, doxy.me (which has some service problems from recent reports), Simple Practice and Theranest.  Most have a monthly charge.  Some are more reliable than others. To see comparisons of the platforms, go to Rob Reinhardt’s website (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=07gTv9yAvdY7x2gNRKQsIb%2BqwBHGTz9sZwVAhnYIiYVxFspw4MabxncvgydQdWyIFJk3E36sfbhT2LrrsJvJzdXzJWxwuYfe2aDJ2i9bxm8%3D) www.tameyourpractice.com .

  Find a payment method for videoconferencing. The ones that seem to be the best are Zelle and Paypal.  Zelle is bank related and have privacy protections; you will need to get the patient’s bank account number.  I believe Paypal will sign a BAA.

  Develop an Informed Consent form for videoconferencing. CSWA has developed a template which can be found at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=B3Hmg1Fmx7FFSYRt9Qga3D3x9p%2BlIG2s70FcismmiBLt7ScW%2F1xlVuyc4f0k2eW%2BYP4ewuu63gmooRKFw4Sw23S0F64qJwvfBWKCwQIMR6s%3D) CSWA - Telemental Health Informed Consent - 3-20.docx.

  Check with all third party payers as to whether your patients will be covered for videoconferencing or telephonic sessions. Medicare patients await guidance from CMS and HHS which should be forthcoming in the next two weeks.  If patients are not covered, see if arrangements for private pay can be made.

If you have any other questions, please let me know.

Laura Groshong, LICSW, Director, Policy and Practice, Government Relations ChairClinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/8837263) Telemental health
Mar 15th 2020, 12:20

There have been many questions about the status of the telemental health expansion of Medicare and private insurers as the COVID-19 crisis itself has rapidly expanded.  Here is what CSWA knows so far.

The emergency bill signed on March 6 allows for an expansion of Medicare telehealth services of all kinds, once guidance from CMS and HHS is made available.  There is no definite date when this will happen, but we hope to have it within two weeks. 

CSWA, NASW, and the American Psychological Association will be sending a letter to CMS and HHS tomorrow encouraging them to allow a temporary expansion for patients that we have been seeing within the past three years.  The option that is currently being discussed per the March 6 bill is videoconferencing only, not telephonic sessions.  Of course CSWA hopes that telephone sessions will be allowed as well, but it is unlikely that it will be as soon as videoconferencing is covered.  It is a possibility that when videoconferencing is expanded by CMS, it will be retroactive to February, 2020.

As for private insurers, there is confusion about what they are willing to cover through videoconferencing and telephonically at this time.  Most companies that offer coverage are doing it for in-network providers only, who must use a specific telemental health platform and accept the fee offered.  This is generally less than LCSWs are used to being paid by these insurers for in-person sessions.  Out-of-network providers may or may not have the option of being covered for videoconferencing or telephonic sessions.  It is VERY important to check with any private insurers you have been reimbursed by, if you want to know the facts about their policies at this time.  Having patients call to find out what their policies are and request videoconferencing and/or telephonic coverage if necessary, is a good idea as well.

Another question is coverage for patients who live in a jurisdiction in which you are not licensed, for example, a patient has previously come to your office in Washington, DC, but lives in Maryland. You are licensed in Washington, DC, not Maryland, so would be practicing without a ;license if you treat the patient through videoconferencing while they are in Maryland.  I recommend calling the Social Work Board in any state in which a patient resides in which you are not licensed, to ask what their policy is on videoconferencing with patients (or telephonic sessions) who reside there. Again, there may not be good solutions here if the state insists that you be licensed in the state in which the patient resides.  Have patients call the Social Work Board in their state and ask for an exemption. 

Finally, there is the question of what to do if you have already moved to videoconferencing or telephonic sessions to protect you and your patients from becoming infected by COVID-19; it is problematic if you want to continue getting reimbursed by third party payers who currently do not cover videoconferencing.  You can continue to provide sessions through videoconferencing with the hope that they will be covered eventually; take a break while this is sorted out; or make arrangements with patients to pay privately.  None are ideal. 

I hope we will have some clarity on telemental health expansion soon and will keep you posted.  This is a unique and troubling time for LCSWs, all mental health professionals, and our patients. CSWA will do everything possible to give us the ability to continue providing our needed services.

Laura Groshong, LICSW, Director, Policy and Practice, Government Relations ChairClinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/8820054) Update on Telemental Health Medicare Coverage - 3-10-20
Mar 10th 2020, 18:32

On Friday, the President signed into law a $8 billion emergency funding bill that included $500 million towards Medicare telehealth, including telemental health services, because this is a declared emergency.  There are a few caveats (see below).

The good news: this bill allows the HHS Secretary to waive current Medicare telehealth restrictions (originating/geographic sites) on telemental health during the COVID-19 public health emergency, so that care can be provided regardless of where a patient is located, including at home.

The other news: a qualifying provider, like licensed clinical social workers, needs to have provided a service to an eligible beneficiary in the last three years—so this can only be applied to existing, or recent, patients.  Additionally, the telemental health services can only be provided through videoconferencing, not telephone only.

Place of service should be 02 for telehealth.  The GT modifier is no longer necessary, but 95 is still needed.  CPT codes should be as for an office visit.

This is overall good news and CSWA will work to make it a permanent option.


(https://www.clinicalsocialworkassociation.org/Announcements/8811530) Update on COVID-19 - 3-8-20
Mar 9th 2020, 12:25

Below is an update on the COVID-19 epidemic.

It appears that the number of cases is spreading, close to 500 with the Seattle area being the heaviest hit (128 cases, 19 deaths as of this writing).  We really don't know when the situation will improve as various cities are just starting to see cases and the tests for confirmation of COVID-19 are still hard to get.

I wanted to pass on some things that members are doing to protect themselves and their patients in addition to the list I sent out last Monday.  Some are cover fabric chairs and couches, even leather ones, with plastic/vinyl material which is easier to clean with antiseptic spray. 

It is important to make sure that any DIY hand antiseptic is at least 70% alcohol, the rest aloe vera gel, with some drops of aromatic oils like tea tree or lavender; unfortunately many areas are completely out of alcohol and aloe vera. Amazon can send in a week.

Those most at risk of being harmed by COVID-19 are people with underlying health conditions and those over 65. Traveling is not recommended for this group in particular.

Many members have asked about whether Medicare will cover telemental health sessions.  The bill signed on Friday provides $8.3 billion for a variety of ways to address the virus but there is no clear guidance on whether CMS will expand their coverage of telemental health yet.  I will let you know when this becomes available. Sen. Ron Wyden did get a provision in to support telemental health but no specific enforcement.  As for private insurers there is no clarity there either.  I suggest having patients request that telemental health be covered if they have private insurance; that is the most likely way to get coverage.

This is a time of anxiety in our personal and professional lives.  We should try to remember that we are all in this together and hopefully can help each other get through it.

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

Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/8810490) CSWA - Medicare Guidance on Telemental Health Coverage - 3-9-20
Mar 9th 2020, 11:43

I just received guidance from CMS on whether we can be reimbursed for telemental health beyond the accepted treatment in rural areas.  Their response is attached.

Basically the answer is no at this time. I recommend calling CMS at1-866-288-8912, x3 to ask for more guidance.

CSWA is developing a Legislative Alert to send to members of Congress to request an expansion of coverage for telemental health during this health crisis.

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

Clinical Social Work Association

The National Voice of Clinical Social Work

Strengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=0%2FDY8WRBQ7nogJTp95ZyPJgNXvaGoTVrOwuAtY7hH%2BU5ZlhNHpZ%2B9QWrQC5jQ6gqTzxB6AHtlmD4oaM6e511QHTSs5aqqvs1AItaJR6grdM%3D) CSWA - Medicare on Distance Sessions - 3-9-20.docx


(https://www.clinicalsocialworkassociation.org/Announcements/8803890) Response to COVID-19
Mar 3rd 2020, 20:00

The Covid-19 virus is spreading and LCSWs need to anticipate the impact that this may have on our patients and our practices.  Many of the suggestions below were gathered from the World Health Organization and other sources.  CSWA hopes we may be helpful to you as this health crisis evolves.

More information can be found at (https://www.who.int/emergencies/diseases/novel-coronavirus-2019/events-as-they-happen) https://www.who.int/emergencies/diseases/novel-coronavirus-2019/events-as-they-happen

Another comprehensive article can be found at (https://www.washingtonpost.com/health/2020/02/28/what-you-need-know-about-coronavirus/?arc404=true) https://www.washingtonpost.com/health/2020/02/28/what-you-need-know-about-coronavirus/?arc404=true

Clinical Practice Action Plan:

- Develop a plan for limiting in-person sessions if there is a public health recommended limitation for being in public places, or a perceived need for such limitation

- Review the CSWA Technology Standards for Social Workers if you have not done so recently ( (https://www.clinicalsocialworkassociation.org/Social-Work-Technology-Standards) https://www.clinicalsocialworkassociation.org/Social-Work-Technology-Standards)

- Check with insurers as to coverage of telephone or videoconferencing

- Make sure that any videoconferencing platform you use is HIPAA compliant (VSee, Zoom, etc.)

- Decide if patients with symptoms should have sessions by telephone or videoconferencing

- Decide if you should be working if you have symptoms

- Discuss a plan with patients in advance of the need to limit in-person contact, including arranging for phone or video sessions

- Sanitizing doorknobs and other surfaces touched by patients

- Be aware of own anxieties and try to contain

- Be prepared to acknowledge the anxieties of patients, should they occur

Public Health recommendations to reduce infection from flu or Covid-19:

- Perform frequent hand washing and use of hand sanitizer after being in public spaces

- Cough into elbow or shoulder, not covering your mouth with your hand

- Stay more than 6 feet away from individuals who are coughing or otherwise appear ill

- Avoid social ways of touching others, including handshakes

- Avoid touching your own face as much as possible

- Avoid public transportation such as buses or trains if recommended distance cannot be maintained

- Use hand sanitizer after going through TSA if flying by plane

- Use sanitizing wipes on plane armrests and tables and rental car keys and steering wheels

- Be aware of countries and cities where Covid-19 virus is increasing if traveling

- Engage in immune enhancing activities, i.e., get enough sleep, reduce alcohol intake, get exercise)

- Do not go to an emergency room unless absolutely essential; for a cough, fever, or other respiratory issues contact your primary care doctor first.

- Self-quarantine at the first sign of illness and wear an N-95 face mask in public spaces

Helping Children with Meaning of Restrictions Due to Covid-19

Suggestions can be found at   (https://onedrive.live.com/view.aspx?resid=D589777FC7C86E35!118&ithint=file%252cdocx&authkey=!ALcOpxBYPPJR_h4) https://onedrive.live.com/view.aspx?resid=D589777FC7C86E35!118&ithint=file%252cdocx&authkey=!ALcOpxBYPPJR_h4

Striking a balance between being overly cautious and overly optimistic may not be easy but as clinical social workers, I think we can achieve it.  As you may know, here in Seattle we have a cluster of Covid-19 cases and two deaths, so I will be applying these principles to my own practi

Laura W. Groshong, LICSW, Director, Policy and PracticeClinical Social Work Association(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.orgCSWA - "The National Voice for Clinical Social Work" Strengthening IDENTITY, Preserving INTEGRITY, Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/8753399) Confidentiality Violations to Immigrant Minors - 2-15-20
Feb 15th 2020, 00:25

The abuse of immigrant minors continues.  This article from the Washington Post details how a 17-year-old who was seen by a therapist while in detention and then had his confidentiality violated with serious emotional consequences. 

The article is called "Trust and Consequences", written by Hannah Drier, and was published on February 15, 2020.  You can find it at (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Ya8vlh1EAipKdfeMC6FQJ74BTIVmImsQvl2vdY6D12l94mEbmQ6rJYDLlC5oRf%2FJ5na9q1b%2FDsx68NEwIwg5gmBO8Ph05Jv43HJxIgqyGAE%3D) https://www.washingtonpost.com/graphics/2020/national/immigration-therapy-reports-ice/

CSWA's commitment to confidentiality includes anyone who is seen by an LCSW.  We condemn this act and will continue to work for the right to privacy of all clients.

(https://www.clinicalsocialworkassociation.org/Announcements/8701800) CSWA - Article by Todd Essig on War in Psychotherapy - 12-28-19
Dec 28th 2019, 22:45

Dear CSWA Members,

I want to call your attention to a terrific article called 'The War for the Future of Psychotherapy". on the conflict in psychotherapy regarding manualized algorithms as the basis for treatment and the treatment alliance as the basis for treatment. The article is by Todd Essig, PhD, a psychologist/psychoanalyst, who writes a column in Forbes Magazine and can be found here

This is not a new battle between short term and in-depth treatment but according to the article, there is new support for using algorithms to guide treatment from the American Psychological Association Guidelines.

CSWA has members who provide all methods and lengths of treatment but the human connection is seen as primary, not one-size-fits-all research. I urge all members to read the article and send me your thoughts, which I will share with other members.

This article came out of the Psychotherapy Action Network (PsiAN) Conference which was held in San Francisco the past month. Full disclosure: I spoke at the conference on clinical social work education in schools of social work (diminishing) and psychotherapy advocacy (time-consuming). Let me know if you want information about those topics. It was heartening to see the many LCSWs in the audience.

Here's to a happy productive new year for clinical social workers.

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

(https://www.clinicalsocialworkassociation.org/Announcements/8594137) MHLG 2019 Hill Staff Champion Awards
Dec 10th 2019, 15:56

MHLG 2019 Hill Staff Champion Awards, given to the members of Congress for their outstanding support of the goals of the Mental Health Liaison Group. These legislative aides are identified below. Peeking out of the second row is our own Margot Aronson, LICSW, CSWA Deputy Director of Policy and Practice.

Joseph Ciccone, Office of Representative Grace F. Napolitano

  Jennifer Tyler, Office of Representative John Katko

  Jeff Morgan, Office of Representative Paul Tonko


(https://www.clinicalsocialworkassociation.org/Announcements/7915933) CSWA - Information by State on Suicide - 10-1-19
Oct 3rd 2019, 08:04

The American Foundation for Suicide Prevention and the Suicide Prevention Resource Center have put together some excellent materials which may be helpful to members.

Here is a general overview of the scope of suicide, costs,vulnerable populations and more. The link is (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=GaYyUgPRtSb6XJjukZJl1HTyiy9Ww4%2BMxusjz1gtnVGHUCgoWNi32vqE0rrytYp9Dw5W3JkhGc%2F59%2FLbHZACYh1YN2kfUF5LKJJ%2BI5VVz0I%3D) http://www.sprc.org/about-suicide

Here is a summary of the guidelines which states use to prevent suicide. The link is (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=45XduS6GiscBcs4VXfm%2FZbI41kPY9SXLgTDTiByqCGRm6d09tgFW1BKDOUFeN9gE806MauSx0g0Ej36MZKJhb6%2FY0Px887z8x4UQajOLXXk%3D) http://www.sprc.org/stateInfrastructure/tools

Here is a summary of the number of suicides that occur each year by state and the ranking per capita of the states.  The link is(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=EIRLHUrNIksTM5VVVfACY93Mmniu1WKHn19fA04P%2FTvMKcgeot15bIF6uw9bbUC2ZAZeVAL809SjovZfLUXrbO0%2B9hEW%2BuLzHzx8pGFUEkk%3D) https://afsp.org/about-suicide/state-fact-sheets/

I hope this may be useful to you and your colleagues.

(https://www.clinicalsocialworkassociation.org/Announcements/7899246) CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies, CMS–1715–P
Sep 24th 2019, 23:03

Centers for Medicare and Medicaid Services
Director Seema Verma
http://www.regulations.gov

RE: CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies, CMS–1715–P

Dear Director Verma:

The Clinical Social Work Association (CSWA) is happy to provide these comments on the proposed Medicare rules for 2020.  There are over 250,000 licensed clinical social workers (LCSWs) in the country, the largest group of behavioral health providers. We are proud to be able to participate in the Medicare program and serve the mental health needs of beneficiaries.

As we understand the proposed rules for LCSWs, they are similar to the Physician Quality Record Systems (PQRS) which were in place from 2010-2017 for LCSWs.  When the Merit-based Incentive Payment System (MIPS) was created in 2018, LCSWs were not asked to report on the measures that were part of that system.  The proposed rule, CMS-1715-P, is specifically considering that clinical social workers now be included in the MIPS reporting.  The PQRS rule had many difficulties for LCSWs with denied reporting and we hope that if the MIPS measures are applied to LCSWs that the processing of the reporting will be improved.

CSWA understands that the Medicare Economic Index (MEI) is subject to change, and is hopeful that the proposed 6% decrease in overall RVUs for LCSWs may change as well.  As has long been the case, we have concerns about the way that LCSWs, who use the same behavioral health codes as psychologists and psychologists for psychotherapy, have nonetheless been reimbursed at 25% less than the other two groups.  We know this will take legislative change. This disparity continues to be patently unfair; groups doing the same work using the same codes should not have different reimbursement rates.  CSWA encourages our members to become Medicare providers and serve this vulnerable population.  However, decreasing reimbursement rates and increasing the paperwork burden could lead to fewer LCSWs choosing to do so.

As requested on p. 460, CSWA would like to offer the following comments on the Clinical Social Work specialty set, in the event clinical social workers are proposed for inclusion in the definition of a MIPS eligible clinician in future rulemaking.  Measures which CSWA finds would fit with the clinical social work scope of practice are marked “ACCEPTED”. Measures which are not included, but recommended by CSWA, are marked “PROPOSED”.

B.41 Clinical Social Work (p.664)

Measures in MIPS

#130, Medications for every patient listed in the Medical Record in each session ACCEPTED

#134, Depression Screening, once a year, followup treatment plan if positive screening ACCEPTED

#181, Elder Maltreatment Screening, once a year, with followup treatment plan if positive screening ACCEPTED

#182, Functional Outcomes Assessment, as needed, followup treatment plan if positive screening ACCEPTED

#226, Tobacco Cessation, once every two years or sooner if positive screening ACCEPTED

#281, Dementia Cognitive Assessment, once a year regardless of age, followup treatment if positive screening ACCEPTED

#283, Dementia Psychiatric Screening, once a year if positive cognitive assessment for dementia, for behavioral/psychiatric disorders, followup treatment if positive screening ACCEPTED

#286, Dementia Physical Safety Screening, as needed if danger to self or others because of physical limitations, followup treatment if positive screening ACCEPTED

#370, Adolescent Depression Remission Percentage at 12 months for 12-17 year old patients who have a positive screening for depression ACCEPTED

#382, Assessment of Suicide Risk for children/adolescents who have diagnosed suicidality with followup plan for continued suicidality ACCEPTED

#383, Assessment of adherence to anti-psychotic medication as needed for patients who have a diagnosis of schizophrenia or schizoaffective disorder and followup plan if positive screening for non-adherence ACCEPTED

#402, Assessment of tobacco cessation for adolescents 12-20 as needed with followup plan if cessation not achieved ACCEPTED

#431, Assessment of Unhealthy Alcohol Use for adults every two years with followup plan for cessation if not achieved ACCEPTED

PROPOSED: Assessment of Unhealthy Alcohol Use for adolescents 12-20 every year if cessation not achieved

PROPOSED: Assessment of Unhealthy Drug Use for adults every two years with followup plan for cessation if not achieved

PROPOSED: Assessment of Unhealthy Drug Use for adolescents every two years with followup plan for cessation if not achieved

Thank you again for the opportunity to offer our comments to CMS on these proposed rules.  We are happy to discuss them with you further.

Sincerely,

Britni Brown, LCSW, PresidentClinical Social Work Association(mailto:bbrown at clinicalsocialworkassociation.org) bbrown at clinicalsocialworkassociation.org

Laura Groshong, LICSW, Director of Policy and PracticeClinical Social Work Association(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

cc:

Margot Aronson, LICSW, Deputy Director of Policy and Practice Clinical Social Work Association(mailto:maronson at clinicalsocialworkassociation.org) maronson at clinicalsocialworkassociation.org

Donna Dietz, CSWA AdministratorClinical Social Work Association(mailto:administrator at clinicalsocialworkassociation.org) administrator at clinicalsocialworkassociation.org

(https://www.clinicalsocialworkassociation.org/Announcements/7671273) CSWA - More Information on Immigrant Children - 6-26-19
Jun 26th 2019, 15:54

Though I have not been sending the voluminous posts that I was sending last summer, the issue of immigrant children who are separated from their families, given inadequate housing, and denied basic care is one that CSWA is carefully tracking.  Here is some information that will keep you up to date and provide options on how to stop these injustices.  There are currently between 1000 and 3000 immigrant children in the US separated from their parents; some older (8 and up) children are being forced to care for younger children.

Summary of Harm – this article is a good summary of the current issues:

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=jD9OYYr7uhOn2ALOJGfwpIsSFqXevnt%2FuFzkfwuA0Nbmb9Z28Z3C532Obvg79j0nTW9VAruhm7AAPNN4fIELSnGakBiNa%2FDmNi7P5nb2ltE%3D) https://time.com/5613435/government-moves-migrant-kids-border-inadequate-shelter/

Agencies for Immigrant Children –Here are some good agencies that are working to improve the conditions of immigrant children and reunite them with their families:

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=KMvfV5zTWepciiQXtv15xK3UNLjT7%2Fqz%2BxOVsRAkib%2B2TgMVaO%2FOzaHPHhgTZwaFOd%2FGBjcaRx41lpcnUSGY%2BokZYxR%2FeNmkxmR6nt9C%2FIY%3D) Kids in Need of Defense (KIND) works to ensure that no child appears in immigration court alone without representation.

Women’s Refugee Commission offers (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=Iz2AAUXNNqLzjpWwoxrl3EHcGleAT9TZddV17kszwCJVYfXo1UZKv%2FLiCt5w9kfESX9fHwCLKmQESFohP%2BcQC7aO%2BGvnphpNi5rSx225d2w%3D) Resources for Families Facing Deportation and Separation in English and Spanish.

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=QRURqZLOj4er69koCobPjmdUg5Rd8Pnibz%2BFE%2BDZAWUuI8csziTutIUVT4lSbaL%2BtEGzDo%2FaiPRoFQ547eM9Y3Wb%2FTKgwG9idHVEapYR02E%3D) Young Center for Immigrant Children’s Rights advocates for the safety and well-being of unaccompanied kids arriving in the United States. They recently announced a project specifically dedicated to helping children separated from their parents at the border.

Donations to Help – here is one of many organizations that are using donations to help immigrant children:

(https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=b6z%2Bpr20DvcZtU4ETctHFRcz6lcYM53zePnJ1CuXhSA05XXAJgX2VQp1MDffKOiFoBdHMKJDSFz77DMn29SUHXNHYHiSUl0lktZd9aW9U7M%3D) https://secure.actblue.com/donate/borderfamilies2019?refcode=20190624esborderd&link_id=0&can_id=1dd38bb56c3bb701463ff79392bbbcf5&source=email-this-is-not-immigration-policy-it-is-inhumane-and-cruel&email_referrer=email_569843&email_subject=this-is-not-immigration-policy-it-is-inhumane-and-cruel

Let me know if you have any questions.

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

Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/7558750) LCSWs and the Use of Texting in Mental Health Treatment
Jun 5th 2019, 22:02

Laura Groshong, LICSW, Director, Policy and Practice
Margot Aronson, LICSW, Deputy Director, Policy and Practice

May, 2019
Text Therapy – Start Feeling Better Today with Talkspace Online Therapy.  A Convenient and Affordable Solution That Provides Access to Therapy Whenever You Need. 100% Private & Secure. Secure & Confidential. 1 Million Happy Users. 2000+ Licensed Therapists. As Low As $49/Week.  (Talkspace Website, (https://help.talkspace.com/hc/en-us) https://help.talkspace.com/hc/en-us )Texts are primarily used for social purposes: short missives conveying limited information.  Much has been written about the negative impact of reliance on this mode of communication (Turkle, 2012), but the popularity of texting is obvious, particularly among those under the age of 30 who have texted regularly throughout their lives. Therefore, the increasing use of texting in the context of therapy cannot be ignored.

While there is no definitive research as yet, it appears that texting can play a useful role in some mental health treatment. Certainly for anyone who is most comfortable with texting as the preferred form of communication, this may be where a treatment relationship can best begin.

Responsibilities of the LCSW Providing Text Therapy

Clinical social workers should be knowledgeable about the promise of digital innovations in treatment, and equally about the potential downside. LCSWs choosing to engage in text therapy must be willing to explore ethical complications, perhaps even license violations, in the terms of agreement with the client and/or the texting platform. 

The first issue:  is text therapy really psychotherapy?

Psychotherapy -- also called "talk therapy" or just plain therapy -- is a process whereby psychological problems are treated through communication and relationship factors between an individual and a trained mental health professional. Modern psychotherapy is time-limited, focused, and usually occurs once or twice a week for 45-50 minutes per session (Herkov, M., “What is Psychotherapy?”, PsychCentral, October 8, 2018.)

This simple definition of psychotherapy, paired with the already quoted Talkspace web advertisement, illustrate the very real differences that exist between psychotherapy and text therapy. Psychotherapy (whether in person or through synchronous videoconferencing) is a continuous process based on an established emotional relationship, an ongoing dialogue between two people in real time about complex issues with deep emotional content.  Texting, on the other hand, is by its nature short, often with a gap in the timing of communications between client and therapist; it is not consistent with a dialogue based on emotional meaning, as with psychotherapy.

Talkspace User Agreement - This Site Does Not Provide Therapy. It provides Therapeutic conversation with a licensed therapist.   (Essig, T., “APA Cancels Talkspace Ads Moving Forward”, Forbes Magazine, July 29, 2018.)

While texting platforms may emphasize, in the small print of the User Agreement, that the services provided are not psychotherapy, most continue to display the term “text therapy” prominently in their ads.  This can create confusion for clients seeking psychotherapy and may give an appearance of misleading advertisement.

How, then, do we as LCSWs conceptualize and engage in text therapy?  Perhaps “text therapy” might more accurately be called “text assessment” or “text coaching”.  Texting might also be the means for starting the therapeutic process, to be converted to an in-person or videoconferencing process if it becomes an ongoing psychotherapy.

Reading any contract with care is essential, and this is most certainly true for provider contracts offered by texting platforms.  Does the contract address issues such as diagnosis, HIPAA compliance, state-to-state licensing laws, and dual relationships?  Does the platform set limitations on helping a client understand the differences between in-person treatment and text therapy, or on recommending in-person therapy when such treatment is indicated?   

LCSW Standards of Practice

The use of ongoing asynchronous texting changes the process of therapy for LCSWs.  The therapeutic alliance is significantly different when the primary means of communication is not direct ongoing communication between the client and therapist, as the asynchronous method of communication tends to preclude in depth exploration of emotional understanding.  Further, a key part of psychotherapy, the “frame”, is lost if client and therapist text and reply at different times, or if the client is limited – as with some agreements - to making and receiving two texts a day to a therapist five days a week.

LCSWs base their understanding of a client on a biopsychosocial assessment, leading to a diagnosis. ASWB Technological Guidelines (2015) identifies additional factors that may contribute to determining whether a client is suitable for text therapy:  age, technological skills, disabilities, language skills, cultural issues, and access to emergency services in the client’s community.  How does the platform provide for assessment?  Can you ensure that our standards of practice will be upheld by the texting platform?

When more intensive treatment is called for, will the platform respect and support the licensed provider’s clinical judgment?  LCSWs know that a client with a psychotic disorder, an autistic spectrum disorder, or an acute episode of depression or anxiety may need in-person communication or hospitalization.  Are there contractual provisions for such a situation? 

Regulatory Considerations

Benign as texting seems, some texting platforms ask clinicians to communicate in ways that may violate state laws and regulations and/or federal laws and rules.

Most states require a clinical social worker to be licensed in both the state where the LCSW resides and the state where the client resides, if different, to provide therapeutic services.  A text platform’s claim that text therapy is not psychotherapy but rather “therapeutic communication” is a blurry distinction not necessarily recognized by state social work boards. It is the LCSW’s obligation to ascertain and comply with relevant regulations of both state boards. 

Licensed therapists are also responsible for making sure that the text platforms used by both client and therapist are HIPAA compliant.   Further, the texts themselves are personal health information sent electronically (PHI) and must be kept private and secure.  It has been reported that one text platform permitted employees – even non-clinically-trained employees – to review the content for training purposes.  A Business Associate Agreement might provide a guarantee of the LCSW’s confidentiality standards, if the platform agrees to sign (HIPAA Basics for Providers, 2018, (https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/HIPAAPrivacyandSecurity.pdf) https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/HIPAAPrivacyandSecurity.pdf )

Ethical Considerations  

Most states use the NASW and CSWA Codes of Ethics as the basis for ethical clinical social work practice. Some text platforms have contractual terms that require the therapist to meet sales targets through their text exchanges.  For a clinical social worker to engage in such a dual relationship, i.e., as a corporate representative for the texting services and, at the same time, as a therapist addressing mental health problems is a clear and serious ethical violation.

Some companies use marketing techniques that also may be ethical violations.  One example, potentially misleading advertising, has been mentioned.  Advertising with testimonials from former clients is another.  From the NASW Code of Ethics (2016)

 4.07(b) Social workers should not engage in solicitation of testimonial endorsements (including solicitation of consent to use a client's prior statement as a testimonial endorsement) from current clients or from other people who, because of their particular circumstances, are vulnerable to undue influence.

Would the company agree to keep the LCSW provider from being caught up in these sorts of business-driven ethical dilemmas?

Summary

Basic to mental health treatment is thoughtful consideration of the conditions being treated and of the biopsychosocial needs of the client. The challenge for the LCSW is incorporating these basics, along with accepted standards of practice, regulatory requirements, and ethical considerations, into the texting format as contracted by the particular text platform.  It is the responsibility as LCSWs to apply clinical social work standards of practice, ethics, and regulations to any work we choose to do.

References

Association of Social Work Boards (2015). Technological Guidelines.

  ASWB, CSWA, CSWE, NASW (2016). Technology Standards in Social Work Practice.

  Clinical Social Work Association (2016). Code of Ethics.

  Centers for Medicare and Medicaid Services (2018). HIPAA Basics for Providers, (https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/HIPAAPrivacyandSecurity.pdf) https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/HIPAAPrivacyandSecurity.pdf .

  National Association of Social Workers (2016). Code of Ethics.

  Turkle, S. (2012) Alone Together: Why we Expect More from Technology and Less from Each Other. NY, NY: Basic Books.


(https://www.clinicalsocialworkassociation.org/Announcements/7304068) Implications of the UBH Decision for LCSWs
Apr 25th 2019, 14:56

THE AWARE ADVOCATE 

Implications of the UBH Decision for LCSWs

Laura Groshong, LICSW, CSWA Director, Policy and Practice

April 17, 2019

Much excitement has been generated in the mental health community since “the UBH decision” – that is, the decision in the US District Court in Northern California case of Wit et al versus United Behavioral Health, filed March 5, 2019 - found UBH liable with respect to the denials of benefits claims.  The clarity and detail of Chief Magistrate Judge Joseph Spero’s 106-page Findings of Fact and Conclusions has provided us with an extraordinary resource for moving forward. 

At the same time, there are clear limits to this big win: this is not the end of insurance denials and parity violations.  UBH will surely be appealing the judgment, and other judges may or may not uphold the present ruling. Further, the insurance arena is complex.  Each state has its own insurance regulations, and each type of plan (ERISA, Medicare, Medicaid, Exchange Plans, or private) has a different source/s of oversight.  (CSWA has posted information to clarify the differences in the Clinical Practices section of our website.)

How, then, can we use this decision effectively to affect access to mental health and substance use treatment?  At the individual level, if your client is being denied care that you deem critical, the detailed court document provides a list of “generally accepted standards of care” that may prove very helpful in your discussion with the insurance representative. 

Judge Spero spent considerable time during the hearing determining what is meant by generally accepted standards of care.  Many sources exist, and CSWA will post the judge’s summary of these on our website. The standards listed below were agreed upon by both plaintiffs and UBH; the wording is taken from the court document itself:

effective treatment requires treatment of the individual’s underlying condition and is not limited to alleviation of the individual’s current symptoms 

  effective treatment requires treatment of co-occurring behavioral health disorders and/or medical conditions in a coordinated manner that considers the interactions of the disorders and conditions and their implications for determining the appropriate level of care

  patients should receive treatment for mental health and substance use disorders at the least intensive and restrictive level of care that is safe and effective

  when there is ambiguity as to the appropriate level of care, the practitioner should err on the side of caution by placing the patient in a higher level of care  

  effective treatment of mental health and substance use disorders includes services needed to maintain functioning or prevent deterioration

  appropriate duration of treatment for behavioral health disorders is based on the individual needs of the patient; there is no specific limit on the duration of such treatment

  unique needs of children and adolescents must be taken into account when making level of care decisions involving their treatment for mental health or substance use disorders

  determination of the appropriate level of care for patients with mental health and/or substance use disorders should be made on the basis of a multidimensional assessment that takes into account a wide variety of information about the patient.

The nine plaintiffs whose cases were reviewed during the ten-day bench trial included denials of residential treatment for substance use disorder, for rehab, for mental health treatment, and, in two cases, for teenagers with substance issues, as well as denials of outpatient mental health treatment two to three times per week, and Intensive Outpatient Treatment (IOP) for a minor with SUD. The Judge provided detail for each case considered, noting the discrepancy between the UBH stated standard of care and the actual guidelines that the reviewers was expected to follow.  His descriptive language throughout, when referring to the UBH testimony, tended toward generous use of the words “evasive” “even deceptive” and “not credible”.  

Given the widespread interest in this case, LCSWs may want to be assertive in appealing denials of care, especially where there is any failure to meet the standards.  As you present your argument - even if you are dealing with a different insurer and a different type of plan - a mention of the UBH case will likely have an effect on the discussion.  (The CSWA website has an Appeals template in the Members-only section; the generally accepted standards of care list will also be there, as well as a description of the five types of insurance plans.)

Another important avenue for LCSWs may be their state insurance laws/regulations and then perhaps their legislators.  The plaintiffs came from different states, and three of these states – Illinois, Connecticut and Rhode Island - have legislation mandating use of the American Society of Addiction Medicine (ASAM) Standards in their insurance laws/regulations; it was not difficult to demonstrate that the UBH denials violated the state laws/regulations.  A fourth state, Texas, has Department of Insurance criteria for standards of care; this proved equally effective.

Summary

The UBH decision is a good step toward making mental health and substance use parity a reality but is far from the end of making this happen.  For now, we can speak out strongly on standards of care, ensure that standards in the client’s policy is being respected in any review process, and feel comfortable noting the UBH loss in court based on violation of these standards, as a basis for appealing a denial of care.  As for the next steps, LCSWs should look to state laws/regulations governing insurance, including any standards of care or enforcement of parity.  (Such information may be online at the website of the Office of the Insurance Commissioner).  Insurance is a state-based system and it may be possible to make a legislative proposal about mental health and substance use that would appeal to your state legislators. Watch for more information from CSWA on this topic soon.

Footnote:     Case 3:14-cv-02346-JCS Document 18 (Findings of Fact and Conclusions of Law).  Heard and ordered UBH liable 2/28.    Filed 3/05/19. 106 pages.  United States District Court, Northern District of California. 

Laura Groshong, LICSW, CSWA Director, Policy and Practice

Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY

(https://www.clinicalsocialworkassociation.org/Announcements/6947332) Merit-Based Incentive Payments (MIPS)
Nov 26th 2018, 14:48

You may have already heard that the CSWA Webinars on the Merit-Based Incentive Payments (MIPS) which were to be held on November 29 and 30 have been canceled.  This post explains why.

Clinical social workers were among the 12 additional practitioner groups that were to be included as eligible providers (EPs) for the MIPS bonus of 2% a year in 2019 if reports on quality, cost, improvement in treatment, and increased use of health care records were met.  There were some options that would have allowed LCSWs to be eligible if they had less than $90,000 in Medicare claims and less than 200 Medicare beneficiaries as clients with less reporting.  Most LCSWs who are sole practitioners would be in this category.  There would have been no penalties for LCSWs who did not submit data in the areas described above.

Two weeks ago CMS took LCSWs off the list of EPs who would be included in 2019 for the bonus.  While this certainly will cut down on the administrative work MIPS would have required, it also takes the option for a bonus away from LCSWs.  So is the glass half empty, or half full?  That depends on how you feel about the loss of the bonus option.

One other note of interest: it appears that there will be a 2-3% increase in reimbursement for psychotherapy services in 2019.  The exact amount will vary by region.

In January, CSWA will be presenting a webinar on the ins and outs of Medicare, a complicated topic about which I receive questions regularly.  Watch for the announcement next month on “Everything LCSWs Need to Know about Medicare Practice”.

Please let me know if you have any questions on the MIPS changes. 
Laura Groshong, LICSW, CSWA Director, Policy and Practice


(https://www.clinicalsocialworkassociation.org/Announcements/5069858) Transferring LCSWs Across States
Sep 7th 2017, 22:42

With all the environmental challenges we are facing – flooding in Texas, fires and smoke in the Northwest and California, anticipated hurricanes in Florida, South Carolina and up the east coast – it may be hard to think about something as mundane as how to transfer our licenses when we move to a different state.  But this is a situation I have had many people tell me they struggled with so I urge everyone to look at this post in case you have been in this situation.

The Association of Social Work Boards (ASWB) is launching an effort to make transferring an LCSW easier by creating more reciprocity between state boards.  This will not be easy as state boards have vested interests in their own laws and rules.  Nonetheless, I hope who has an experience to share will go to (http://movingsocialwork.org/take-action/share-your-story/) http://movingsocialwork.org/take-action/share-your-story/

This will be used as the base for making the case to the boards that this is an important issue for LCSWs and should be made easier than it is.

Thanks for your help.  I hope everyone gets through this weekend as well as possible. 

(https://www.clinicalsocialworkassociation.org/Announcements/5054940) Red Cross - Hurricane Harvey
Aug 29th 2017, 19:00

The Red Cross IT system is down.  They hope to have it back up by the end of the day.  In the meantime, fill out the form at (http://www.redcross.org/volunteer-interest-form) http://www.redcross.org/volunteer-interest-form and you will be contacted.  Keep trying the link below as well.~LWG

Red Cross has initiated a direct deployment for Hurricane Harvey. This program is for those who are not currently a Red Cross volunteer.  I have attached a document with two versions regarding the Direct Deployment program that you can use to share this information far and wide and get the word out.

These Event Based Volunteers (EBVs) will be 'screened' and followed by a mental health volunteer to guide and support  them  thru the process. The process has been streamlined and formalized since it was developed last year. To check it out yourself click on the link: (http://www.redcross.org/take-a-class/lp/hurricane-harvey-health-professionals) http://www.redcross.org/take-a-class/lp/hurricane-harvey-health-professionals  They must deploy for 9 days which includes 1 day on each end for travel, plus take a few classes online and other paperwork. Important to note that eligibility now includes retirees and out of state licenses. 

Please post this on your respective websites, Facebook, LinkedIn, emails, listservs etc. It is anticipated that this will be a long haul with a great need for mental health.

Current volunteers are encouraged to note their availability in Volunteer Connection.or contact their local Staffing person.   

If you have any questions, feel free to contact me at (mailto:vicky.powell at redcross.org) vicky.powell at redcross.org  


(https://www.clinicalsocialworkassociation.org/Announcements/5029221) Statement on Charlottesville Violence - 8-13-17
Aug 14th 2017, 09:14

The Clinical Social Work Association is stunned and outraged at the violence by white supremacists that took place in Charlottesville, Virginia, yesterday.  CSWA sends our best wishes and prayers to the families of those who injured and killed in Charlottesville.  We oppose bigotry in any form and encourage all Americans to make it clear that our country will not stand for ‘internal’ terrorism based on prejudice.

According to the Southern Poverty Law Center, there are now 917 hate groups in the United State ((http://www.splcenter.org) www.splcenter.org) .  There has been a 67% increase in hate crimes (from 2014) as of 2015, the latest data available, according to the FBI ((https://ucr.fbi.gov/hate-crime/2015) https://ucr.fbi.gov/hate-crime/2015) .

CSWA is disturbed by the fact that President Trump’s original statement about the incidents in Charlottesville was such a weak condemnation of the clear bigotry that led to the deaths of three people.  His support of actions based on discrimination during his campaign paved the way for white extremist groups to act destructively toward those that they see as their enemies.

We call upon President Trump to speak out against this rage that has been simmering in some of our citizens and stop this dangerous trend.  It is time for all Americans to take a stand against those of us whose racist anger is turning into actions that hurt or destroy those they hate.

(https://www.clinicalsocialworkassociation.org/Announcements/5019949) 2017 CSWA Diversity Statement
Aug 8th 2017, 21:39

The Clinical Social Work Association has been working for several months to assess and discuss diversity of our membership and our Board. Planning and discussion at the 2016 Annual Summit helped to launch a larger consideration of diversity within our membership. While it is beyond the mission of CSWA to alter the demographics of clinical social work, it is our responsibility to regularly assess our membership and evaluate the perspective we are representing. Our goal was simple: start a conversation about encouraging diversity of membership and Board representation, and continue this conversation by offering action steps and educational tools. In order to reach our goal, we disseminated a survey, created an ad hoc diversity committee, and incorporated the results into our strategic planning.

We are not alone in our commitment to assess and discuss diversity and inclusion. Several Societies have been facilitating these critical conversations for years. Others have begun to take action recently. We know that despite CSWA’s best efforts, there will always be room for improvement.  We encourage all state societies to promote through trainings and increased inclusion of diverse populations on Society Boards and in membership.  Additionally, CSWA encourages Societies to reach out to other clinical social work organizations to build bridges for more unified membership and advocacy efforts.  CSWA supports all attempts to create a clinical social work community that is inclusive and sensitive to the experience of all its members.

We are proud to send the following statement and reminder of the CSWA Code of Ethics that outlines our long standing commitment to cultural competency.

2017 CSWA Diversity Statement

The Clinical Social Work Association has long supported the values of diversity and inclusion. During these troubling times it is vital we create a welcoming and supportive environment for all our members and the people we serve. We firmly believe that we can best promote excellence within our profession by offering educational tools for dialogue and professional development, assessing our membership, and promoting our strong code of ethics regarding cultural competency standards. Further, we recognize the responsibility for excellence, diversity and inclusion lies within each of us who make up the clinical social work profession. CSWA encourages all members and affiliated societies to promote increased awareness of the meaning of diversity to all.


(https://www.clinicalsocialworkassociation.org/Announcements/5019916) Promoting Diversity Awareness
Aug 8th 2017, 21:13

Melissa Johnson, CSWA President, July, 2017

The Clinical Social Work Association has been working for several months to assess and discuss diversity of our membership. Several Societies have begun to develop programs to promote diversity awareness. Based on their work, below are some suggestions.

Define your terms. Everyone has a different idea about what diversity means. Beyond race and gender, it can also include but is not limited to considerations of age, ethnicity, sexual orientation, mental and physical capabilities, gender identity, family status, language, opinions and experience. 

Assess. Review your bylaws and clauses that define diversity standards; check for any institutional bias or exclusionary language. Start a conversation about diversity and inclusion with Board members and within your Society. Be prepared to have difficult conversations.  Collect rich data; the goal of a survey is not just a head count, but rather the beginning of an education process.

Listen and affirm. Ask about the experiences of your members. Do not make assumptions about how people view this complicated issue. Encourage all Board members to evaluate their own perspective. Don’t scold or shame those who are struggling with understanding.    

Learn, share, educate.  Offer trainings; invite speakers; build coalitions with other associations; plan a conference on diversity and inclusion.  Identify all of the ways you can define diversity and how inclusion is experienced within your society and the profession. Embed these principles in your leadership and others will follow. 

Contact Melissa Johnson, CSWA Board President or any of the board members if you want to discuss these concepts with other Societies or find experts to conduct trainings.  It helps to not have to reinvent the wheel.  CSWA wants all its members and Societies to be self-aware about what healthy understanding and acceptance of diversity means to them and others.

(https://www.clinicalsocialworkassociation.org/Announcements/4088662) Draft Technology Standards
Jun 21st 2016, 07:46

Four major national social work organizations - NASW, CSWA, CSWE, and ASWB - have been developing draft Social Work Technology Standards for the past two and a half years.  These standards will cover every area in clinical social work practice that may be affected by the use of technology including clinical practice, record-keeping, education, and macro social work.  Many thanks to Laura Groshong, CSWA Director of Policy and Practice, who served as CSWA's representative on the Task Force that put in hundreds of hours on this project.

These standards have been posted for public comment until July 20, 2016.  They are available at the following link with instructions on how to submit comments:   (http://www.socialworkers.org/practice/naswstandards/TechnologyStandardsInSocialWorkPractice/CommentSubmission.aspx) http://www.socialworkers.org/practice/naswstandards/TechnologyStandardsInSocialWorkPractice/CommentSubmission.aspx Another way to obtain the draft standards is to go to (http://www.socialworkers.org/) www.socialworkers.org. To the right, look for the “What’s New” box.  Scroll down and click on “Draft Technology Standards in Social Work Practice.” 

Comments must be submitted by July 20, 2016 to be considered.  After consideration of the changes by the Task Force, the draft technology standards will be submitted for review and approval to the NASW Board of Directors in September, 2016 and the other organization Boards (CSWA will meet in October).

The goal is to have these standards published by the end of 2016.

CSWA is proud to have been a participant in this important project and encourages all members to review the draft standards and send comments.

Clinical Social Work AssociationThe National Voice of Clinical Social WorkStrengthening IDENTITY | Preserving INTEGRITY | Advocating PARITY


(https://www.clinicalsocialworkassociation.org/Announcements/4077490) CSWA Response to Orlando Tragedy
Jun 15th 2016, 14:54

Dear CSWA Members, 

It is hard to accept the massacre of LGBTQ people in Orlando and the hate it represents.   

There have been some good summaries of how to think about it, including one by Glenda Russell (attached).  A PDF version is available online at (http://drglendarussell.com/wp-content/uploads/2016/06/Responding-to-Orlando.pdf) http://drglendarussell.com/wp-content/uploads/2016/06/Responding-to-Orlando.pdf. Please feel free to share with others.

"Give an Hour" is making the thousands of therapists who give an hour of treatment to veterans available to the Orlando LGBT community - to join go to (http://www.giveanhour.org/ForProviders.aspx) http://www.giveanhour.org/ForProviders.aspx .  To read their press release, go to (http://bit.ly/1YnkaTl) http://bit.ly/1YnkaTl  .  

We can never stop insisting on the right of everyone to live their lives regardless of color, sexual orientation, gender or any identity that has been demonized. Please re-read the (https://www.clinicalsocialworkassociation.org/resources/Documents/CSWA%20-%20Statement%20on%20Discrimination%20(Final)%20-%204-11-16.pdf) CSWA Statement on Discrimination (attached).  The hate being legalized against trans people in the states mentioned is a contributing factor to the terrible loss in Orlando.  Speak out against all forms of hate."

Susanna Ward, PhD, LCSWPresident & CEO, Clinical Social Work Association(606) 923-0944(mailto:cswapres at gmail.com) cswapres at gmail.com

Melissa Johnson, LCSWPresident-Elect, Clinical Social Work Association(mailto:mjohnson at clinicalsocialworkassociation.org) mjohnson at clinicalsocialworkassociation.org

Laura Groshong, LICSWDirector, Policy and Practice(mailto:lwgroshong at clinicalsocialworkassociation.org) lwgroshong at clinicalsocialworkassociation.org

 attachment:  (https://www.clinicalsocialworkassociation.org/resources/Documents/Russell%20-%20RespondingtoOrlando%20-%206-16.pdf) Russell - RespondingtoOrlando - 6-16.pdf

CSWA - "The National Voice for Clinical Social Work"Strengthening IDENTITY, Preserving INTEGRITY, Advocating PARITY


(https://www.clinicalsocialworkassociation.org/Announcements/4052125) Preparing for Practice Interruptions and Endings
Jun 1st 2016, 20:40

Laura Groshong, LICSW, CSWA Director, Policy and Practice

We clinical social workers all recognize the possibility that an unexpected life event could interfere with our clinical social work practice.  We help our patients deal with unanticipated events every day. Yet many clinical social workers have no plan for notifying patients in such a case, and no arrangement with a colleague who, should it become necessary, would enact this plan.

Of equal concern is the end of a practice:  best practice dictates a mindful approach to closing a practice, with a plan developed long before retirement draws near.  Yet a comprehensive study (Hovey, 2014) of how social workers address the end of a practice found that only 18% of those surveyed had completed a professional will.   The sample (n=83) consisted primarily of White/Caucasians (94 %), female social workers (82 %), ranging in age from 24 to 80 years, most of whom were in private practice (78 %).  While 35 % said they had made some informal arrangements with colleagues, 47 % had made no arrangements at all. These results highlight the likelihood that clinical social workers have not given practice interruptions and endings the attention that they should have.

What Makes Planning So Difficult?

As Ragesua, Shatsky, and others have noted, it is often difficult for clinicians, including clinical social workers, to anticipate interruptions in a practice, planned closing of a practice, or instructions for the unplanned closing of a practice.  Shatsky states: “As clinicians, we champion our patients’ examination of the difficult, important transitions of their lives. Yet, when it comes to this issue, more often than not we fail to conduct a competency examination on ourselves….Why is it unusual to hear cognitively fit colleagues openly discuss looking forward to retirement? Unlike other health professional arenas, why is planning for and discussing this significant transition (amongst psychotherapists) rarely embarked upon with enthusiasm?” (2016).  Ragusea gets to the heart of the matter in his adaptation on ending a practice “On rare occasions, reality breaks through our merciful denial and we all consider our own demise.  Yes, the last great adventure beckons to us; even psychologists [and clinical social workers] die.  Most of us like to think that we will pass away quietly in old age, peacefully sleeping in our own beds and, perhaps, surrounded by loved ones.  But, what if the path goes off in a different, surprising direction?  What if we die suddenly, unexpectedly?” (Ragusea, 2002). 

The internal process of accepting the fact that there are likely to be interruptions and there will definitely be endings to clinical practice may involve working through feelings of loss, ambivalence, guilt, relief, and much more. Clinical social workers should begin to consider their feelings about the inevitable ending of clinical practice from the beginning of their careers, rather than wait until nearing the likely end of their working lives.  Having no plan in place for an unexpected interruption or ending could put patients at risk for a wrenching disruption in treatment and may burden an unprepared spouse, partner, or colleague with the complex task of closing a practice.  The responsible clinical social worker will have a plan in place; this is best practice, ethical practice, and even required in some states by the boards of social work.

What The Clinical Social Work Association Can Do To Help

There are four major ways that clinical social work practices may be interrupted or ended:  

Unplanned Termination of Practice; 

  Temporary Inability to Continue Practice; 

  Extended Inability to Practice; and 

  Planned Termination of Practice.  

Over the next few weeks, we will consider each of these four possibilities.  We will offer you Guidelines for developing a plan in each case, and a Template Agreement or Professional Will for carrying out needed responses in the CSWA Members Only section (you must join CSWA separately from your society).  Watch for notices that these templates are available.References

Hovey, J. K. (2014). “Mortality practices: How clinical social workers interact with their mortality within their clinical and professional practice” (Unpublished master’s thesis). Smith College School for Social Work, Northampton, MA. Available from (https://www.clinicalsocialworkassociation.org/EmailTracker/LinkTracker.ashx?linkAndRecipientCode=%2b4HgauMlXWUiBRhbVUPFCwYRoX8yaT3zqt89cvMFugw%2bPN3x4K8Fu20922mtiyaGO5cZxa8CryDwYP8ubdm%2bU8b8EGaK2FH7JJTpLXjiCYg%3d) https://dspace.smith .

Ragusea, S. "A Professional Will for Psychologists", adapted from VandeCreek, L. & Jackson, T., Eds. (2002) Innovations in Clinical Practice: A Source Book, Vol. 20, pp. 301-305. Sarasota, FL: Professional Resource Press.

Shatsky, P. (2016) “Everything Ends: Identity and the Therapist’s Retirement”. Clinical Social Work Journal, Vol. 44, No. 2, pp. 43-149.


Forwarded by:
Michael Reeder LCPC
Baltimore, MD

 

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