​Life After Public Health Emergency (PHE)

On May 11, 2023, the World Health Organization announced the end of the federal COVID-19 PHE declaration.
Unfortunately, this does not mean that coronavirus does not exist anymore, rather that Covid-realated deaths
have substantially decreased. The U.S. government’s approach to coronavirus will change, but how does this
impact social workers?
The end of the PHE has caused concern for LCSWs who work via telehealth with clients on Medicare (CMS).
Firstly, the coverage of telehealth has begun to be limited by some insurers. This is concerning because
telehealth increases access to healthcare providers, and limiting access to that may cause clients to stop
receiving the care they need. Fortunately, The Consolidated Appropriations Act of 2023 extended Medicare
coverage of telemental health until December 31, 2024 but many commercial insurers did/do not follow CMS
guidance. Secondly, after the December 31, 2024 date, clients will be required to be seen in-person at least
once a year. Due to health risks, transportation issues or more, this could be virtually impossible for some
clients. Audio-only telehealth appointments will not be covered following the The Consolidated
Appropriations Act of 2023 further alienating some clients from care.
LCSW’s who use platforms such as Skype will need to change mediums. According to the Office of Civil Rights
(OCR), using such platforms was not seen as a violation of HIPAA rules during the PHR. Now, LCSW’s will be
required to use a HIPAA compliant platform, such as ZoomPro, Doxy.me, and other platforms offer a Business
Associate Agreement (BAA).
Finally, there are changes to codes and modifiers for Medicare:
● 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.

More information can be found on the Clinical Social Work Association website.
Info: https://www.clinicalsocialworkassociation.org/Announcements/13134039
https://www.clinicalsocialworkassociation.org/Announcements