Advocating for Equitable Reimbursement
Blueprint of Public Policy Priorities for the 119th Congress, 2025-2026
Priority:
- Improve access to mental health services
Legislation:
- The Improving Access to Mental Health Act
Goal:
- Improve access to mental health services in Medicare by increasing
reimbursement for clinical social workers (CSWs), allowing CSWs to bill
independently at skilled nursing facilities (SNFs), and allowing CSWs to
provide additional Health Behavior Assessment and Intervention (HBAI)
services
Background:
Across the country, millions of Medicare beneficiaries experience significant health and mental health challenges. The beneficiary population is rapidly increasing in size, changing demographically, and coping with issues such as functional limitations, multiple chronic conditions, social isolation, economic insecurity, and ageism. CSWs are one of the largest groups of mental health service providers in the United States and are among the professions that can bill Medicare Part B for mental health services. However, they are not able to bill Medicare Part B for psychosocial services provided in SNFs or for some HBAI services, even though they are within CSWs’ scope of practice. Beneficiaries who receive SNF services under Medicare Part A, for example, cannot simultaneously receive services from an independent CSW under Part B. And even though in 2023 the Centers for Medicare and Medicaid Services (CMS) allowed CSWs to receive Medicare reimbursement for some HBAI services beginning January 2024 through its Physician Fee Schedule final rule, there continue to be four HBAI codes that are not available through CSWs. Medicare also reimburses CSWs at only 75% of the physician fee schedule, whereas psychiatrists and psychologists are reimbursed 100% and other non-physician practitioners including nurse practitioners and occupational therapists are paid at 85%. Mitigating this reimbursement inequity by increasing CSWs’ rates to 85% of the physician fee schedule will increase recruitment and retention of CSWs in the Medicare workforce, thereby expanding provider options for beneficiaries.
Recommendation:
Given these inequities and the challenges that they pose for service delivery, NASW urges policymakers to:
- Reintroduce and pass the Improving Access to Mental Health Act, which would increase Medicare reimbursement for CSWs to 85% of the Physician Fee Schedule, enhance beneficiaries access to CSW while residing in SNFs, and enhance access to CSW for those experiencing psychosocial concerns arising from medical conditions