Clinical Social Work Practice Tools: Billing

Following a recent update from the Center for Medicare, and Medicaid Services (CMS), NASW has received multiple inquiries regarding telehealth place of service codes (POS) for Medicare, Medicaid, and private health insurance companies. The purpose of this blog is to clarify what POS codes clinical social workers should use when providing telehealth services.

Beginning January 1, 2022, clinical social workers (CSWs) will become eligible to participate in Medicare’s Quality Payment Program (QPP). NASW advocated for the inclusion of CSWs in the QPP and are pleased that they are now eligible.

On November 2, 2021, the Centers for Medicare and Medicaid Services (CMS) released the CY 2022 Medicare Physician Fee Schedule (PFS) final rule. The 2400+-page rule includes updates to policies and payments that are pertinent to clinical social workers (CSWs) and other Medicare providers. NASW submitted comments on September 13, 2021 to CMS on the proposed rule.  A  number of NASW’s recommendations are reflected in the final rule. The final rule goes into effect on January 1, 2022. Below is a summary of the provisions and their implications for CSWs.

NASW will continue to monitor Medicare regulation and inform members of any further updates from CMS clarifying the CY 2022 final rule provisions. NASW also continues to undertake vigorous advocacy with CMS on behalf of CSWs and their clients, including efforts to increase the CSW reimbursement rate.

Beginning January 1, 2022, clinical social workers (CSWs) will become eligible to participate in Medicare’s Quality Payment Program (QPP). NASW advocated for the inclusion of CSWs in the QPP and are pleased that they are now eligible. CSWs participate in the QPP through a system called the Merit-Based Incentive Payment System (MIPS). MIPS was designed to tie payments to quality and cost efficient care, drive improvement in care processes and health outcomes, increase the use of healthcare information, and reduce the cost of care.  15 other provider types participate in the QPP.

CSWs may participate in the QPP by earning a payment adjustment for Medicare Part B covered professional services based on a performance evaluation across different categories that focus on the quality of care provided to a patient.

The Centers for Medicare and Medicaid Services (CMS) proposed CY 2022 Physician Fee Schedule (PFS) issued on July 16 includes a variety of provisions that are relevant to clinical social workers (CSWs) who are participating providers in Medicare. These provisions are outlined below and cover a number of areas, including but not limited to telehealth, the Quality Payment Program (QPP) and reimbursement.

NASW submitted a comment letter to CMS on September 13, 2021. In addition, NASW members were invited to submit their own comments via an action alert. The agency will issue the final rule in late 2021. NASW will provide an update at that time on the contents of the rule and implications for clinical social workers (CSWs).