There is good news to pass along about Medicare telehealth flexibilities - this time for the longer term.

On February 3, the “Consolidated Appropriations Act, 2026” was signed into law, ending a short-term 4-day partial government shutdown.

The Act, part of a broader fiscal year (FY) 2026 spending package, includes a further extension of Medicare telehealth flexibilities that recently expired on January 31, 2026.

Originally introduced as temporary pandemic-era measures, these telehealth policies have been repeatedly sustained through short term legislative extensions.

Among other flexibilities being extended, this is key for outpatient behavioral health:

• In-Person Requirement for Mental Health Visits: Medicare patients receiving services for the diagnosis, evaluation, or treatment of a mental health disorder via telehealth may continue to do so without having received a Medicare-covered in person item or service through January 1, 2028.

In other words, Medicare behavioral health services can continue to be provided via telehealth without any in-person meetings required. This will be the case through at least Jan. 1, 2028. In the meantime, there are bills continuing to move through Congress to make the flexibilities permanent.

As a reminder, telehealth services generally have already been made permanent for behavioral health specifically, including audio-only.

More information at link below for general allowances included in the law.

NASW-MA will continue to follow developments, and will keep membership updated.

NOTE: We will soon be removing anyone on this Clinical Alert list who does not have an active NASW membership. To ensure continuing to receive notifications and other benefits from NASW, be sure that your membership is current or you can rejoin via the link below.

Hello,

This is to update information previously sent about potential Medicare regulations changes.

As of Oct. 1st, some Medicare telehealth restrictions went into effect. There is still very good chance that they will still be reversed temporarily or permanently. But for now, they are in effect.

For behavioral health, Medicare laws allow for telehealth permanently.

But there are some restrictions that will be in effect for now.

• For new clients after Oct. 1, it is required to see them at least once in-person prior to starting telehealth.

• There are no exceptions in place for this requirement.

• Ongoing clients do NOT have to have an initial in-person session at this point.

• For both new and ongoing clients, there will be requirement of one in-person visit annually.

• There are exceptions written into the regulations for this, with the following language in the Medicare rules

• If the patient and practitioner consider the risks and burdens of an in-person service and agree that … these outweigh the benefits … and the practitioner documents the basis for that decision in the patient’s medical record, then the in-person visit requirement is not applicable for that 12-month period

• Note that in-person does not necessarily mean office visit; home visits or meetings in other agreed-upon locations would be acceptable

This post from a Medicare expert expands further on all this, including the exceptions. 

Should you choose to take on new Medicare clients at this time, you will need to be able to see them in-person for the first visit. For ongoing clients, there is a long lead time to figure out a plan for an in-person visit or to claim exceptions, given the 12-month period allotted.

Note also the following, as posted by National NASW:

Medicare Administrative Contractors (MACs) have been directed to temporarily hold claims for 10 business days to avoid the need to re-process claims should Congress act to further extend the flexibilities.

So, there may be some delay in Medicare payments, but this also indicates that there is good chance that these restrictions may well be reversed soon.

NASW-MA is following closely, and will be posting updates on this topic through alerts, notices to our website, social media, postings to the Private Practice Google Group, listings in the monthly Chapter E-News, etc.

Best,

Barbara Burka, LICSW
Director of Clinical Practice
Director of Therapy Matcher
bburka.naswma@socialworkers.org

What you can do

• Contact your federal senator and representatives to advocate for postponing or eliminating these requirements. Here is the link to an NASW template to indicate your support for the bill that would permanently eliminate these requirements: https://www.socialworkers.org/Advocacy/Action-Center

• Start to be planful to be ready if changes do go through. For ongoing clients, consider how to potentially arrange for an in-person visit within next 12 months. For others, consider how to document reasons that in-person visits are not possible. 

• In the event that changes do move forward, be ready to consider carefully any new Medicare telehealth cases, and whether it could be feasible to arrange an in-person visit during first 6 months of treatment. 

NASW-MA is following closely, and will be posting updates on this topic through alerts, notices to our website, social media, postings to the Private Practice Google Group, listings in the monthly Chapter E-News, etc.

Best,
Barbara Burka, LICSW
Director of Clinical Practice
Director of Therapy Matcher

2025 Medicare Telehealth Regulations: Updated Status

Original Alert: Tuesday, December 17, 2024  

Updated Alert: Thursday,  January 2, 2025

Congress passed an appropriations bill on December 20, 2024 that included provision to extend current Medicare allowances short-term through March 31, 2025. That includes waivers for in-person meeting requirements. 

So, there will be no in-person requirements being put into place at this point, but still possibly coming after March.

Congress will revisit this along with other Medicare allowances, and there still could be further extensions.

NASW-MA will keep members updated as we can. 

________________________

Many have heard of possible changes to telehealth allowances for Medicare, to begin on Jan. 1, 2025. There has been quite a bit of confusion and misinformation around.

At this point, there is some information that is clear, and some that is still in flux.

What we know

• There are a number of changes coming in 2025 for some aspects of Medicare telehealth. But for the most part, those changes do NOT apply to behavioral health.

• Medicare telehealth allowances for BH will continue, to include both video and audio-only.

• Rates will continue to be equal to in-person as long as using POS 10.

• The changes that could possibly be coming are requirements for one in-person visit during the first 6 months of treatment, and once every 12 months after that.

What is still in flux

• Those in-person requirements may still be reversed through a bill that is working its way through Congress - the Telehealth Health Care Access Act. The status of that bill is still unclear - it could be voted through before Dec. 31st, or extended into the new year. National NASW is monitoring the status.

What you can do

• National NASW has put together this Action Alert that members can use to advocate with your federal senators and representatives about the above bill.

What else to keep in mind

• Even if these in-person requirements do go through, there are exceptions built into the regulations, at least for the 12-month requirement, which "must be documented in the patient’s medical record noting a reason of the exception (such as a travel hardship, or unavailability of providers or patients in scheduling)."

• There is not yet information on any more specifics on how exceptions would be determined or documented, and how enforcement on this overall. We will share as we learn more.

Bottom line for now

• At this point, it seems that providers can move forward with telehealth as has been provided, until more information becomes available - with the understanding that changes could be coming down the pike.

• Increase the number of qualified behavioral health professionals supervising students and workers pursuing new certification or licensure as behavioral health clinicians.
• Increase the number of hours that clinical supervisors can dedicate to supervision.
• Increase the number of newly certified or licensed behavioral health clinicians serving residents in Massachusetts.

We want to call attention to new reporting requirements for private practitioners with LLCs and similar entities - with deadline of Jan. 1, 2025 for filing.

National NASW has posted about this, and we are sharing that information directly from the chapter, to help ensure that affected members are aware.

These are called Beneficial Ownership Information (BOI) reports, as required by the Federal Corporate Transparency Act (CTA).

See below for recent National NASW posting about this, which includes a link to a previous article with full information.

Here are some key takeaways from the original NASW posting on this.

The CTA applies to corporations, limited liability companies (e.g., LLCs, PLLCs), and other entities that are created through filing a document with a secretary of state (e.g., LLPs, LLLPs, and business trusts) and the beneficial owners of those entities.  Beneficial owners are individuals who exercise substantial control over a reporting company or control at least 25% of the ownership interests of a reporting company.

If you directly or indirectly have a significant ownership stake or control in a reporting company, you must file a report with your BOI to FinCEN. FinCEN information is accessible to federal, state, local, and tribal officials, and certain foreign officials who submit a request for BOI through a U.S. federal government agency in connection with national security, intelligence, and law enforcement. The information will be stored in a non-public database.

The deadline to report BOI depends on the date of company formation:

• Companies created before January 1, 2024, must file BOI by January 1, 2025.
• Companies created on or after January 1, 2024, must file BOI within 90 calendar days of receiving notice of the company’s registration.
• Companies created on or after January 1, 2025, must file BOI within 30 calendar days of receiving notice of the company’s registration.

NASW members are welcome to contact NASW Member Services to seek a legal consultation on this and other social work practice legal issues.

Note: You may need to consult an accounting and/or tax professional for compliance questions or to prepare for tax year requirements.

See below for information on this through the Massachusetts Secretary of State office.

The link to the e-filing system is below, and includes information and instructions as needed. It seems like it will be relatively straightforward.

We realize that this notice comes close to the deadline for filing. We hope that many will have heard of this through National NASW or otherwise, and that this information will be helpful in moving forward at this time.

• Some providers have reported being able to use their existing EHR to submit claims successfully. Others who regularly use clearinghouses other than Change Healthcare have been able to submit BCBS claims in that way. 
  
  
• For those without an existing connection with an EHRs or clearinghouse, there is the option to establish an account - potentially through a short-term free trial, or at a monthly rate for the duration of this situation
  
  
  • Some examples of EHRs: Simple Practice, Theranest, Therapy Appointment, and others
    
    
  • Clearinghouses that have been suggested: Office Ally, Availity, along with others listed on BCBS page

• The other alternative is to send paper claims 
  
  
  • Be sure to purchase and use the original red HCFA / 1500 forms
    
    
  • Can purchase software to fill out form online, and print directly onto the forms
    
    
  • Forms can be handwritten, if very clearly printed in black ink
    
    
  • There will be longer delay with paper claims (they are advising 30-45 days), but they will process, and will pay out through Payspan in the usual way
    
    
  • More details and mailing address on the BCBS page
    
    
• BCBS has stated that while they will accept paper claims, they strongly encourage providers to utilize other clearinghouses.
  
  
• BCBS announced on March 7^th that they would waive timely filing limits at this time. Keep watching the BCBS page for any changes on that. 

• If you might be interested to connect with a billing service during this time to assist, here is a list of billers who have been recommended by NASW members

• For sessions after December 31, 2023, use POS 10 for telehealth services when the client is in their home, or any place other than a hospital or facility.

• Note that POS 02 is intended for telehealth when client is located at a hospital or facility, and payment would be at the lower facility rate.

• There is no longer a telehealth modifier required for video sessions. For audio-only sessions, use modifier 93.

• For 2023, continue billing telehealth claims with the 11 POS indicator you would bill for an in-person visit. You must use Modifier 95 to identify as telehealth through December 31, 2023. 

• After December 31, 2023, use POS 10 for telehealth services when the client is in their home, or any place other than a hospital or facility.

• Note that POS 02 is intended for telehealth when client is located at a hospital or facility, and payment would be at the lower facility rate.

• After December 31, 2023, there will be no telehealth modifier required for video sessions. For audio-only sessions, use modifier 93.

Starting April 1, 2023, MassHealth will begin the eligibility redetermination process, renewing all 2.3M members over the following 12 months. This will generally be the first-time members are at risk of losing their coverage since February 2020.

In preparation for this effort, MassHealth has increased staffing significantly to handle a greater volume of calls and applications, improved our systems to automatically renew as many members' coverage as possible, and is working in close collaboration with health plans, providers, and other stakeholders. Even with this preparation, we understand that this may be difficult for members. We’re asking for your support as part of our outreach strategy.

MassHealth is sharing the Phase 2 Redeterminations Outreach Toolkit for you and your NASW-MA membership to help educate members and make sure they are prepared and know how to complete their renewal. This toolkit includes key messages as well as downloadable flyers, posters, and other materials in 9 languages. This toolkit also includes materials for specific populations, such as members experiencing homelessness, older adults, or members with disabilities. We are also excited to share the MassHealth Renewal Help Guide, a new resource for individuals who interact with members.

Click here for the full Clinical Alert: https://conta.cc/3oIl8Nc

• These proposed cuts include a four (4) percent cut in 2020 for code revisions or a seven (7) percent cut in 2021 to increase reimbursement for evaluation and management (E/M) services which are provided by physicians, nurse practitioners, and physician assistants
• Clinical social workers are already only reimbursed at 75% of the physician fee schedule, lower than any other mental health provider in Medicare Part B
• Read the full proposed rule here

Important NEW Information for Private Practitioners about the Partners/Optum Transition

1. You applied to be either an Optum or a Partners-only provider, but did not receive your signed contract by 1/1/19, or 
2. You are choosing to not apply to either panel

• Alec Ward, Network Director: alec.ward@optum.com
• Gabriel Nathan, Senior Network Manager: Gabriel.nathan@optum.com
• Janet Choup, Network Manager: janet.choup@optum.com

The Centers for Medicare & Medicaid Services released the final rule for the 2019 Physician Fee Schedule on November 1, 2018. The 2019 final rule for the CMS Quality Payment Program excludes clinical social workers from the Merit-Based Incentive Payment System (MIPS) reporting in 2019. This is a victory for clinical social workers who have limited quality measures to report on and in the past have received penalties when reporting quality measures.

As you may remember, thanks to your consistent feedback, NASW-MA and our partners advocated on your behalf to halt the Beacon clawback process this past winter/spring. At that time, clawbacks were suspended until October 1, 2018, and clinicians were given an opportunity to appeal.

We are excited to share that Beacon will not resume audits this October as originally planned, and audits will be “business as usual” in terms of checking for compliance with state and federal laws. Additionally, Beacon terminated its contract with Nokomis in June, so all audits and appeals will be done in house by Beacon directly. As you know, audits come with the territory of being an independent practitioner, but we hope that these changes will reduce the chance of clawbacks.

Beacon is also taking the following steps to improve their operations:

• Establishing a hotline solely for NASW-MA members, giving members direct access to Beacon. This is set to launch in the fall.
• Hiring a LICSW to their payment integrity staff to better assist social workers with clinical and billing issues.
• Meeting with NASW-MA and other professional membership associations on a quarterly basis to establish a direct line of communication to address issues as they arise and to keep us abreast of other changes.

Additionally, we’ve been working with MassHealth, providers, and managed care companies to create a bulletin about documentation, audits, and related processes. Expect to see this in November.

As always, please reach out to me with any clinical/insurance-related issues or concerns. Thank you for your membership!

Sincerely,

Jonas Goldenberg

Director of Clinical Issues and Continuing Education

NASW-MA

jgoldenberg.naswma@socialworkers.org

August & September 2018

ALL social work licenses are being renewed online this year. If you received your renewal license in the mail, just carefully follow the instructions detailed in the letter. The process includes three sections: 1) setting up an account, 2) linking your new account with your license number, and 3) renewing your license (including submitting online payment). It should take you about 15-30 minutes to complete the three-step process.

VERY HELPFUL INFORMATION

The Board has just published the following Online License Renewal Step-by-Step Instructions (with diagrams!) to help you through the entire online renewal process.

OTHER USEFUL INFORMATION

• At this time, the MA Board of Registration of Social Workers does NOT have a paper alternative - renewals must be done online. This could change in the future, but for now, paper renewal are not an option. NASW suggests you complete the online process and not count on doing a paper renewal. If you do not have access to a computer, we suggest partnering with a trusted friend who does or going to your local library. 
• If you own a Mac, you may have difficulty renewing online. The process seems to work better with a PC. In fact, we are hearing that the entire renewal process works best using Internet Explorer.
• If you did NOT receive your license renewal letter via normal postal service delivery, there is an alternative to getting the instructions. Send an email to DPLauthcodes@mass.gov with subject line: "Social Work License Authorization Code." In the body of the email include:
  1. Full Name
  2. License Number
  3. Type of License
  4. Mailing Address (last known address or past address)
• You should receive a follow-up email that contains all information you need for online renewal with 3 – 7 days. 
• As the September 30th deadline draws closer, it could take longer to get a response, so please plan accordingly.

VITALLY IMPORTANT FOR LICSWs

• If you are licensed as a LICSW you must have, or get, an NPI# (https://nppes.cms.hhs.gov/NPPES/Welcome.do)
  • If you are not sure whether you have one go to: https://npiregistry.cms.hhs.gov/ - if it does not work, call NPI at 800-465-3203
• If you are licensed as a LICSW you must then submit an application and contract to be a MassHealth Non-billing Provider (nearly all LICSWs fit in this category) or apply to be a MassHealth Qualified Member Beneficiary (QMB) Provider (only private practice providers who bill Medicaid secondary to Medicare should apply).
  • If you are already a QMB provider you are all set; there is nothing else you need to do.
• Access the MassHealth Application and Contract and detailed instructions here

Section 6401 of the Affordable Care Act requires that, for MassHealth services that must be ordered, referred or prescribed, the provider who ordered, referred or prescribed the service must be enrolled with MassHealth, at least as a nonbilling provider in order for the claim for the service to be payable.

As LICSWs are eligible to order, refer or prescribe certain services for MassHealth members, under state law they  must apply to enroll with MassHealth at least as an “ordering and referring” (nonbilling) provider in order to obtain and maintain Massachusetts state licensure. Providers who are already enrolled with MassHealth have already met the requirement and do not need to take further action. 

MassHealth has created a Nonbilling Provider Application for provider types that are not eligible to enroll as billing providers. This application can also be used by provider types who are eligible to enroll in MassHealth as billing providers but who choose not to at this time.  

Providers who enroll with MassHealth as nonbilling providers via the Nonbilling Provider Application are not permitted to submit claims to MassHealth.

LICSWs are currently only eligible to enroll in MassHealth as nonbilling providers or as a special type of billing provider known as “QMB Only." QMB Only status only allows the provider to be paid by MassHealth for Medicare crossover claims for members who are eligible for both Medicare and MassHealth.

ALL Massachusetts licensed LICSWs must apply to MassHealth to be a QMB Only or a NonBilling provider. The law does not allow for any exceptions. This applies to all practicing and non-practicing Massachusetts licensed LICSWs, if you are renewing your license in 2018 or at any time in the future. LICSWs living in other states wishing to renew their Massachusetts license also need to apply to MassHealth to be a QMB Only or nonbilling provider.

Any and all questions regarding the application process should be directed to the MassHealth Customer Service Center at 1.800.841.2900

TTY services at 1.800.497.4648

Important points to know:

• All applications are accepted and reviewed through MassHealth. The licensing Board does not review or approve any MassHealth provider applications.
• To Apply:
  • All nonbilling providers may print out and return the application and provider contract that are on the MassHealth website:  http://www.mass.gov/eohhs/provider/insurance/masshealth/aca/aca-section-6401enrollment-information.html
  • All LICSWs who wish to apply to be QMB Only providers must contact the MassHealth Customer Service Center to receive an application at 1.800.841.2900
• All applications must be complete in order to comply with the state law requirement to apply to participate in MassHealth.
  • All applications, including the Nonbilling Provider Application, require an NPI number.  If you do not have an NPI number, you will need to obtain one in order to complete the application. The instructions on how to obtain an NPI are at: https://nppes.cms.hhs.gov/webhelp/nppeshelp/NPPES%20FAQS.html
  • All Applications require the inclusion of your Social Security Number (SSN) to allow MassHealth to perform the required review of the application in accordance with federal law.
• All Massachusetts LICSW licenses expire on October 1, 2018. Upon renewal of that license, all LICSWs will be asked to attest that they have applied to MassHealth as a QMB Only or nonbilling provider. LICSWs who are unable to make this attestation will not be eligible for licensure renewal. 
• We encourage LICSWs to apply to enroll with MassHealth as soon as possible so that their license renewals will not be delayed.

More information regarding how to enroll can be found here: http://www.mass.gov/eohhs/provider/insurance/masshealth/aca/aca-section-6401enrollment-information.html

If you are a Licensed Independent Clinical Social Worker (LICSW) in Massachusetts, you must register with MassHealth as a billing or non-billing provider in order to renew your license by the September 30, 2018, deadline. Failure to do so could result in suspension or loss of license.

Non-billing Provider

A non-billing provider is a LICSW who does not bill MassHealth directly for any client services. If you see MassHealth clients and bill Beacon, MBHP, Tufts Public, or HNE, you are NOT billing MassHealth directly; you MUST register as a non-billing provider (unless you are a QMB provider, see below). Most LICSWs fall within the non-billing provider camp.

Download Non-billing Provider Application and Contract Here

The Application is Asking for a National Provider Identification (NPI) Number. What is it / How Do I Get One?

A National Provider Identifier (NPI) is a unique 10-digit identification number issued to health care providers in the United States by the Centers for Medicare and Medicaid Services (CMS). If you don’t have an NPI#, you will have to get one. All LICSWs must have an NPI# in order to complete the MassHealth registration paperwork. Visit this website to get an NPI number or call 800-465-3203.

I Don't Understand Why I Have to Do This / How to Fill-out the Non-billing Provider Paperwork.

MassHealth is hosting a webinar for LICSWs on Tuesday, August 28, from 9:00 - 10:00 am. To register, please visit:  masshealthtraining.com and select course title "08-28-2018 Ordering Referring and Prescribing Webinar for LICSWs." Download more information about this training here.

Can't make the webinar or need more immediate information? See the  Step-by-Step instructions and Frequently Asked Questions  posted on NASW-MA's website.

Where Do I Mail Completed and Signed Documents?

As stated on the contract, mail completed and signed documents to MassHealth Customer Service Center, Attn: Provider Enrollment, P.O. Box 121205, Boston, MA 02112-1205.

I Already Applied but Haven't Heard Back. How Do I Check the Status of My Application?

Billing Provider

A billing provider is a LICSW who is registered with MassHealth and is authorized to bill MassHealth directly for client services. If you are a QMB provider and bill MassHealth for co-pays for your Medicare clients who have MassHealth secondary, you are already registered and you do not need to do anything. If you believe that you are a billing provider, but not a QMB provider, please contact MassHealth Customer Service Center at 1-800-841-2900 in order to get additional information or request an application.

Updated 8/13/18

During the past 90 days, all therapists were allowed to bill the insurance programs to which their MassHealth clients were transferred, whether or not the therapist was a provider for the new insurance.

As of today, a therapist is supposed to have applied to be on the new insurance and been accepted, arranged for a single case agreement, or arranged to transfer their out-of-network client; HOWEVER, there have been many glitches, and MassHealth has negotiated the following with each of the insurance companies covering their clients:

1. Although MBHP stated that it would not start paying newly empaneled therapists until June 5, in fact they will cover all authorized sessions that occur from June 1-5.
2.  The major problems at this time are with Tufts Health Public Plans. THPP has been slow to credential new therapists, at times stating they were not accepting applications; that applications would not be read until October 1; that new providers could not bill until they received a letter from their Credentialing Committee in addition to getting back their countersigned contract. MassHealth has insisted that THPP continue to accept applications, and that member care should not be disrupted while applications for credentialing are being processed.

 What to do:

1. If you have applied to MBHP and been accepted on to their panel – begin billing as a provider today, June 1.
2.  If you applied to THPP but your application was rejected or not yet processed - write to Nancy Carlucci at MassHealth with the specifics: nancy.carlucci@state.ma.us. She will triage your situation to the MassHealth contract managers, so they can work with the plans to resolve specific cases. 
   •  Please write to her even if you have contacted her before.
   • Include your NPI and describe the problem you are having.
   • And continue to see your clients during this ongoing transition. MassHealth wants all their members to be able to continue to see their therapists.
3. If your MassHealth client has Fallon or BMC HealthNet, or NHP in Merrimack Valley (all 3 of which are part of Beacon), and you have been reimbursed, it is assumed that you can continue to bill as you have been over the past three months.
4. All providers should be careful to track authorizations, and request additional authorizations when necessary.

If you are a Beacon provider you should have received communication (a “payment integrity” packet) directly from them about this reimbursement process. You have until September 1, 2018, to complete this paperwork and return it to Beacon.

VERY IMPORTANT: If you didn’t receive the “payment integrity” packet in the mail, please let us know. We are in direct communication with Beacon and will share your name and contact information with our contact at Beacon who will then follow-up with you.

We’d like to hear from you regarding your experience with Beacon customer service and this recoupment process thus far. Please fill-out this short form so we can stay in-the-loop about which of our members were impacted by the Beacon/Nokomis audit and who did or did not hear from Beacon about the current recoupment process.

Thank you! Please let Rebekah, Jonas, or Sophie know if you have any questions:

Rebekah: rgewirtz.naswma@socialworkers.org

Jonas: jgoldenberg.naswma@socialworkers.org

Sophie: shansen.naswma@socialworkers.org