Biden Administration proposes additional expansions to Medicare Part B

Recently, the Centers for Medicare and Medicaid Services (CMS) released their proposed rule for the Calendar Year 2025 Physician Fee Schedule (PFS). As this impacts social work care and billing under Medicare, CHaSCI and the Coalition for Social Work and Health (CSWH) are  providing a review of provisions relevant to social workers and others integrating social care with delivery of health care.   

The PFS, which outlines Medicare payments and other Medicare Part B policy issues, is updated annually via the proposed rule. All proposed changes would build on the 2024 PFS final rule which recognized clinical social workers (CSWs) as eligible providers for health behavior assessment and intervention services and authorized new clinic-based service codes for select social care integration services. Comments and suggestions on the proposal are open until September 9, 2024 with a final rule issued later this year to go into effect on January 1, 2025. 

We encourage you to review CSWH’s stance, submit your own comments, and identify opportunities to engage in these developments to support care for Medicare beneficiaries. A CMS press release and summary of the rule is available here, and the proposed rule can be read in its entirety here. 

Feedback Request for Health Social Services (Page 213) 

Community Health Integration (CHI), Principal Illness Navigation (PIN), Principal Illness Navigation - Peer Support (PIN-PS), and Social Determinants of Health Risk Assessment (SDOH RA) were implemented in 2024 to improve reimbursement for community health services. CMS is seeking input on if the codes are accurately reflective of the services and the providers responsible for implementation. 

CSWH believes this is an opportunity to reinforce the role that social workers of all types can play as part of interprofessional care teams implementing SDOH RA, CHI, PIN, and PIN-PS. While CMS previously clarified clinical social workers (CSWs) can serve as auxiliary personnel to bill CHI and PIN via a supervising practitioner, CMS has not clarified explicitly whether other social workers can also qualify as auxiliary personnel. Around the country, health systems may employ bachelor’s-prepared social workers (BSWs) and master’s-prepared social workers (MSWs) in job titles such as case manager, care coordinator, care navigator, and health support specialist.  

CSWH will elaborate further in our comments on examples of BSW and MSW preparation and example jobs. The BSW degree prepares students for generalist practice positions (such as casework) where they engage with clients (e.g., individuals, families, communities), assess their needs, link them to services, and monitor their progress. Accredited BSW programs require a minimum of 400 hours of supervised field experience. MSW programs prepare graduates for work in their chosen field of concentration or specialization and include developing skills required to perform clinical assessments, manage large caseloads, take on supervisory roles, engage in policy-level advocacy, and explore new ways of drawing on social services to meet the needs of clients and communities. MSW programs last 2 years and include a minimum of 900 hours of supervised field instruction. Social work disciplinary competencies covered in BSW and MSW programs overlap with the training requirements outlined for CHI and PIN auxiliary personnel. 

CMS has also identified that Health Behavior Assessment and Intervention (HBAI) can serve as an initiating visit for PIN when the focus of HBAI services is the focus of PIN. The 2024 PFS authorized CSWs and other mental health counselors to be independent providers of HBAI services. CMS has suggested that CSWs may be eligible to provide PIN as independent provider  but has clarified that CSWs cannot themselves supervise and bill on behalf of other auxiliary personnel who are operating under the guidance of the social worker. We believe this policy should be addressed to minimize barriers to care, as clinical social workers are often operating as the core coordinator of community care teams and are recognized as specialists in social care. 

Additional Codes for Interprofessional Consultations (Page 384) 

Medicare has six codes which cover interprofessional consultations conducted via phone, online, or through electronic health records. These codes are only applicable to practitioners already eligible to bill Medicare for evaluation and management (E/M) visits. Based on comments submitted to the last PFS, the proposed rule suggests opening these services with six new codes specifically for practitioners in behavioral health professions, such as psychologists, social workers, and mental health counselors.  

CSWH sees this approach as an excellent step for improving integration of behavioral health care into primary care and other settings, and for allowing CSWs to capture the time they spend inviting clinical expertise from and sharing clinical expertise with interprofessional colleagues as part of interprofessional consultation sessions. This aligns with the broader push from CMS to improve care coordination across providers for better patient outcomes and to recognize behavioral health care on equal footing as physical health care. 

Caregiver Training via Telehealth (Page 90) 

CMS added a suite of codes for Caregiver Training Services (CTS) to the 2024 PFS, focused on strategies and techniques to facilitate the patient’s functional performance in the home or community, and on behavior management and modification services with a group. The final rule did not include CSWs as eligible providers, but later on CMS FAQ stated that CSWs are indeed eligible to bill for CTS. Further clarification from CMS would facilitate further roll out, specifically on which CTS codes CSWs can bill independently for and if there are any limitations on beneficiary qualifying conditions given Medicare’s definition of CSW services being limited to mental health diagnosis and treatment.  

The CTS codes are proposed as a provisional addition to the Medicare Telehealth List with future data consideration for a permanent status. In recognition of the medical tasks that many caregivers assist with such as wound care, CMS is further suggesting new codes to cover CTS for direct care services. CMS is also proposing to recognize behavior management and modification training services provided to an individual in addition to the group services recognized in 2024. We support each of these proposals.  

Additional Codes for Crisis Intervention (Page 370) 

CMS previously requested stakeholder input on enhancing suicide prevention efforts and specifically received feedback on improving Safety Planning Interventions (SPI) and Post-Discharge Telephonic Follow-Up Contacts (FCI). Two new proposed would 1) encapsulate SPI services when they are performed alongside an E/M or psychotherapy visit and 2) cover certain post-discharge follow-up calls from the Emergency Department for behavioral health crisis visits. 

CSWs provide safety planning as part of regular care within their scope of practice, and CSWH is heartened that CMS is supporting the workforce providing these interventions. We support CMS enabling services when delivered by arrangements with peer support specialists and other auxiliary personnel working with oversight from an independent billing provider.  

For Further Consideration 

CSWH has detailed key takeaways that we see as being of interest to Coalition members. There are further sections of the PFS covering related topics to the social work profession and equity in care, such as: urgent care and emergency department capacity, Intensive Outpatient Program (IOP) services, cardiovascular risk assessments, dental coverage for beneficiaries with end-stage renal disease, and Advanced Primary Care – Hybrid payment, and Advanced Primary Care Management. 

Finally, it is noteworthy that due to budget neutrality adjustment, any time Medicare physician payments are estimated to increase by $20 million or more (due to either coverage for new services or rate increases for services already covered), CMS is required to offset that with cuts. As such, the 2025 proposed PFS includes a rate reduction that will reduce average payment rates by 2.94% compared to 2024. This will take Congressional action to address. 

We encourage social workers, stakeholders, and advocates to further review details of the proposed rule and submit comments prior to September 9. The official press release and CMS’s website offer comprehensive summaries on the full scope of proposed changes.