NASW Responds to the 2025 CMS Physician Fee Schedule Final Rule

After advocating for expanded Medicare reimbursement for clinical social workers in 2025, NASW is alerting members about some of the outcomes of the Physician Fee Schedule (PFS) final rule, which the Centers for Medicare and Medicaid Services (CMS) issued on Nov. 1, 2024. The changes became effective on Jan. 1 of this year.

New Services

Social workers now have access to two new codes for services they will be able to use for reimbursement this year—for safety planning and follow-up interventions.

A safety planning intervention (SPI) involves working with a patient to develop a personalized list of coping and response strategies, and sources of support to use when experiencing thoughts of harm to themselves or others. It is not a suicide risk assessment, but an intervention provided with a patient who may have an elevated risk for suicide. Safety planning intervention is also used to reduce the risk of overdose.

Follow-up contacts intervention (FCI) involves a series of audio-only phone calls following discharge from an emergency department or other relevant care setting. The calls, which are designed to reduce the risk of adverse outcomes, are meant to encourage the patient to use the SPI as needed in a crisis, to express psychosocial support, and to help facilitate engagement in any indicated follow-up care and services. FCI services are not a substitute for in-person service.

See a December 2024 NASW Tips & Tools for Social Workers to learn more about these codes.

Telehealth Gets an Extension

NASW highlighted the critical importance of telehealth during the COVID-19 pandemic, and the association’s advocacy helped ensure that telehealth flexibilities were extended through March of 2025. The extension preserves access to vital mental health services, including audio-only telehealth, and delays the six-month, in-person visit requirement for telemental health services.

Congress approved these telehealth updates through March 31, 2025:

• Waiving geographic and originating site requirements
• Expanding practitioners eligible to furnish telehealth services
• Allowing Federally Qualified Health Centers and Rural Health Clinics to serve as distant site providers
• Delaying in-person requirements for telemental health services (through April 1, 2025).
• Allowing audio-only telehealth

“In the final rule, (CMS) had actually changed rules about geographic and originating site requirements, eliminating the telehealth flexibility put in place during COVID. That meant that many providers would not be able to continue providing services across state lines,” said Mirean Coleman, LICSW, director of clinical practice at NASW. However, on January 6, 2025, Congress approved the American Relief Act, which extended the telehealth waivers to March 31, 2025, keeping in place covid-inspired telehealth flexibilities. NASW is watching closely to learn what the final status will be after March 31 and will update our members.

NASW is advocating for the permanency of these telehealth flexibilities, recognizing their potential to revolutionize the accessibility and delivery of mental health services. Learn more about telehealth developments during COVID-19.

Digital Access

CSWs may receive reimbursement in 2025 for services using a digital mental health treatment (DMHT) device. The device is software approved by the U.S. Food and Drug Administration to treat a mental health condition in conjunction with ongoing mental health treatment that includes a plan of care. The device generates and delivers a mental health treatment intervention that has a positive therapeutic impact on a patient’s mental health. Learn more about DMHT devices and reimbursement.

Long History of Advocacy with Medicare

NASW advocated for social workers to join Medicare as providers in the 1980s. Coleman said, “Social workers have always been doing the work of mental health,” but being Medicare providers meant that CMS recognized the skill level of CSWs. NASW has provided comments to CMS regarding the Physician Fee Schedule “since we became providers for Medicare in 1989,” Coleman said.

“Being a part of the (CMS) reimbursement system was an area that really helped people to understand who (CSWs) were and what type of services that we did—because we were previously understood by many in the context of child welfare,” Coleman said. “But being part of the diagnosis and treatment system alerted people that clinical social workers do other things, beyond child welfare. So, it expanded public perceptions of social work.”

One of the challenges CSWs still face in this system is low reimbursement rates, Coleman said. “Social workers want to be paid more for their services, and currently we’re only paid for 75% of the physician fee schedule. We want to be paid more, and we think we have the skills to be paid more. So right now we’re advocating to be paid 85% of the physician’s fee schedule.”

This reimbursement rate was set by a provision in the Social Security Act, which limits CSW payments to 75% of what physicians receive for similar services. NASW is working to change this through the Improving Access to Mental Health Act, which includes provisions for fairer compensation for CSWs and improved access to critical mental health services

NASW Comments on the 2025 PFS

Each year, CMS seeks public comments on policies and health care practices for the coming year, and NASW has always submitted comments to advocate for social workers. In addition to telehealth access and higher reimbursement rates, some of NASW’s comments to CMS included the following topics:

• Caregiver training services
• Services for health-related social needs
• Care management
• Post-discharge telephonic follow-up services
• Digital mental health treatment
• Interprofessional consultation
• Rural health clinics
• Federally qualified health clinics
• Opioid treatment programs
• Quality payment program
• Ability to bill Part B for mental health services delivered to beneficiaries simultaneously receiving skilled nursing facility services under Medicare Part A.

Read all of NASW's September 2024 recommendations to CMS for the 2025 PFS Final Rule. Check out this summary of the 2025 Medicare PFS final rule and its implications for social work practice.