A question frequently raised by new social work graduates is whether or not they can bill for services once they receive their limited license.
Individually, LLMSWs (limited license master social workers) cannot bill for psychotherapy services as they have not completed the licensure requirements. However, in the case of Medicaid, LLMSWs are able to bill under their clinical supervisor (who must be a fully licensed social worker). The LMSW supervisor must be on site, but is not required to be in each session for the billing to take place. According to the PIHP-MHSP Provider Qualification manual a social worker is an:
“Individual who possesses Michigan full or limited licensure as a master’s social worker or a bachelor’s social worker. Social workers with limited licenses must be supervised by a fully licensed master's social worker. Student interns pursuing a master’s degree in social work and supervised by a Licensed Masters Social Worker in a manner that meets the requirements of a Council on Social Work Education (CSWE) accredited education program curriculum preparing an individual for licensure may provide services.”
Medicare recognizes licensed clinical social workers (not limited licensed) as acceptable providers under Part B to furnish diagnostic and/or therapeutic treatment for mental, psychoneurotic, and personality disorders as well as Medicare screening, brief intervention, and referral to treatment (SBIRT) services. Medicare requires that social workers:
1. Have a Master’s or Doctoral degree in social work;
2. Have performed at least 2 years of supervised clinical social work; and
3. Is licensed or certified as a CSW by the state in which the services are performed; or
4. If the individual practices in a state that does not provide for licensure or certification, has completed at least 2 years or 3,000 hours of post Master’s degree supervised clinical social work practice under the supervision of a Master’s level social worker in an appropriate setting (for example, a hospital, Skilled Nursing Facility [SNF], or clinic)
If a LLMSW is working in an outpatient psychiatric clinic (OPC) the billing is almost always completed under the psychiatrist on staff. A fully licensed master’s social worker may perform the billing if no psychiatrist is present.
NASW best practices recommend that you:
1. Know what requirements your specific insurance provider(s) requires
2. Possess a Master of Social Work Degree or a doctorate degree from an accredited school of social work.
3. Have a minimum of two years or 3,000 hours of post-master’s experience in a supervised clinical setting (two years full time in 4,000 hours)
4. Have a clinical license in the state of practice. In the absence of a state license, a state certification is required.
5. Have a National Provider Identifier Number.
6. Have malpractice insurance
7. Obtain the ACSW credential
Each insurance provider has different standards and requirements. Some providers allow LLMSWs to bill under their supervisor (like with Medicaid), some do not. It is best practice for agencies employing social workers to check with the individual insurance providers they use.
Limited licensed social workers going into private practice should make sure that there is a fully licensed master’s social worker on site and that proper supervision is being acquired. It is the recommendation of NASW – Michigan Chapter that LLMSWs do NOT practice in a solo private setting until the licensure process is completed, as it is often out of their scope of practice and conflicts with our Code of Ethics.
The NASW Code of Ethics states that social workers should only practice within area(s) of competence and their scope of practice. “Social workers should provide services and represent themselves as competent only within the boundaries of their education, training, license, certification, consultation received, supervised experience, or other relevant professional experience. (b) Social workers should provide services in substantive areas or use intervention techniques or approaches that are new to them only after engaging in appropriate study, training, consultation, and supervision from people who are competent in those interventions or techniques (1.04)”. Limited licensed social workers should be aware of potential liability and ethical concerns if working in private practice without proper training or supervision.
Clinical social workers represent the largest group of behavioral health practitioners in the nation. They are often the first to diagnose and treat people with mental disorders and various emotional and behavioral disturbances. Clinical social workers are essential to a variety of client-centered settings, including community mental health centers, hospitals, substance use treatment and recovery programs, schools, primary health care centers, child welfare agencies, aging services, employee assistance programs, and private practice settings.
Clinical social work is a state-regulated professional practice. It is guided by state laws and regulations. In Michigan, clinical social workers are required to have the following credentials:
· A master’s degree from a social work program accredited by the Council on Social Work Education
· A minimum of two years or 4,000 hours of post-master’s degree experience
· 100 hours of supervision by a LMSW
· Pass the standard ASWB exam
· A clinical license in the state of practice
Below are some practice and policy resources for clinical social workers to help them develop and maintain an effective clinical practice. Information is listed under categories such as billing codes, documentation, practice, reimbursement, and standards
· NASW Code of Ethics - http://www.socialworkers.org/pubs/code/default.asp
· Clinical Social Work Standards - http://www.socialworkers.org/practice/standards/NASWClinicalSWStandards.pdf
· NASW Assurance (Liability Insurance) - http://www.naswassurance.org/
· ACSW Credential - http://www.socialworkers.org/credentials/credentials/acsw.asp
· Michigan Public Health Code - http://www.legislature.mi.gov/%28S%28rdblsu45fdc02t45gtyr5lis%29%29/mileg.aspx?page=getObject&objectName=mcl-368-1978-15-185.