The Practice Team at NASW reviewed the 2027 Physician Fee Schedule Proposed Rule and submitted comments to the Centers for Medicare and Medicaid Services on September 11, 2026. You can read the full letter here.

Below is a brief outline of the content in the letter, and the issues that NASW is advocating for and areas where we expressed our concern or desire to see changes.

Telehealth Flexibilities & Service Expansion

• Permanent Adoption: NASW strongly supports extending audio-only telehealth flexibilities and delaying in-person visit requirements for mental health services, urging CMS to make these flexibilities permanent.
• New Telehealth Codes: Supports adding Advance Care Planning (ACP) and Shared Medical Appointments (SMAs) to the Medicare telehealth list.
• Facility Fees: Supports increasing the telehealth originating site facility fee to $32.65.

Reimbursement Rates & Clinical Social Worker (CSW) Scope

• Direct Billing Expansion: Advocates for allowing CSWs to bill Medicare Part B directly for Advance Care Planning, Care Management, and SMAs (when focused on mental/behavioral health).
• Rate Increases: Urges CMS to raise CSW reimbursement rates beyond the current 75% PFS cap and supports higher valuations for timed behavioral health, tobacco cessation, and Collaborative Care Management (CoCM) services.
• Skilled Nursing Facilities (SNFs): Requests the removal of restrictions prohibiting independent CSWs from billing Part B for psychotherapy provided to Part A SNF residents.

Care Management & Integrated Health Services

• Primary Care Integration: Urges CMS to incentivize primary care practices to incorporate social workers for care management, community health integration, and principal illness navigation.
• Community-Based Palliative Care: Recommends making palliative care consultations available to any beneficiary with a serious illness without requiring a limited life expectancy or strict prognosis.
• Shared Medical Appointments: Supports SMAs for chronic conditions but details strict guidelines for beneficiary consent, privacy protections, and copay caps.

Technology, AI, & Coding Systems

• Cautious AI Implementation: Urges CMS to delay incorporating AI into Merit-Based Incentive Payment System (MIPS) measures, citing concerns around ethical standards, client privacy, bias, and data security.
• CPT Maintenance: Recommends retaining the established CPT coding system to maintain consistency across providers and payers.

Medicare Eligibility & Equity Advocacy

• Opposing Coverage Restrictions: Strongly opposes statutory changes under P.L. 119-21 that strip Medicare eligibility from certain lawfully present immigrants.
• Special Enrollment Period: Requests expanding the Special Enrollment Period from 6 to at least 8 months for individuals regaining eligibility, along with retroactive coverage options.
• Dental Coverage: Urges CMS to streamline claims and operationalize coverage for medically necessary dental services inextricably linked to covered medical conditions.