September 26, 2025

It appears that the furious effort by mental health groups to do away with the requirement that new patients be seen in person before beginning virtual mental health treatment has failed for now. Therefore, starting September 30, 2025, any new Medicare patient must be seen in-person before starting virtual treatment, and once a year after that. The good news is that current patients being seen virtually will not need to be seen in person.

If CMS does change these rules in the future, there is strong support for those changes to be retroactive. As most of you know, CMS has agreed to cover telemental health permanently, but the in-person requirements going forward will make virtual treatment much more difficult and have a chilling effect on seeing patients through telemental health. Additionally, there is the problem for LCSWs who have given up having an office where they can see patients in person.

CSWA will continue to provide information on this important topic as we receive it. Please let Laura Groshong, LICSW, CSWA Director of Policy and Practice know if you have any questions at lwgroshong@clinicalsocialworkassociation.org.