Reimbursement for Associate Clinical Social Worker and Associate Marriage and Family Therapist Services for FQHCs and RHCs

June 16, 2020

In response to the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) have approved State Plan Amendment (SPA) 20-0024, which temporarily adds Associate Clinical Social Worker (ACSW) and Associate Marriage and Family Therapist (AMFT) services at Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) as billable visits. ACSWs and AMFTs are not licensed practitioners, per the California Board of Behavioral Sciences. Therefore, services are billed under the supervising licensed, billable behavioral health practitioner of the FQHC or RHC. The licensed behavioral health practitioners must supervise and assume the professional liability of services furnished by the unlicensed ACSWs and AMFTs. Additionally, the licensed practitioner must also comply with supervision requirements established by the Board of Behavioral Sciences.

During the public health emergency declaration, an FQHC or RHC can be reimbursed at the Prospective Payment System (PPS) rate for a visit between a FQHC or RHC patient and an ACSW or AMFT. The visit may be conducted as a face-to-face encounter or, if it meets all relevant requirements, via telehealth.

Payment for ACSW or AMFT services is as follows:

  • ACSW or AMFT services provided by FQHCs and RHCs that meet visit criteria and are provided on or after March 1, 2020 may be eligible for reimbursement at the PPS rate.
  • Services are billed under the supervising licensed, billable behavioral health practitioner of the FQHC or RHC.
  • These services are billed using existing claiming processes that include billing managed care plans first, followed by billing DHCS for the PPS rate wrap payment. Note that the services are billed using the appropriate billing code set.

Please refer to the Federally Qualified Health Centers/Rural Health Clinics Provider Manuals for additional billing guidelines.