Australian Association of Social Workers
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1 Australian Association of Social Workers Submission to Medicare Australia and Minister for Mental Health and Ageing to review MBS Schedule Fees for Social Workers under the Better Access initiative AASW CONTACT: Professor Bob Lonne AASW National President Peter Badenhorst Chief Operating Officer Phone: September 2011
2 Table of Contents Executive Summary Summary of recommendations Proposal Background Social Work Practice standards and Tertiary Qualifications Accountability Accredited Mental Health Social Workers Years of experience and ongoing professional development Services provided Client profile Client outcomes Billing arrangements Activities outside scheduled sessions Accessing mental health services for the first time Issues arising from two tiered fee schedule Recommendations Conclusion Summary table for Accredited Mental Health Social Workers Appendix: Financial Implications of Minor Changes to Rebates Page 2 of 14
3 Executive Summary The Australian Association of Social Workers (AASW) submits this proposal to the Australian Government and Medicare Australia to review and increase the MBS Schedule Fees for MBS Item numbers pertaining to accredited mental health social workers providing services under the Better Access Initiative. The proposal puts forward that these Schedule Fees should be, at a minimum, in parity with those for Registered Psychologists providing identical services under this initiative. On 1 November 2006, the Better Access Initiative was introduced allowing appropriately trained social workers to receive referrals from General Practitioners, Psychiatrists and Paediatricians for patients, diagnosed with a Mental Disorder, for the provision of Focused Psychological Strategies. Social workers, like psychologists and occupational therapists, provide identical services to these patients under the Better Access Initiative. At that time, and subsequently, there has been no consultation with the AASW on the setting or review of the MBS schedule fees and rebates. Despite considerable feedback from the AASW and individual members through the various components of the evaluation of the Better Access initiative during , changes to MBS Fees were not addressed. The Medicare Benefits Schedule Item Descriptor is exactly the same for each of the three professions providing Focused Psychological Strategies. Some of the implications for social workers include the following: Confusion for referrers and clients Lack of recognition of the level of education and training, years of direct practice experience and skill demonstrated by accredited mental health social workers Lower level tier does not adequately reflect the professional or practice components of providing a service A smaller proportion of clients being bulk billed, than would normally occur because of social work commitment to social justice, because of the lower level of rebate Limited choice of clinicians / discrimination against social workers This submission has argued that accredited mental health social workers working under Better Access are skilled practitioners providing focussed psychological interventions to clients in line with the aims and structure of the Better Access program. It is clear that the education and training, skills and knowledge, accountability requirements, and ethical framework for practice, are at least as rigorous as that of registered psychologists. The therapeutic activity of social workers as defined in the Medicare items is identical to that of registered psychologists. Our research suggests that social workers are also providing additional services to clients beyond the requirements of the Medicare items. Our argument is that the Medicare payment schedule should be the same for social workers and registered psychologists. Page 3 of 14
4 Summary of Recommendations In acknowledgement of the new quality framework being established for the Medicare Benefits Schedule, the AASW requests that the two tiered rebate system for providers of Focused Psychological Strategies under the Better Access Initiative be reviewed to better reflect an improved schedule fee setting process, in line with recognition that fees need to meet ongoing needs of clinicians and facilitate the provision of safe, high quality services for the public. In order to remove the unreasonable and illogical inequities the following is required: 1. Removal of the original fee structure that cemented inequities 2. Acknowledgement and recognition of the highly skilled and experienced accredited mental health social work workforce registered with Medicare Australia 3. Acknowledgement of the additional non remunerated services provided by accredited mental health social workers as responding to the degree of complexity of clients referred and contributing to high quality services and improved outcomes to their clients, and 4. At a minimum, set new fee structures in parity with registered psychologists working in the Better Access Initiative [see Appendix 2 - a number of options to achieve equal rebates with no additional cost to Government or consumers] Page 4 of 14
5 1. Proposal The Australian Association of Social Workers (AASW) submits this proposal to the Australian Government and Medicare Australia to review and increase the MBS Schedule Fees for MBS Item numbers pertaining to accredited mental health social workers providing services under the Better Access Initiative. The proposal puts forward that these Schedule Fees should be, at a minimum, in parity with those for Registered Psychologists providing identical services under this initiative. The fees applicable to social work and registered psychologists are: Item descriptor Provision of Focused Psychological Strategies Provision of Focused Psychological Strategies Provision of Focused Psychological Strategies Provision of Focused Psychological Strategies Provision of Focused Psychological Strategies in a group setting Item no Social Work Schedule Fee Social Work Rebate Social Work Item no Reg d Psych Schedule Fee Reg d Psych Rebate Reg d Psych $59.50 $ $68.00 $ $84.35 $ $92.50 $ $84.60 $ $96.00 $ $ $ $ $ $21.50 per group member $ $24.50 per group member $20.85 A number of options are submitted, to achieve equity of rebates, with no additional cost to the Government and consumers (see Appendix 2). 2. Background On 1 November 2006, the Better Access Initiative was introduced allowing appropriately trained social workers to receive referrals from General Practitioners, Psychiatrists and Paediatricians for patients, diagnosed with a Mental Disorder, for the provision of Focused Psychological Strategies. Social workers, like psychologists and occupational therapists, provide identical services to these patients under the Better Access Initiative. At that time, and subsequently, there has been no consultation with the AASW on the setting or review of the MBS schedule fees and rebates. Page 5 of 14
6 Despite considerable feedback from the AASW and individual members through the various components of the evaluation of the Better Access initiative during , changes to MBS Fees were not addressed. In the Final Report of the Better Access Evaluation undertaken by Melbourne University 1 the authors identified that in looking at the respective roles of social workers, occupational therapists and psychologists and whether they are the same or different there should also be consideration of the relative levels of reimbursement for their services. 3. Social Work Practice Standards and Tertiary Qualifications The AASW is the professional body representing qualified social workers in Australia. The AASW sets the national standards for the social work profession, is the accrediting body for Social Work education and is the designated assessing authority for social work recognition on behalf of the Department of Education, Employment and Workplace Relations. The AASW is also the assessor, on behalf of the Commonwealth Department of Health & Ageing, for accredited mental health social workers registration with Medicare Australia. For sixty years, the AASW has been setting the national standard for social workers, and for forty years, has been the accrediting authority for all university schools of social work in Australia. The AASW standards document Australian Social Work Education & Accreditation Standards (2008) requires that an essential outcome of social work qualifications is that all graduates should be able to work with clients to a high professional standard. This includes being able to assess problems, develop an intervention (known in medical terms as treatment) plan and then provide appropriate individual counselling, couple or group intervention to the client(s). To practice as a professional social worker in Australia, graduates must have completed either a 4 year accredited Bachelor of Social Work degree or a 2 year accredited qualifying Masters of Social Work following a minimum relevant three year undergraduate degree. All social work graduates have completed at least one direct practice field placement of 490 hours, with the equivalent of one hour per 38 hour week in supervision with a qualified professional social worker approved by the university, during their social work course. Many would have completed 980 hours of direct practice experience the field of practice. Social work graduates are employed in a range of clinical settings including child protection, hospitals, mental health settings, sexual assault services, domestic violence services, employee assistance programs and aged care services, where they provide intensive direct practice to clients and their families. Clinical social workers are also expert panel members providing services to Legal Aid, the Federal Magistrates Court and the Attorney General s Department. Services include undertaking complex assessment, providing comprehensive reports and participating as expert witnesses. Not all social work graduates are eligible to provide services under the Better Access program 4. Accountability Membership of the AASW provides clients with a means of redress and complaint, in the event of sub-standard services, unethical practice or other professional conduct issues. This is enabled by a comprehensive ethics complaints management system established by the AASW. 1 Pirkis J, Williamson M, Ftanou M, Machlin A, Warr D, Castan L, Christo J, Harris M Evaluation of the Better Access to Psychiatrists, Psychologists and GPs through the Medicare Benefits Schedule Initiative: Component A.2: A study of consumers and their outcomes (focusing on the occupational therapy and social work sectors) Final Report, p 54 Page 6 of 14
7 As Social Work is not a registered profession, there is no requirement for social workers to be registered with any authority or Board of Registration, however, Accredited Mental Health Social Workers are required to be members of the AASW to be accredited to offer services under Medicare, and are therefore subject to the AASW ethics complaint management process. The requirements to maintain accredited mental health social worker status are comprehensive and comparable to the requirements of registered psychologists. The AASW is well aware that the safety of clients, including all emotional, physical and psychological aspects, is crucial to any service whether government funded or otherwise. In the event of a serious breach of the code of ethics by a social worker, through the complaints management system the social worker could be prohibited from practice. As the clinical competencies for Mental Health Accreditation and the ethical obligations for social work practice are no different from other disciplines providing services under Medicare, remuneration should be the same for all disciplines. 5. Accredited Mental Health Social Workers Accredited Mental Health Social Workers are required to demonstrate their competence to provide services under Better Access. They are members of the AASW who have demonstrated their capacity to meet the skills and knowledge set out in the Practice Standards for Mental Health Social Work (AASW, 2008). As such they are specialist practitioners who possess a distinctive body of knowledge and skill in order to assess, diagnose and ameliorate problems, disorders and conditions that interfere with healthy bio-psychosocial functioning of individuals, couples, families and groups of all ages and background. As at June 2011 there are 1,355 accredited mental health social workers registered with Medicare Australia. Information reported below outlining the profile of Accredited Mental Health Social Workers and their Clients has been collated from two surveys conducted in 2010 by the AASW Years of experience and ongoing professional development All accredited mental health social workers are qualified social workers with at least two years of clinical experience working in mental health or related program under professional social work supervision. Accredited mental health social workers are highly qualified and skilled direct practice professionals. A survey conducted by the AASW, in 2010, showed that nearly 50% of mental health social workers in private practice have over 20 years of experience and with approximately 80% having over 10 years experience. All accredited mental health social workers must participate in the AASW Continuing Professional Development (CPD) program. They are required to accrue and submit evidence of 30 CPD points (equivalent to 30 hours) specifically relevant to mental health annually. These points must be gained through participating in activities for skill development and gaining new knowledge categories. Mental health relevant activities must contribute to their 2 AASW Mental Health Social Work Continuing Professional Development Project Report prepared by Jennifer Martin June 2010 AASW Accredited Mental Health Social Workers Data Mining Survey conducted August 2010 by AASW Page 7 of 14
8 learning and practice in working with clients and assist them to meet the AASW Practice Standards for Mental Health Social Workers (2008) Approximately 60% of social workers, who participated in the AASW 2010 survey, have undertaken postgraduate education and training to enhance their knowledge and skills in mental health. 5.2 Services Provided Just over half of respondents to the 2010 AASW survey reported that Medicare funded activities comprised over 50% of their workload. In addition to Medicare related activity respondents provided services in a range of other programs including Employee Assistance, Access to Allied Psychological Services (ATAPS), Department of Veterans Affairs/VVCS, Victims of Crime, Work Cover, Family Court and Motor Vehicle Accident Commissions. Non-Medicare funded work was primarily directed towards private clients and providing professional supervision, education, training and consultancy. Accredited mental health social workers are skilled to undertake a comprehensive bio-psychosocial assessment/formulation, including assessment of risk and to provide evidence based treatment appropriate for mental health disorders. Cognitive Behaviour Therapy and Interpersonal Therapy being the most utilised followed by Psycho-education and Relaxation Strategies and Skills Training. Social workers working with Aboriginal and Torres Strait islander people commonly utilise a Narrative Therapeutic approach Client Profile In a survey conducted in August 2010 with accredited mental health social workers working in private practice: the majority of clients seen by providers were aged years (43%) then years (28%) with children and young people (up to 24 years) making up approximately 25% of the client group. Only 4% if clients were aged 65 years or more. Two thirds were female. The majority of clients (53%) were identified as being single (32%), living on their own following a death of a partner (3%) or separated from their partner (18%). Approximately 41% were identified as being partnered. The most frequent primary diagnosis on referral, in order of prevalence, was Depression, Anxiety, co-occuring Depression and Anxiety, Grief & Loss, Posttraumatic Stress, Adjustment and Substance Abuse. Referrers often identified other reasons for referral. The most common of these was relationship difficulties and stress, with other reasons including behavioural problems, sleep difficulties, family violence, parenting issues, self harming behaviours and adjustment to illness. The vast majority of clients presented with 1-6 referral reasons, with approximately 75% of this group presenting with 1-3 referral reasons. 3 Medicare Benefits Schedule Page 8 of 14
9 In the evaluation of the Better Access program by Melbourne University 4 there were some indication that social workers (and occupational therapists) maybe preferentially being referred consumers who have complex social needs and relationship issues and are suffering financial hardship. 5.4 Client outcomes Some 87% of respondents recorded some or significant improvement with their clients and 11% complete resolution. Increased complexity often resulted in a lesser outcome. Clinicians reported that the changes/improvements made by their clients in the time of their work were: Improved emotional wellbeing (40%) Improved integration with social context (26%) Improved quality of life (26%) Factors influencing more positive outcomes included engagement with the client, early intervention, client adjustment, symptom reduction and support to the client. Factors influencing a less positive outcome included complexity of presentation, unstable social circumstances including accommodation, employment and education and negative experience of previous engagement with helping providers, such as other therapists and counsellors. 5.5 Billing arrangements Over 60% of social work providers bulk bill some or all of their clients. For those social workers charging full fee to the client, the average gap payment was $ The majority of social workers surveyed (78.8%) charged between just over the Medicare Rebate ($76.00) up to $ Activities outside scheduled sessions (non remunerated wrap around services ). According to the Practice Standards for Mental Health Social Workers (2008), social work activity is at multiple levels, thus taking into account not only the individual but also the impact of the social context and social consequences of mental illness. Social work practice occurs at the interface between the individual and the environment. It is concerned with the impact of mental illness and mental health problems on the individual, the family and personal relationships and the broader community including the impact on sense of self, on life chances, on family wellbeing and on economic security, employment and housing. Thus social workers look at the integration of their clients into the broader community as part of interventions provided. The majority of clients (69%) required 1-4 hours of additional time from their therapeutic session to assist with improvement to their situation. For those presenting with 1-3 referral reasons approximately 4 additional hours (non-remunerated) were required. For a small number of extremely complex cases (14%) a significant number of hours was dedicated to wrap around services. Non-remunerated services provided included phone calls with client and/or GP, writing reports, liaison with other agencies such as schools, Centrelink, consultation with colleagues, longer sessions than covered by the rebate. 4 Pirkis J, Williamson M, Ftanou M, Machlin A, Warr D, Castan L, Christo J, Harris M Evaluation of the Better Access to Psychiatrists, Psychologists and GPs through the Medicare Benefits Schedule Initiative: Component A.2: A study of consumers and their outcomes (focusing on the occupational therapy and social work sectors) Final Report, p 54 Page 9 of 14
10 The following case studies are presented in the words of the member who provided them, and we have removed identifying information only. Case Study 1 Presenting Issues: Domestic Violence, Sexual Assault, Depression, Anxiety, generational trauma and Post Traumatic Stress Disorder. Psychosocial issues: Poverty I see a lot of males going into the juvenile justice system (where there s a high suicide risk), behavioural issues. I m asked to be involved in circle interventions. My referrals are not coming in via general practitioners but via the community network. I then send people to the GP for the mental health care plan. Then they re able to come and see me under Medicare. The GP referrals I do receive are for women and adolescents. In the past month I ve received five domestic violence referrals. I do home visits, people often don t have transport or the money for transport. It might be a case of money for transport or buying their medication. Between sessions I call clients, organise things, refer to other services and workers, attend appointments with them. None of this other work is charged for. I bulk bill all my health care card holders, youth, Indigenous clients if money is an issue. If people are working and able to pay I do charge. My appointments are usually longer than the normal 50 minutes. There is a lot of contact with Centrelink, early playgroups, linking people in to parenting courses, refuges, DOCS, health services the doctor, dentist, getting people Medicare cards, drivers license tests, go for walks with clients. I do the motivational interviewing while we re walking. Case Study 2 A man in his 50 s who has attended for approximately three years has a treatment resistant severe depression and anxiety disorder. He has attended a private psychiatrist for approximately one year. A number of treatment interventions including ECT and medication have not been successful and he and his supportive wife, on the advice of his psychiatrist, are now considering early retirement from a demanding administrative position. Transition to retirement inclusive of application for a DSP will be challenging for this man who has strong work values and has the potential for suicidal thoughts and further isolation from the wider community. The role of the social worker will be important in assisting with this transition. Interventions may include therapeutic counseling for the client and his wife as they adjust to retirement and linking him into services in the community where he hopefully may find fulfillment perhaps through volunteering etc. As this client has been suicidal only for a short time in the last three years, he would not have met public mental health eligibility criteria. The psychiatrist or his supportive GP do not have the time or skills to interface with community support services and to provide the therapeutic counseling required. 5.7 Accessing mental health services for the first time under the Better Access initiative Accredited mental health social workers report 5 that since the introduction of the Better Access Initiative they have been able to provide services to people who previously have not been able to afford or access private counselling, such as: People earning low income Clients presenting with complex / multiple problems Specific populations such as males, CALD and the farming community Group work for specific populations and/or disorders 6. Issues arising from two tiered fee schedule for providers of Focused Psychological Strategies The Medicare Benefits Schedule Item Descriptor is exactly the same for each of the three professions providing Focused Psychological Strategies. The AASW has, to date, not been able to ascertain from the Government or Medicare Australia a rational reason for the establishment of a two tiered system. 5 AASW Accredited Mental Health Social Workers Data Mining Survey conducted August 2010 by AASW Page 10 of 14
11 In other Government initiatives under Medicare Australia eg Chronic Disease Management and Non- Directive Pregnancy Support counselling programs, the item descriptors are identical and this is reflected in the schedule fee / rebate. Implications for social workers have been: Confusion for referrers and clients is the lesser rate a reflection of a lesser or different service or a less qualified practitioner? Lower level tier does not recognise or acknowledge the level of education and training, years of direct practice experience and skill demonstrated by accredited mental health social workers o Many accredited mental health social workers reported that they had many years of experience (20-30 years) and were supervising recently graduated psychologists whose clients were able to access high rebates than they themselves. This is outrageously inequitable. Lower level tier does not adequately reflect the professional or practice components of providing a service. For example, the fees set do not reflect: o The hours outside of the session provided by social workers required to deliver a safe, high quality service in order to improve outcomes for their clients o The costs associated with practice rooms and administration o The cost associated with regular supervision and appropriate professional development to maintain and increase practitioners skills. Whilst approximately two thirds of social workers bulk bill all or some of their clients because of their commitment to social justice o A larger proportion of clients would be bulk billed if the rebate was at the higher level. This would result in improved access for clients to a service, particularly those living in regional, rural and remote areas where some 40% of the social work workforce is located. Limitation of choice for some clients / discrimination against social workers o A recent case example reported by a member was that she was asked to work in a GP practice. There was a psychologist already working in the practice. The social worker s fee was appropriately set at the same as the psychologist at $ per session. The gap payment for a client to see the psychologist was $43.40, however for the social worker it was $ A number of clients felt unhappy about the additional cost and requested to see the psychologist instead of the social worker who then made the decision to reduce the session fee to $ so as not to disadvantage clients access to social workers. 7. Recommendations In acknowledgement of the new quality framework being established for the Medicare Benefits Schedule, the AASW requests that the two tiered rebate system for providers of Focused Psychological Strategies under the Better Access Initiative be reviewed to better reflect an improved schedule fee setting process, in line with recognition that fees need to meet ongoing needs of clinicians and facilitate the provision of safe, high quality services for the public. In order to remove the unreasonable and illogical inequities the following is required: Page 11 of 14
12 removal of the original fee structure that cemented inequities acknowledgement and recognition of the highly skilled and experienced accredited mental health social work workforce registered with Medicare Australia acknowledgement of the additional non remunerated services provided by accredited mental health social workers as responding to the degree of complexity of clients referred and contributing to high quality services and improved outcomes to their clients, and at a minimum, set new fee structures in parity with registered psychologists working in the Better Access Initiative [see Appendix 2 - a number of options to achieve equal rebates with no additional cost to Government or consumers] 8. Conclusion This submission has argued that accredited mental health social workers working under Better Access are skilled practitioners providing focussed psychological interventions to clients in line with the aims and structure of the Better Access program. It is clear that the education and training, skills and knowledge, accountability requirements, and ethical framework for practice, are at least as rigorous as that of registered psychologists. The therapeutic activity of social workers as defined in the Medicare items is identical to that of registered psychologists. Our research suggests that social workers are also providing additional services to clients beyond the requirements of the Medicare items. Our argument is that the Medicare payment schedule should be the same for social workers and registered psychologists. Page 12 of 14
13 APPENDIX 1 Accredited Mental Health Social Workers Statement of professional domain. The domain of social work in mental health is that of the social context and social consequences of mental illness. The purpose of practice is to promote recovery, restore individual, family and community wellbeing, to enhance development of each individual s power and control over their lives, and to advance the principles of social justice. Social work practice occurs at the interface between the individual and the environment: social work activity begins with the individual, and extends to the contexts of family, social networks, community and the broader society. Registration/ Accreditation Process Social work is not currently a regulated profession despite a long-standing commitment from the AASW to secure registration of the title. The profession is self-regulating in key areas such as AASW accreditation of professional training programs, code of ethics and management of complaints of breach of ethics by members, statements of professional practice standards, requirements for continuing professional development as part of personal accreditation. Professional Training Program Social workers are qualified either through a 4 years BSW program in an accredited University program, or through a 2 year MSW intensive program building on a relevant Bachelor degree (5 year training). Both programs include 28 weeks of supervised field education. Program Content AASW specifies course requirements. Broad curriculum to prepare graduates for practice in a wide range of health and welfare settings. Schools are required to include specific mental health content in BSW/MSW programs as a condition of program accreditation. Professional Supervision Social workers are not required to undertake formal intern arrangements on graduation but are required to show that they have received at least 2 years of professional supervision as a condition of accredited mental health worker status. Social workers employed in health agencies would typically receive additional professional supervision as part of their conditions of employment. Professional Standards Mental health social workers are required as a condition of accreditation that they demonstrate their capacity to meet the practice standards as set out in Social Work & Mental Health Practice Standards (2008). Social workers in mental health services are required to meet the generic practice standards as set out in the Practice Standards for the Mental Health Workforce. Professional Ethics. Social workers practice according to the ethical guidelines as set out in the AASW Code of Ethics (2010). In the absence of a Registration Board for social work, complaints against social workers are dealt with by the AASW through a nationally managed ethics complaints procedure. Specific Skill Sets Social workers typically have a wide range of skills for mental health practice. For the purposes of the Better Access Initiative, participating social workers are required to have expertise in the Focused Psychological Strategies identified in the Medicare Benefits Schedule. Many social workers, particularly those who have worked in the public mental health system, will have highly developed skills in case management, crisis work, family work, groupwork and community work. Professional Structure. All accredited mental health social workers are members of the AASW. The AASW has recently established a College of Social Work open to social workers with additional academic qualifications, experience and expertise. The first specialist group to be established within the College will be for mental health social workers. It is anticipated that most accredited mental health workers will be eligible to join the College and will do so this year. Page 13 of 14
14 APPENDIX 2 OPTIONS TO ILLUSTRATE FINANCIAL IMPLICATIONS OF MINOR CHANGES TO REBATES FOR PROVIDERS OF FOCUSED PSYCHOLOGICAL STRATEGIES UNDER THE BETTER ACCESS PROGRAM 6 Indicative costs/savings for three options Option 1 Reducing rebate for registered psychologists by $1.00 and applying this rebate to registered psychologist, social work and occupational therapy providers $ Current 50+ minutes $ Proposed 50+ minutes Applying option 1 to ALL item numbers Clinical psychologist Registered psychologist Social worker Savings of $ 151, Occupational therapist Option 2 Reducing rebate for clinical psychologists by $1.00 and rebate for registered psychologists by $0.50 and applying revised rebate for registered psychologist to social work and occupational therapy providers $ Current 50+ minutes $ Proposed 50 + minutes Applying option 2 to ALL item numbers Clinical psychologist Registered psychologist Social worker Savings of $ 8,343, Occupational therapist Option 3 Reducing rebate for clinical psychologists to current rebates for registered psychologists and applying to social work and occupational therapy, so that all professions have the same rebate $ Current 50+ minutes $ Proposed 50+ minutes Clinical psychologist Applying option 3 to ALL item numbers Registered psychologist Social worker Occupational therapist Savings of $ 131,993, Figures are based on current rebates for allied health under the Better Access program for number of services provided during the period January June 2011and then extrapolated to 12 months Page 14 of 14
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