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Authors Posts by Jim Sharp

Jim Sharp

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the OMHSAS-24-05 Peer Support Services (PSS) Bulletin and PSS Provider Handbook, updating the requirements for Peer Support Services. OMHSAS significantly reorganized the existing language in the Handbook to better clarify which requirements apply to OMHSAS licensure and which apply to Medical Assistance payment. Along with these formatting changes, OMHSAS-24-05 includes the following updates:

  • Staff Qualifications and Requirements for Certified Peer Specialists (CPS)
    • The requirement for a CPS to have a high school diploma or GED has been removed.
    • The requirement for a Serious Mental Illness (SMI) or Serious Emotional Disturbance (SED) has been replaced with a requirement to have a mental health diagnosis. Please note, to be eligible to receive PSS services, there is still a requirement for “the presence or history of an SMI or SED.”
    • The clause requiring CPSs “to attain certification through the PCB within six months of hire” has been removed, as the certification examination is now available on-demand, eliminating the need for a grace period for testing to be completed.
  • Staff Qualifications and Requirements for CPS Supervisors
    • Adding a new qualification category for individuals with an associate degree.
    • Supervisory meetings held in an audio-only format shall not be considered supervision.
    • Supervisory meetings shall be provided at a minimum of one hour each week.
  • Telehealth
    • The prior requirement that only 25% of total services provided per beneficiary per calendar year can be delivered by telephone has been removed.
    • PSS may be provided via telehealth technology, including audio-only service delivery, when it is clinically appropriate to do so.
    • PSS providers must ensure that the preference of individuals receiving services (or their legal guardian) is given a high priority when determining the appropriate service delivery modality.

Please review all other revisions to OMHSAS-24-05 here.

Comments and questions regarding this bulletin should be directed to:
Office of Mental Health and Substance Abuse Services, Bureau of Policy, Planning and Program Development,
P.O. Box 2675,
Harrisburg, PA 17105
General Office Number: 717-772-7900
Email

If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

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Capitol hill building in the morning with colorful cloud , Washington DC.

On December 21, President Biden signed into law the 2025 American Relief Act, a stopgap funding bill passed by Congress on December 20 that funds the federal government through March 14, 2025, and includes over $110 billion for disaster relief.

The bill extends certain Medicare telehealth flexibilities through March 31, 2025, under Section 3207, including the six-month in-person requirement for mental health services, the expanded originating sites, and coverage of audio-only services.

The bill also extends funding for several expiring health care programs through March 31, 2025, including the National Health Service Corps at $85 million and the Teaching Health Center Graduate Medical Education Program at $43 million, both under Section 3101.

In addition, the stopgap bill delays scheduled reductions to the Medicaid Disproportionate Share Hospitals allotments, which are currently set to result in a total reduction of $32 billion between 2025 and 2027. Under Section 3401, the bill delays these cuts through April 1, 2025.

You can read the bill text and a summary of the health care provisions.

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The Department of Human Services (Department) issued bulletin OMHSAS-16-03, “Revised Procedure for Waiver of Office of Mental Health and Substance Abuse Services (OMHSAS) Program Regulations and Standards,” on April 19, 2016, to update and clarify the procedure for submitting and processing of waiver requests to OMHSAS. OMHSAS has issued OMHSAS-24-04 to further update regulatory waiver language and the process to appeal a waiver determination. The issued bulletin can be found here. OMHSAS-16-03 is obsoleted by this bulletin.

OMHSAS licenses or approves community mental health facilities and agencies and other service providers operating in the Commonwealth of Pennsylvania. In accordance with this responsibility, the Department’s authorized agents periodically inspect mental health facilities and agencies. If regulatory requirements are met, certificates of compliance or approvals are granted under Article IX of the Human Services Code (62 P.S. §§ 901 – 922) or under Article X of the Human Services Code (62 P.S. §§ 1001 – 1080).

Pursuant to applicable regulations, a facility or agency may request a time limited waiver of regulations or program standards, or a portion of regulations or program standards. All regulatory waiver requests are subject to applicable waiver of standard requirements as outlined by each chapter or bulletin. In reviewing any such waiver request, OMHSAS will consider whether the facility or agency has demonstrated that substitute measures assure the health, safety, and welfare of all individuals who reside in the facility or who receive services from the agency.

Please contact RCPA COO and Mental Health Policy Director Jim Sharp with any questions.

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Image by Gerd Altmann from Pixabay

RCPA is excited to host a Membership Benefits webinar on Wednesday, January 15, 2025, at 1:00 pm, as an opportunity for members to orient themselves with all that RCPA membership includes. This is not just for new and future members. For current members, there may be benefits associated with our membership that you may not be aware of, including targeted meetings and groups that occur throughout the year.

Registration is required; please register here to attend the webinar. Items we will review include the below and much more:

  • Virtually meet the dedicated RCPA Policy Staff and RCPA lobbyists;
  • Discuss the 2025 Legislative and Administrative priorities;
  • Preview RCPA divisional committee and subcommittee meetings and what they offer;
  • View the RCPA member-only website;
  • Review exclusive yearly educational and networking events; and
  • Understand the value of the National Association memberships included with RCPA membership.

Visit the RCPA member benefits web page for more information, or contact Tieanna Lloyd for benefit details.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) is pleased to release the Partial Hospitalization Regulatory Compliance Guide (RCG). This guide has been developed to provide clear explanations of the regulatory requirements of Title 55 Pa. Code Chapter 5210 “Partial Hospitalization” regulations. It is meant to help agencies providing partial hospitalization services with the goal of ensuring safe environments and effective services to individuals through regulatory compliance, and to help OMHSAS Licensing Representatives protect individuals served by these programs by conducting consistent and comprehensive inspections.

This guide is a companion piece to Title 55 Pa. Code Chapter 5210 regulations. It is intended to be a helpful reference for these regulations. The explanatory material contained in this guide in no way supplants the plain meaning and intent of the regulations set forth in 55 Pa. Code Chapter 5210.

The guide can be accessed here.

Feedback or questions on the RCG can be sent electronically. If you have additional questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

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The Department of Human Services’ Office of Children, Youth and Families (OCYF) is supporting a specialized training effort addressing child abuse recognition and reporting training for residential facilities through a contract with the Pennsylvania Family Support Alliance (PFSA) to provide training child residential staff, their related purchasing entities, and local law enforcement agencies.

Title of Training: Reporting Requirements for Children Served in Residential Care Facilities
Training Hours: 3 Hours 
Format: Live, Virtual
Register for an upcoming Training:

  1. December 17: 12:00 pm – 3:00 pm
  2. December 19: 9:00 am – 12:00 pm
  3. December 20: 9:00 am – 12:00 pm

Training Summary:

This training is for providers and other child-serving entities and clarifies what allegations must be reported to ChildLine as suspected child abuse and/or HCSIS as a reportable incident, as well as further clarifies when an alternative plan of supervision must be put into place. This training also teaches minimal facts interviewing skills to better determine when to make a report and explains how those reports of suspected child abuse are categorized and handled at ChildLine. Lastly, internal follow-up recommendations and communication are discussed. Other entities that interact with these 3800 facilities are also welcome to attend – OCYF Regional Office Reps, Law Enforcement, MCOs, etc.

This training mirrors the information outlined in the OCYF Bulletin # 3800-21-01 issued January 19, 2021, and is an additional training (not a replacement for the mandated reporter training).

Please reach out to COO and Mental Health Policy Director Jim Sharp with any questions.

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The Substance Abuse and Mental Health Services Administration (SAMHSA) is welcoming public comments on the draft SAMHSA Now Accepting Public Comments on Draft Model Behavioral Health Crisis Services Definitions.

SAMHSA developed the draft Model Behavioral Health Crisis Services Definitions document for state, territory, Tribal, and local entities; crisis services providers; public and private payers; regulators; and help seekers and their supporters to clarify and distinguish the different types of crisis services for people across the nation.

Interested people are invited to submit written comments for these draft definitions from Thursday, November 21, 2024, through Thursday, December 5, 2024, at 11:59 pm ET.

For more information on the definitions and to submit comments, please visit the Model Behavioral Health Crisis Services Definitions web page on the Crisis Systems Response Training and Technical Assistance Center website at the link below.

Read More Here

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The Drug Enforcement Administration (DEA), in concert with the Department of Health and Human Services (HHS), has issued a third extension of telemedicine flexibilities for the prescribing of controlled medications, through December 31, 2025.

In 2023, in response to a set of proposed telemedicine rules, DEA received more than 38,000 comments and held two days of public listening sessions. In light of that feedback and discussion, and to give DEA time to consider a new path forward for telemedicine, DEA and HHS extended current telemedicine flexibilities through the end of 2024.

DEA and HHS continue to carefully consider the input received and are working to promulgate a final set of telemedicine regulations. However, with the end of 2024 quickly approaching, DEA, jointly with HHS, has extended current telemedicine flexibilities through December 31, 2025. RCPA has remained active in our advocacy to make permanent the telehealth flexibility across the behavioral health landscape both federally and in Pennsylvania. Please follow this link to view the ruling.

If you have additional questions, please contact RCPA SUD Treatment Services Director Jason Snyder or COO / Mental Health Services Director Jim Sharp.

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