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Authors Posts by Jim Sharp

Jim Sharp

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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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The Office of Mental Health and Substance Abuse Services (OMHSAS) is working on developing Regulatory Compliance Guides (RCG) for each licensed level of care to support their commitment to quality in licensing. The RCG is a tool for providers, OMHSAS staff, and the public to better understand the regulations.

This Regulatory Compliance Guide is a companion piece to 55 Pa. Code Chapter 5200. 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 Chapter 5200.

OMHSAS issued the first version of the Psychiatric Outpatient Clinic RCG in November 2021. Today, they are reissuing an updated Psychiatric Outpatient Clinic RCG. The changes made were primarily to language and updates based on comments received on the original document.

Feedback or questions on the RCG can be sent electronically.

If you have any questions, please contact RCPA COO Jim Sharp.

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The Center for Medicare and Medicaid Services (CMS) has released the Physician Fee Schedule CY 2025 Final Rule. You can view CMS’ press release, fact sheet, and final rule page in the Federal Register for more information. There were critical areas addressed in this year’s Physician Fee Schedule (PFS), including:

  • The extension of some telehealth flexibilities permitted under CMS’ authority absent Congressional action;
  • Updated payment for social determinants of health risk assessments as a part of Opioid Use Disorder intake activities furnished at Opioid Treatment Programs (OTP);
  • The establishment of a new add-on code to account for coordinated care, referral services, and peer supports at OTPs;
  • Payment for safety planning intervention and post-discharge follow-up;
  • The establishment of six G codes that mirror current interprofessional consultation Common Procedural Terminology codes used by practitioners who are eligible to bill E/M visits; and
  • Recognition of responses to CMS’ request for information on Certified Community Behavioral Health Clinics.

For the OPPS Final Rule, please see links to CMS’ press release, fact sheet, and final rule page in the Federal Register. Some highlights from this final rule include:

  • The maintenance of the Partial Hospitalization Program and Intensive Outpatient Program rate structures;
  • Narrowing the definition of “custody” in Medicare’s payment exclusion rule to mitigate barriers to Medicare access by individuals who have recently been released from incarceration or are on parole, probation, or home detention; and
  • Changes to Medicaid regulation, allowing states implementing the Medicaid clinic services benefit to cover clinic services outside the “four walls” of behavioral health clinics.

If you have any further questions regarding these final rulings or the application of the “four walls” impacts on Pennsylvania, please contact RCPA COO and Mental Health Director Jim Sharp.

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Image by DarkmoonArt_de from Pixabay

The Office of Mental Health and Substance Abuse Services (OMHSAS) has announced the 2025 quarterly meeting dates for next year’s OMHSAS Stakeholder Webinars and asks that you mark your calendars.

2025 OMHSAS STAKEHOLDER WEBINAR DATES:

  • January 30, 2025 — 3:00 pm – 4:00 pm
  • April 24, 2025 — 3:00 pm – 4:00 pm
  • July 17, 2025 — 3:00 pm – 4:00 pm
  • October 23, 2025 — 3:00 pm – 4:00 pm

In the meantime, if you have suggestions for agenda topics for January’s webinar, please submit them via email. We will monitor the account and will only reply to the sender if more information is needed. Responses will not be provided if additional information is not needed.

Please note that webinar links will be provided closer to each of the meeting dates as shown above.

Thank you for your review and please – SAVE THE DATE.

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

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On Friday, November 1, the Centers for Medicare & Medicaid Services (CMS) released an anticipated Final Rule titled “CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS 1809-FC),” which includes three new exceptions for the federal “four walls” rule. At present, the “four walls” rule prohibits Medicaid payment for clinic services when both the practitioner and individual receiving service are outside of the “four walls” of the clinic unless the services are being provided to unhoused individuals (such as through street medicine). The new exception for Indian Health Services and Tribal Facilities is required nationally. The exceptions for Behavioral Health Clinics and Rural clinics are optional. States who determine that their Behavioral Health Clinic and/or Rural Health Clinic populations served meet the four criteria established by CMS (see page 1323 of the final rule) must submit a Medicaid State Plan Amendment (SPA) and receive approval from CMS for these exceptions to be in place for their state.

The Office of Mental Health and Substance Abuse Services (OMHSAS) had been working toward a short-term state level solution to the four walls issue for both Outpatient Psychiatric Clinics and Drug and Alcohol Clinics. However, now that a long-term federal option has been made available, the team in OMHSAS will be pivoting to pursue this newly available federal exception for Behavioral Health Clinics. While OMHSAS is still in the process of developing a timeline for the new State Plan Amendment, their team will be working on this as a top priority, with the goal of having a SPA in place in early 2025.

It has been confirmed that OMHSAS will not be shifting their current enforcement policy around the four walls while they work through getting this waiver in place. RCPA will continue its collaboration with OMHSAS on the process as this move forwards. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

For additional information, please see the following:

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Removes Barriers to Delivering Telehealth Outside the Clinics

On Friday, November 1, the US Centers for Medicare and Medicaid Services (CMS) released a final rule for calendar year 2025 that will give states the option to cover Medicaid telehealth behavioral health clinic services delivered outside the “four walls.” Previously, under 42 CFR § 440.90, the “Four Walls Rule,” it was required that during Medicaid outpatient behavioral health clinic telehealth services, either the patient or the clinician had to be physically onsite at the clinic.

CMS waived this requirement during the Public Health Emergency (PHE). Now that the PHE has ended, CMS has released this final rule to allow states to cover behavioral health outpatient clinic services outside the four walls. The final rule should take effect on January 1, 2025. In the meantime, it is the expectation that telehealth services will continue to be delivered as per current operating standards to ensure service access to individuals.

CMS amended the Medicaid clinic services’ regulation to authorize Medicaid coverage for clinic services furnished by IHS/Tribal clinics outside the “four walls” of their facility. In addition, states implementing the Medicaid clinic services’ benefit can opt to cover clinic services furnished outside the “four walls” of behavioral health clinics or clinics located in rural areas. For clinics located in rural areas, based on comments received, CMS is finalizing an approach to defining “rural area” where states will select either a definition used by a federal agency for programmatic purposes, or a definition adopted by a state agency with a role in setting state rural health policy.

For more information, view the CY 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Final Rule (CMS 1809-FC) Fact Sheet and the full Final Rule.

RCPA will be reviewing the implications of this final form ruling for Pennsylvania and our ongoing efforts to expand telehealth services through legislative action. RCPA offers thanks to our members, as well as DHS/OMHSAS, County Primary Contractors, BH-MCOs, the National Council on Mental Wellbeing, and our stakeholder groups and associations for their collaborative advocacy to remove the “4 Walls” barriers to equity and access through telehealth.

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

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