National Council to Host Annual Membership Meeting on December 13
Jim Sharp
SAMHSA Now Accepting Public Comments for Draft Model BH Crisis Services Definitions
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.
DEA Extends Telehealth Prescribing Flexibilities – Ryan Haight Act of 2008
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.
RCPA Member Chestnut Ridge Counseling Services, Inc. Expanding Mental Health Services Throughout Fayette County
National Council to Hold CMS 2025 PFS & OPPS Rule Briefing November 21
OMHSAS Releases Regulatory Compliance Guide as Companion to 55 Pa. Code Chapter 5200
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.
CMS Releases Physician Fee Schedule CY 2025 Final Rule
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.
OMHSAS Announces Stakeholder Webinar Dates for 2025
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.
NEPA Health Care Foundation Announces $1.13 Million Grant for Mental Health Needs, RCPA Members Children’s Service Center and Scranton Counseling Center Featured
OMHSAS Provides Updated Telehealth Guidance on “Four Walls”
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:
- Full Final Rule
- CMS FAQ on the Final Rule
- Email for Questions Regarding OMHSAS Telehealth Policy
