RCPA submitted a letter of support to OMHSAS Deputy Secretary Jennifer Smith on October 1, to advocate for re-entry into the SAMHSA CCBHC Demonstration project, on behalf of all Integrated Care and Wellness Clinic (ICWC) providers in the commonwealth. We believe this action would further support the state’s vision of quality integrated whole-person care. Read the letter here.
Providers who hold a license to operate a facility licensed by the Pennsylvania Department of Human Services (DHS) are being notified of a change to the Civil Rights Compliance process. There is a new Civil Rights Compliance form when submitting a new licensing application as well as a new Civil Rights Compliance Renewal form when submitting a licensing renewal application.
Entities seeking a new license will utilize a Civil Rights Compliance (CRC) form (HS2126). The prior Civil Rights Compliance (CRC) form is now obsolete and will be returned back to providers. This form must be included in the packet submitted as part of any new license request. The new application, supporting documents, and CRC form must be emailed to the DHS office that issues your license; the email address can be found in the chart below.
Entities licensed by OCDEL or ODP who use CLS or PELICAN to submit new applications must submit the form by email. The CRC forms are not part of the electronic CLS/PELICAN new application process. The updated CRC form for new applications can be found on the DHS website under the “Application for License” page.
For licensing renewals, a licensee will now submit a CRC Renewal form (HS 2125). The prior Attestation form is now obsolete and will be returned back to providers. The renewal form must be submitted as part of a renewal licensing application, and the renewal notice will still be sent out 130 days prior to expiration. The renewal application must be emailed to the DHS office that issues your license; the email address can be found in the chart below.
Entities licensed by OCDEL or ODP who use CLS or PELICAN to submit renewal applications must submit the renewal by email. The renewal is not part of the electronic CLS/PELICAN renewal application process. The CRC form for can be found on the DHS website under the “Application for License” page.
Previously, the DHS Bureau of Equal Opportunity (BEO) would issue you a letter verifying that you are compliant with applicable civil rights laws. With the new process, a letter from BEO will no longer be sent out to licensed entities. Instead, the issuance of the new license or renewal license will indicate that your CRC form or renewal form submission was approved. If there are issues or questions on the submitted CRC or renewal form, a staff member from BEO or DHS will contact you.
| If your license is issued by… | Submit your application AND your CRC form (if new license) or CRC Renewal (if license renewal) to: |
| The Bureau of Human Services Licensing (Renewals) – PCH & ALR | [email protected] |
| For NEW applications for Personal Care Homes or Assisted Living Residences | Send the application, supporting documents, Civil Rights Compliance Form (HS2126) and the application fee, check or money order payable to DHS to:
Via USPS: Or via courier: DHS/BHSL DHS/BHSL Room 623 Health & Human Services Bldg. PO Box 2675 Rm 623 Harrisburg, PA 17105-2675 625 Forster Street Harrisburg, PA 17120 |
| The Office of Children, Youth, and Families | [email protected] |
| The Office of Mental Health and Substance Abuse Services | [email protected] |
| The Office of Developmental Programs* | [email protected] |
| The Office of Child Development and Early Learning* | Child care providers should include their MPI number in the subject line and email the appropriate regional office:
Northeast Region: Central Region: Counties: Dauphin, Cumberland, Lancaster, York, Adams, Lebanon and York Counties: Snyder, Perry, Juniata, Centre, Mifflin, Tioga, Lycoming, Northumberland, Union and Clinton South Region: |
| Western Region:
Counties: Allegheny, Armstrong, Beaver, Butler, Cameron, Clarion, Clearfield, Crawford, Elk, Erie, Fayette, Forest, Greene, Indiana, Jefferson, Lawrence, McKean, Mercer, Potter, Venango, Warren, Washington and Westmoreland Counties: Bedford, Blair, Cambria, Franklin, Fulton, Huntingdon and Somerset |
*Licensees who use CLS or PELICAN to submit renewal applications must submit the renewal by email. The renewal is not part of the electronic CLS/PELICAN renewal application process.
The new process is effective on Tuesday, October 1, 2024. Existing licensees and applicants must begin following the new process on or before that date.
If you have any questions about the new process, please contact the applicable DHS office, DHS Human Services Licensing Office at 717-705-0383, or, if your facility is a childcare facility, please reach the Office of Development and Early Learning (OCDEL) at Western Region 1-800-222-2149, Central Region (Harrisburg) at 1-800-222-2117, Northeast Region (Scranton) at 1-800-222-2108, or Southeast Region (North & South) at 1-800-346-2929.
If you have any questions or need assistance with the completion of your civil rights compliance application, please contact Bureau of Equal Opportunity Licensing office at 717-787-1579 or electronically.
Thank you for your commitment to protecting the rights of Pennsylvania’s most vulnerable citizens. If you have any additional questions, please contact your respective RCPA Policy Director.
The Pennsylvania Independent Regulatory Review Commission (IRRC) has completed their review of existing Intensive Behavioral Health Services (IBHS) regulations codified at 55PA. Code chapters 1155 and 5240, as requested by the RCPA IBHS Steering Committee.
The RCPA IBHS Regulatory Reform Recommendations, submitted on November 29, 2022, requested the commission to review the IBHS regulations under section 8.1 of the Regulatory Review Act, which provides that the commission may review any existing regulation which has been an effect for at least three years.
The commission has noted the burden placed on providers by the Department of Human Services regulation, but while they appreciated our concerns, the commission’s role is to determine whether existing regulations, as a whole, remain in the public interest. In the commission review letter, they determined that further action by the commission is not warranted in this matter.
We have been in contact with OMHSAS throughout this two-year period, and the commission provided the department with guidance as part of the review process. Despite the ruling from the IRRC, OMHSAS has agreed that they will reopen the IBHS for review as announced by OMHSAS Deputy Secretary Jennifer Smith at the RCPA Conference last week. RCPA will be reviewing the recommendations to calibrate those areas that continue to create barriers to access that have arisen since the recommendations created in the Fall of 2022.
If you have any questions, please contact RCPA COO and Policy Director Jim Sharp.
The process to route cell phone calls to the 988 Suicide & Crisis Lifeline based on the caller’s approximate location, versus by area code, has started; FCC to vote next month on a final rule that would require all U.S. wireless carriers to implement geo-routing with specific timelines
The 988 Suicide & Crisis Lifeline announced that the process to start routing cellular phone calls to 988 contact centers based on the caller’s approximate location, versus by area code — known as “geo-routing” — began last week with two major U.S. wireless carriers that combined make up about half of all wireless calls to 988. The U.S. Department of Health and Human Services’ (HHS) Substance Abuse and Mental Health Services Administration (SAMHSA) and the 988 Network Administrator, Vibrant Emotional Health, have been working with all of the major U.S. cell phone carriers for more than a year to improve call routing to 988 so that callers on a cell phone can be connected more locally to centers that are better equipped to provide nearby resources and services.
These new rules, if adopted by a vote from the full commission next month, would require all U.S. wireless carriers to implement geo-routing. In addition, the rules will also establish an implementation timeline for geo-routing calls to the 988 Lifeline of 30 days following the effective date of the rule for nationwide wireless providers and 24 months after the effective date of the rule for smaller, non-nationwide providers.
More than 200 contact centers across the country provide support through the 988 Lifeline network. Geo-routing connects cell phone callers to the closest 988 contact center to the caller’s physical location. Geo-routing differs from geolocation in that it does not provide a precise location of the caller, allowing callers to maintain their location privacy. Studies have shown that after speaking with a trained crisis counselor, most callers feel more hopeful and less depressed, suicidal, and overwhelmed.
If you have additional questions, please contact RCPA COO and Mental Health Director Jim Sharp.
The Collaborative Family Healthcare Association (CFHA) and the Value-Based Care Work Group have created a value-based survey that is being distributed across the US to seek insights into the current state of value-based care, identify existing gaps, and explore opportunities for better alignment between payment models and clinical practice.
The target audience includes health systems, quality and administration professionals, primary and specialist care providers, and funding sources such as payers, policymakers, foundations, and grants.
The results of the 5-minute survey, which you can view here, will be shared with members as accompanying review is completed. If you have any questions, please contact RCPA COO and MH Policy Director Jim Sharp.
The Pennsylvania Department of Human Services (DHS) Office of Mental Health and Substance Abuse Services (OMHSAS) will be holding quarterly public meetings for anyone interested in discussing the topic of peer support services (PSS) working in the mental health realm. These meetings will provide a regularly scheduled opportunity for OMHSAS representatives to give PSS updates and information as well as answer questions and obtain essential insight and feedback from stakeholders.
The first quarterly meeting will be held on October 8, 2024, at 9:00 am – 10:00 am. The TEAMS meeting link is available here. Going forward, these meetings will be held on the second Tuesday in the months of January, April, July, and October 2025. Attendees will receive general updates and discussion topics OMHSAS will send ahead of time. Meeting links will also be provided in advance of each meeting.
Recommendations for agenda topics or questions can be submitted via email and must be submitted at least two weeks prior to the meeting date. The email account will be monitored, and the sender will receive a reply if more information is needed. Responses will not be provided if additional information is not needed.
If you or your colleagues would like to be added to an OMHSAS Listserv to receive the quarterly invitations, please go to the Listserv DHS website, then select the “join or leave the list” link.
Meeting Dates:
OMHSAS is open to ideas and suggestions on maximizing the effectiveness of these meetings.
These quarterly meetings are not a replacement for the Mental Health Planning Council quarterly meetings. Those meetings will continue in addition to these newly established meetings.
OMHSAS appreciates your review and hope you will join them for these PSS discussions. Questions pertaining to these meetings should be submitted via email.
Legislation for Telehealth Flexibilities Introduced:
HB 2560 To Address Psychiatry Time Requirements and “4 Walls”
RCPA is pleased to announce that yesterday, September 10, State Representative Tina Pickett (R-District 10) introduced House Bill 2560, which was referred to the House Health and Human Services Committee. The legislation is focused on addressing two critical telehealth considerations, including an update of the outpatient psychiatric outpatient time requirements and the Federal Medicaid payment standard known as the “4 Walls.” The latter would abrogate DHS 55 Pa. Code § 1153.52 Payment Conditions for Various Services and 55 Pa. Code § 5200.52 Treatment Planning. By addressing the “4 Walls” requirement, telehealth services by a practitioner can be delivered outside the physical outpatient clinics and will be categorized under licensed mobile mental health services.
On a parallel track, the Center for Medicare and Medicaid Services (CMS) has proposed a final rule exception that would eliminate the “4 Walls” requirements among several other actions. On September 9, 2024, RCPA submitted comments regarding the Medicaid Clinic Services 4 Walls Exceptions on behalf of our membership in support of the proposed exception to eliminate this Medicaid standard.
Additionally, the bill requires that providers who want to deliver telehealth services 100% must maintain a written agreement with a geographically proximate outpatient psychiatric clinic that operates a physical facility and provides in-person services at the outpatient psychiatric clinic within 40 miles or 60 minutes travel from the residence of the individual receiving services AND that the written agreement must include a provision that a referred individual must be seen by the geographically proximate outpatient psychiatric clinic within 10 days of the referral.
Finally, the bill addresses the required 50% psychiatric in-clinic time requirements of 55 Pa. Code Chapter 5200 for Psychiatric Outpatient Clinics. The proposed legislation outlines that required psychiatric time may be provided in person or by the use of telebehavioral health technology by psychiatrists, as specified by department regulations. Advanced practice professionals may also provide a portion of the psychiatric time, as specified by department regulations, either in person or by the use of telebehavioral health. Onsite supervision requirements can be performed by either a psychiatrist or an advanced practice professional. Lastly, the legislation permits DHS to issue waivers to fully remote providers so they can serve patients covered by private insurance.
The introduction of the bill represents a unified effort with OMHSAS, our partners in the Pennsylvania General Assembly, and stakeholders across the Commonwealth to enhance our system’s capacity to deliver services to those most in need. We ask that you join us in working with your legislators to pass this critical legislation.
RCPA will continue to update members as the legislation advances. If you have any questions, please contact RCPA COO and Mental Health Director Jim Sharp.
An excerpt from Pennsylvania’s Suicide Prevention Month Guide Start the Conversation:
September is Suicide Prevention Month, with the week of September 8–14 identified as National Suicide Prevention Week. September 10 is recognized as World Suicide Prevention Day in countries around the world. This year marks the beginning of a new three-year theme focused on changing the narrative on suicide, which involves moving beyond awareness to starting conversations and taking action. Across sectors and settings, changing the narrative requires both culture and systemic change to provide meaningful education, advocate for resources, and prioritize suicide prevention in an ongoing way.
Read the Start the Conversation guide to learn how to speak with others about suicide prevention as well as gain access to toolkits and resources.
The Rehabilitation and Community Providers Association (RCPA), in conjunction with our provider members and partner stakeholders, have written to PA Senator Casey and PA Senator Fetterman to express our full support for ensuring the mandated inflationary increases are preserved for the Pennsylvania Office of Vocational Rehabilitation (OVR) so that critical OVR employment programs will continue for working and job-seeking Pennsylvanians with disabilities. Vocational rehabilitation funding is essential in Pennsylvania to maintain services that support the advancement of employment. We are fortunate that our state legislature has consistently funded Pennsylvania OVR in a manner that has allowed OVR to collect the full federal match and even draw down more when there is a surplus.
If the mandated inflationary increases are rescinded, Pennsylvania’s OVR funding will be cut by millions of dollars, adversely impacting working and job-seeking Pennsylvanians with disabilities. Specifically, approximately $13M would be eliminated from a limited $200M budget, or 6.5%. The resources provided to PA OVR are too valuable and already limited. This potential action forces Pennsylvania to prioritize allocations at the expense of critical employment and related services. Maintaining funding levels is crucial for advancing employment for individuals with disabilities.
Should you have any questions, please feel free to contact Intellectual/Developmental Disabilities Division Director Carol Ferenz or IDD Policy Analyst Cathy Barrick.
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