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Authors Posts by Jim Sharp

Jim Sharp

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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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The Office of Mental Health and Substance Abuse Services (OMHSAS) recently sent out information to County Mental Health Administrators to alert each of them to an upcoming funding opportunity. This funding supports OMHSAS’s efforts to equip the ICWCs for alignment with the Certified Community Behavioral Health Clinics (CCBHC) model, which includes providing robust crisis services. Additional information regarding the OMHSAS plan for the expansion of the ICWC model is forthcoming, but clinics should still take advantage of this potential opportunity. The ICWCs are encouraged to contact their county representatives to express interest in participating in the start-up project for walk-in crisis services.

An informational meeting for County Partners will be held on Wednesday, October 23, 2024. Please do not submit any applications to OMHSAS, as the application must come from the County Partner(s) in order to be considered.

If you have any further questions, please reach out to your County Partner. Please see below for the information that was shared.

Upcoming Funding Opportunity: Emergency Behavioral Health Crisis Walk-In Centers (EBHC Walk-In Centers)

OMHSAS is excited to announce a new funding opportunity for County Mental Health Administrators aimed at supporting the establishment of Emergency Behavioral Health Crisis Walk-In Centers (EBHC Walk-In Centers). This opportunity offers up to five grants, with a total funding request of up to $3 million per project. Each grant will consist of a blend of $1 million in state funds and $2 million from the federal Community Mental Health Services Block Grant (CMHSBG).

Funding Breakdown:

  • State Funding: Can be used for infrastructure, purchasing property, construction, and/or service provision.
  • Federal CMHSBG Funding: Limited to services for individuals with Serious Mental Illness (SMI)/Serious Emotional Disturbance (SED), provider training, and rent/utilities.

Key:

  • New Walk-In Centers in Rural Areas: Particularly those formed through multi-county partnerships, beyond joinder counties.
  • Applicants that have not previously received CMHSBG funding for crisis start-up projects will be prioritized.

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

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The Pennsylvania State Interagency Coordinating Council (SICC) is seeking interested family members, caregivers, and professionals to serve on ad hoc subcommittees. The PA SICC is a Governor-appointed council that advises and assists the Departments of Health, Education, and Human Services to ensure that a comprehensive delivery system of integrated Early Intervention programs and services is available to all eligible infants, toddlers, and young children as well as their families.

Individuals are needed to serve on one or more of the following committees:

  • Mental health committee;
  • Workforce development committee;
  • Outreach and communication committee; and
  • Access and inclusion committee.

The deadline to apply is Monday, October 28. All applicants will be notified about the decision of their application by early January via email.

Please share this information with professionals and families within your network. For more information about the committees and to apply, view the application here. Please send any questions electronically.

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Image by Dirk Wouters from Pixabay

The Office of Mental Health and Substance Abuse Services (OMHSAS) has submitted to the Pennsylvania Independent Regulatory Review Commission (IRRC) IRRC No. 3417 — Psychiatric Residential Treatment Facilities (14-555) regulations for the first phase of the promulgation process.

At this time, the regulations will be open for the submission of public comments from November 2, 2024, to December 1, 2024. The IRRC will review these comments and work with OMHSAS on developing responses as well as any potential language changes.

This process for regulation development with stakeholders began in 2019, and RCPA and its members have been active partners with the OMHSAS Children’s Bureau in the ongoing process through forums and work group meetings. The RCPA Residential Services Work Group completed a cursory review of a PRFT regulation presentation by OMHSAS in July and will begin working on developing a full response to the regulations.

RCPA will be connecting with these members this week to schedule the PRTF Regulatory Review Team that will support our recommendations to the current draft. If any member is interested in participating in the review group, please contact RCPA COO and MH Director Jim Sharp.

The regulations can be view at the links below.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) October 2024 Stakeholder Webinar is currently scheduled for Thursday, October 17 from 3:00 pm – 4:00 pm.

Use this link to register for the webinar. After registering, you will receive a confirmation email containing information about joining the webinar.

For those that want to join via phone:
Call-in Number: 914-614-3221
Access Code: 854-614-804

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

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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:

[email protected]

Central Region:

[email protected]

Counties: Dauphin, Cumberland,

Lancaster, York, Adams, Lebanon and York

[email protected]

Counties: Snyder, Perry, Juniata, Centre, Mifflin, Tioga, Lycoming, Northumberland, Union and Clinton

South Region:

[email protected]
Western Region:

[email protected]

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

[email protected]

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.

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