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Authors Posts by Jim Sharp

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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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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