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Authors Posts by Jim Sharp

Jim Sharp

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OMHSAS has released the following Telehealth Regulatory Waiver Request template in order to streamline regulatory waiver requests for the continued delivery of telehealth services following the 9-30-21 end date of statewide regulatory waivers based on the COVID-19 Emergency Declaration.

The waiver submission process will adhere to the revised OMHSAS Waiver Bulletin 16-13.

The waiver will cover deliverable considerations for the following services

  • Mental Health Intensive Case Management 55 Pa. Code § 5221.33(4)(iii)
  • Outpatient Psychiatric Services 55 Pa. Code § 1153.14(1)
  • Outpatient Drug and Alcohol Clinic Services 55 Pa. Code § 1223.14(2)

Each waiver request will remain in place for a 1-year period and will require providers also have documented policies in place for clinical appropriateness and the delivery of telehealth in emergencies. RCPA recommends agencies carefully review each section of the waiver request as they complete their submission.

The waiver will outline the following service considerations:

  • To ensure continuity of telehealth delivery of services by allowing this agency/facility to use audio-only service delivery for Outpatient Psychiatric Services, Outpatient Drug and Alcohol Clinic Services when the individual served does not have access to video capability or for an urgent medical situation.
  • To ensure continuity of telehealth delivery of services by allowing this agency/facility to accept verbal consent/verification for documentation where a signature cannot be obtained when delivering Mental Health Intensive Case Management Services.

Submission Considerations:

  • For all Mental Health Intensive Case Management and Outpatient Psychiatric Clinic Waivers: Please submit all waiver requests to the appropriate OMHSAS Regional Field Office with an attached letter of support from the County MH/ID Administrator where your primary licensed location is at.
  • For all Outpatient Drug and Alcohol Clinic Services Waivers: Please submit here. No letter of support is required for these waivers.

Providers may utilize the following language in your waiver request letter:

Kristen Houser, Deputy Secretary
OMHSAS
Commonwealth Tower, 11th Floor
303 Walnut Street, Harrisburg 17101

Dear Deputy Secretary Houser:

This letter is a request for a waiver of Department of Human Services regulation(s) to continue the delivery of services through telehealth after September 30, 2021, which is the end date of the Governor’s COVID -19 Emergency Disaster Declaration which authorized certain regulatory suspensions.  The details for this request for waiver are included in the form below.  In addition, a letter of support from the County MH/ID Administrator for this request for waiver is attached. (REMOVE if Outpatient D&A Clinic Waiver) 

Your consideration for approval is appreciated. I look forward to your response. If you have any questions or concerns regarding this regulatory waiver request, please contact me at (Phone and e-mail address.)

Sincerely,
(Signature)
(Name)

Members may contact RCPA Policy Director Jim Sharp or their respective Policy Director with questions or feedback.

In the United States, September is acknowledged as Suicide Prevention Month, with the week of September 5–11 identified as National Suicide Prevention Week. Around the world, September 10 is recognized as World Suicide Prevention Day. The goal of annual suicide prevention observances is to provide education and encourage advocacy around this public health challenge toward which prevention efforts can and should occur every single day.

This September, the theme of Suicide Prevention Month is Creating Hope Through Action. As communities here in Pennsylvania, nationwide, and around the world continue to experience the social, economic, and health-related impacts and disparities associated with the COVID-19 pandemic, this theme offers an important opportunity to work together to promote awareness, provide support, and take action to prevent suicide.

Everyone has a role in preventing suicide. In recognizing Suicide Prevention Month, we can work to reduce the stigma around suicide, suicide attempts, and mental health challenges, and we can reinforce the message that help is available. The following guide offers a broad range of suicide prevention resources and strategies for individuals, families, organizations, and communities. The information in this guide can be used during the month of September and throughout the year.

Image by Shotkitimages from Pixabay

This three-hour virtual training is approved by the Departments of Human Services, Education, and State and meets all requirements for training on recognizing and reporting child abuse (to include Act 126 for school employees).

It is also approved for continuing education credits under Act 31 (Department of State for health-related licenses) and Act 48 (Department of Education for teachers) at no cost. PFSA will submit your training verification to the Department of State or Education as appropriate on your behalf (details provided during training).

Please register for your preferred training date and time by clicking one of the session links below. Each person must log in through separate devices, using the unique access link emailed to them after registration to receive credit.

Wednesday, Sept. 1 — 9:00 am–12:00 pm

Wednesday, Sept. 1 — 1:00 pm–4:00 pm

Thursday, Sept. 2 — 9:00 am–12:00 pm

Thursday, Sept. 2 — 1:00 pm–4:00 pm

Thursday, Sept. 2 — 6:00 pm–9:00 pm

Friday, Sept. 3 — 9:00 am–12:00 pm

Tuesday, Sept. 7 — 9:00 am–12:00 pm

Tuesday. Sept. 7 — 1:00 pm–4:00 pm

Wednesday, Sept. 8 — 9:00 am–12:00 pm

Wednesday, Sept. 8 — 1:00 pm–4:00 pm

Thursday, Sept. 9 — 9:00 am–12:00 pm

Thursday, Sept. 9 — 1:00 pm–4:00 pm

Friday, Sept. 10 — 9:00 am–12:00 pm

Friday, Sept. 10 — 1:00 pm–4:00 pm

Saturday, Sept 11 — 9:00 am–12:00 pm

Monday, Sept. 13 — 9:00 am–12:00 pm

Monday, Sept. 13 — 1:00 pm–4:00 pm

Tuesday, Sept. 14 — 9:00 am–12:00 pm

Tuesday, Sept. 14 — 1:00 pm–4:00 pm

Tuesday, Sept. 14 — 6:00 pm–9:00 pm

Wednesday, Sept. 15 — 9:00 am–12:00 pm

Wednesday, Sept. 15 — 1:00 pm–4:00 pm

Thursday, Sept. 16 — 9:00 am–12:00 pm

Thursday, Sept. 16 — 1:00 pm–4:00 pm

Friday, Sept. 17 — 9:00 am–12:00 pm

Friday, Sept. 17 — 1:00 pm–4:00 pm

Monday, Sept. 20 — 9:00 am–12:00 pm

Monday, Sept. 20 — 1:00 pm–4:00 pm

Tuesday, Sept. 21 — 9:00 am–12:00 pm

Tuesday, Sept. 21 — 1:00 pm–4:00 pm

Thursday, Sept. 23 — 9:00 am–12:00 pm

Thursday, Sept. 23 — 1:00 pm–4:00 pm

Friday, Sept. 24 — 9:00 am–12:00 pm

Friday, Sept. 24 — 1:00 pm–4:00 pm

Saturday, Sept. 25 — 9:00 am–12:00 pm

Monday, Sept. 27 — 9:00 am–12:00 pm

Monday, Sept. 27 — 1:00 pm–4:00 pm

Tuesday, Sept. 28 — 9:00 am–12:00 pm

Tuesday, Sept. 28 — 1:00 pm–4:00 pm

Wednesday, Sept. 29 — 9:00 am–12:00 pm

Wednesday, Sept. 29 — 1:00 pm–4:00 pm

Wednesday, Sept. 29 — 6:00 pm–9:00 pm

Thursday, Sept. 30 — 9:00 am–12:00 pm

Thursday, Sept. 30 — 1:00 pm–4:00 pm

For questions or to schedule a session specifically for your organization, please email PFSA.

After 18 months of telehealth service implementation, the Rehabilitation and Community Providers Association (RCPA) has conducted provider telehealth satisfaction surveys, created a provider telehealth task force, and developed policy positions regarding the future of telehealth services. As the Wolf Administration, the Pennsylvania General Assembly, and the Department of Human Services seek to make telehealth services permanent, RCPA sets forth our telehealth service recommendations for implementation across the Commonwealth of Pennsylvania. RCPA has compiled the provider comments from these efforts and we believe the following recommendations represent a viable and successful pathway for practitioners and those in need of services.

We offer these recommendations to the provider community to share with stakeholders and legislators as we move forward with the expansion of telehealth services.

RCPA Strongly Recommends and Endorses the Following Telehealth Standards:

  • The delivery of virtual services through telephone use only, absent video, should be permitted when the individual served lacks video capability or during an urgent medical situation.
  • Payment for services delivered through telehealth should be paid at the same rate as a comparable, in-person encounter.
  • Use of telehealth should be expanded to cover services provided by non-clinician mental health practitioners, including unlicensed master’s level therapists, mental health targeted case managers, and mental health certified peer support specialists.
  • Use of telehealth should be expanded to include services provided in non-clinical settings.
  • Documented verbal consent in the medical record should be acceptable for consent for treatment, verification and acknowledgement of treatment/service plans, release of information, and privacy (HIPAA) notices, in the event that a signature cannot be obtained from the individual served or their legal guardian.
  • Given that telehealth use is deemed clinically appropriate, the preferences of the individual served and their caregivers should be given the highest priority when making determinations regarding service delivery method.
  • Telehealth service delivery should be expanded to include drug and alcohol providers licensed by the Pennsylvania Department of Drug and Alcohol Programs, including but not limited to counselors, certified recovery specialists, case managers, physicians, physician assistants, nurse practitioners, and nurses for services reimbursed through the MA program.
  • Translation services, including sign language interpretation, should be available for all telehealth encounters to ensure equitable access for all individuals.
  • Dedicated funding for the expansion of broadband accessibility should be allocated to ensure access to critical services for all Pennsylvanians.

Contact RCPA Children’s Division Director Jim Sharp or your RCPA policy director with questions.

The following is a notice provided by Community Care Behavioral Health (CCBH) regarding the future status of provider Alternative Pay Agreements/Arrangements (APA):


“Community Care, in collaboration with our Primary Contractors/county partners, has been closely monitoring service delivery volumes in order to assess the level of need to continue with the current Ambulatory Alternative Payment Arrangement (APA). In order to continue to support providers to ensure member access to essential behavioral health services, we collectively have determined the need to continue the current terms of the Ambulatory APA and are committed to doing so through December 31, 2021. Community Care and our Primary Contractors will continue to work with our contracted providers to prepare for the future and the eventual discontinuation of our APAs.

Please review your previous contract amendment. In lieu of an extension for additional one (1) month periods, this email serves as formal notification to extend the APA through December 31, 2021. The criterion for eligibility and the methodology for APA calculations will remain unchanged from the contract language. Please add this document to your previous contract exhibit listed below.

APA Exhibit
Ambulatory Services Advance Payment Arrangement Exhibit P

 

As noted in the contract amendment, Community Care will perform a reconciliation process for the payments providers receive under this agreement. The reconciliation process for 2021 will begin 90 days after the APA ends.

Providers have the option to opt-out of the APA payments by submitting notice to the following email address. Please use the subject line Opt Out – your organization’s name.

Continue to check our website (COVID-19 Information: HealthChoices Providers – Community Care (ccbh.com)) for other important COVID updates. If you have any questions, please contact your Community Care Provider Relations representative. A list of Provider Relations representatives and contact information may be found at Provider Representatives: HealthChoices Providers – Community Care (ccbh.com).”


RCPA is grateful for these efforts by CCBH for their continued support of providers during this time. If you have any questions, please contact your RCPA Policy Director.

The 29th Virtual Forensic Rights and Treatment Conference is scheduled for December 1–2, 2021.

At this time, Drexel University’s Behavioral Healthcare Education is now seeking presentation proposals for the conference. Applicants are invited to submit an abstract for a 60-minute workshop consisting of 50 minutes of presentation and 10 minutes for Q&A. 

Presentation proposals are encouraged to illustrate this year’s theme: The Power of Opportunity – Creating Growth Through Effective Mental Health Supports.

To submit a proposal, please download this call for presentations document and fill in all information. Please note, the deadline to submit proposals is August 31, 2021. All proposals will be considered, but only a limited number can be selected. Notifications of proposal acceptance will be emailed September 27, 2021.

Please visit here for more details on the call for presentations. If you have further questions, please contact RCPA Policy Director Jim Sharp.

The Pennsylvania Commission on Crime and Delinquency (PCCD) and the Office of Justice Programs (OJP), in a collaboration with the Department of Human Services and Office of Mental Health and Substance Abuse Services (DHS/OMHSAS), announces the availability of $1,000,000 in funds for the implementation of crisis response or pretrial diversion strategies for justice-involved individuals with Mental Illness/Co-Occurring Substance Use Disorders (MI/COD), Intellectual Disorders (ID), and/or autism spectrum disorders.

RCPA is recommending that members connect with their county courts and agencies to gauge interest and potential service provision opportunities. View the memorandum for further details, and please contact your respective Mental Health/Drug & Alcohol/IDD RCPA Policy Director with any questions.

As announced last week, the COVID-19 pandemic-related Department of Human Services (DHS) Regulatory Suspensions are set to expire on September 30, 2021. RCPA has fielded numerous inquiries as to the ongoing status of telehealth and the implications to the pending end of the regulatory suspensions. The following is a review of this status.

PA Perspective
In February 2020, DHS and the Office of Mental Health and Substance Abuse Services (OMHSAS) released an updated Telehealth Bulletin in advance of the pandemic and updated it again in March 2020 with additional flexibilities and guidelines for the use of telehealth. That bulletin is separate and apart from the regulatory suspension standards with the exception of the following:

  1. The signatory responsibility for telehealth encounters;
  2. Audio/telephonic only telehealth for Outpatient Behavioral Health services; and
  3. Audio/telephonic only telehealth for Drug and Alcohol services.

There currently is no Pennsylvania State statute prohibiting the use of telehealth/telemedicine. However, the ending of the regulatory suspensions would specifically affect those three service operations mentioned above.

PA Telehealth Bulletin
Since June of 2020, a statewide Group of Stakeholders, including RCPA, has been engaged in the development of an updated PA DHS/OMHSAS Telehealth Bulletin. This group developed a set of recommendations for operating standards and practices for telehealth in PA.

In our ongoing work and partnership with OMHSAS, we expect the PA Telehealth Bulletin to be released in advance of the Regulatory Suspension end date of September 30, 2021. It is our further expectation that the bulletin will reflect the recommendations of the PA Telehealth Steering Committee and the many operating efficiencies and practices that have been implemented during the last 18 months, including a pathway for audio only communication allowances. This referenced bulletin will only be for OMHSAS-licensed agencies, and we have been informed that other DHS divisions will subsequently release their own telehealth guidelines.

PA Telehealth Legislation
Currently in the PA State House and Senate, there are also two compatible telehealth bills that have been drafted. RCPA has been working with the legislators on the impacts of House Bill 1573 and Senate Bill 705. The bills essentially address many of the current practices of telehealth, including audio-only, but many of the current flexibilities have not been adequately addressed. RCPA continues its work in both the House and Senate on language and practices that ensure parity, equity, and access should this legislation continue through its process.

Federal Telehealth
There are more than 100 telehealth-related bills that have been introduced in this 117th Congress, and many capture the needed flexibilities that ensure best practices and access to services for practitioners and consumers. The Center for Medicaid and Medicare Services (CMS) as well as the Office of Civil Rights and Compliance are reviewing these standards, including the use of audio/telephonic only telehealth delivery. RCPA continues to advocate through our State and Federal Legislators and the National Council of Wellbeing on any pending telehealth legislation.

If you have questions of feedback, please contact RCPA Children’s Director Jim Sharp or your RCPA Policy Director.