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Authors Posts by Jim Sharp

Jim Sharp

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As the behavioral health system struggles to find in-clinic psychiatric services, the Office of Mental Health and Substance Abuse Services (OMHSAS) has been issuing waivers to providers to address this barrier, while legislative remedies are pursued. There have been some waivers granted in the past year that included conditional language requiring the presence of a psychiatrist in the clinic a minimum of two days per month.

RCPA began discussions with OMHSAS that this condition was difficult to meet and it represents the actual reason for the waiver. OMHSAS has reconsidered this positon and will eliminate that language and requirement for future waivers. In the interim, providers with approved waivers with the above referenced psychiatrist requirements will need to submit a revised waiver request. RCPA thanks OMHSAS for their partnership and consideration on this matter.

If this impacts your organization, please contact RCPA COO & Mental Health Services Director Jim Sharp, who will provide guidance in the resubmission process.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the Intensive Behavioral Health Services (IBHS) Regulatory Compliance Guide (RCG). This guide has been developed to provide clear explanations of the regulatory requirements of Title 55 Pa. Code, Chapter 5240, “Intensive Behavioral Health Services” regulations. It is meant to help agencies providing IBHS services, with the goal of ensuring safe and effective services to children, youth, and young adults through regulatory compliance as well as to help OMHSAS Licensing Representatives protect those served by these programs by conducting consistent and comprehensive inspections.

This guide is a companion piece to Title 55 Pa. Code Chapter 5240 regulations. 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 55 Pa. Code Chapter 5240.

The RCPA IBHS Steering Committee will be reviewing UBHS RCG and will provide further clarification to members in the near future.

Feedback or questions on the RCG can be sent to OMHSAS electronically.

If you have any questions or are interested in joining the RCPA IBHS Committee, please contact RCPA COO & Mental Health Policy Director Jim Sharp or RCPA Policy Associate Emma Sharp.

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Image by Gerd Altmann from Pixabay

RCPA is excited to host a Membership Benefits webinar on Wednesday, January 15, 2025, at 1:00 pm, as an opportunity for members to orient themselves with all that RCPA membership includes. This is not just for new and future members. For current members, there may be benefits associated with our membership that you may not be aware of, including targeted meetings and groups that occur throughout the year.

Registration is required; please register here to attend the webinar. Items we will review include the below and much more:

  • Virtually meet the dedicated RCPA Policy Staff and RCPA lobbyists;
  • Discuss the 2025 Legislative and Administrative priorities;
  • Preview RCPA divisional committee and subcommittee meetings and what they offer;
  • View the RCPA member-only website;
  • Review exclusive yearly educational and networking events; and
  • Understand the value of the National Association memberships included with RCPA membership.

Visit the RCPA member benefits web page for more information, or contact Tieanna Lloyd for benefit details.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the OMHSAS-24-05 Peer Support Services (PSS) Bulletin and PSS Provider Handbook, updating the requirements for Peer Support Services. OMHSAS significantly reorganized the existing language in the Handbook to better clarify which requirements apply to OMHSAS licensure and which apply to Medical Assistance payment. Along with these formatting changes, OMHSAS-24-05 includes the following updates:

  • Staff Qualifications and Requirements for Certified Peer Specialists (CPS)
    • The requirement for a CPS to have a high school diploma or GED has been removed.
    • The requirement for a Serious Mental Illness (SMI) or Serious Emotional Disturbance (SED) has been replaced with a requirement to have a mental health diagnosis. Please note, to be eligible to receive PSS services, there is still a requirement for “the presence or history of an SMI or SED.”
    • The clause requiring CPSs “to attain certification through the PCB within six months of hire” has been removed, as the certification examination is now available on-demand, eliminating the need for a grace period for testing to be completed.
  • Staff Qualifications and Requirements for CPS Supervisors
    • Adding a new qualification category for individuals with an associate degree.
    • Supervisory meetings held in an audio-only format shall not be considered supervision.
    • Supervisory meetings shall be provided at a minimum of one hour each week.
  • Telehealth
    • The prior requirement that only 25% of total services provided per beneficiary per calendar year can be delivered by telephone has been removed.
    • PSS may be provided via telehealth technology, including audio-only service delivery, when it is clinically appropriate to do so.
    • PSS providers must ensure that the preference of individuals receiving services (or their legal guardian) is given a high priority when determining the appropriate service delivery modality.

Please review all other revisions to OMHSAS-24-05 here.

Comments and questions regarding this bulletin should be directed to:
Office of Mental Health and Substance Abuse Services, Bureau of Policy, Planning and Program Development,
P.O. Box 2675,
Harrisburg, PA 17105
General Office Number: 717-772-7900
Email

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

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Capitol hill building in the morning with colorful cloud , Washington DC.

On December 21, President Biden signed into law the 2025 American Relief Act, a stopgap funding bill passed by Congress on December 20 that funds the federal government through March 14, 2025, and includes over $110 billion for disaster relief.

The bill extends certain Medicare telehealth flexibilities through March 31, 2025, under Section 3207, including the six-month in-person requirement for mental health services, the expanded originating sites, and coverage of audio-only services.

The bill also extends funding for several expiring health care programs through March 31, 2025, including the National Health Service Corps at $85 million and the Teaching Health Center Graduate Medical Education Program at $43 million, both under Section 3101.

In addition, the stopgap bill delays scheduled reductions to the Medicaid Disproportionate Share Hospitals allotments, which are currently set to result in a total reduction of $32 billion between 2025 and 2027. Under Section 3401, the bill delays these cuts through April 1, 2025.

You can read the bill text and a summary of the health care provisions.

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The Department of Human Services (Department) issued bulletin OMHSAS-16-03, “Revised Procedure for Waiver of Office of Mental Health and Substance Abuse Services (OMHSAS) Program Regulations and Standards,” on April 19, 2016, to update and clarify the procedure for submitting and processing of waiver requests to OMHSAS. OMHSAS has issued OMHSAS-24-04 to further update regulatory waiver language and the process to appeal a waiver determination. The issued bulletin can be found here. OMHSAS-16-03 is obsoleted by this bulletin.

OMHSAS licenses or approves community mental health facilities and agencies and other service providers operating in the Commonwealth of Pennsylvania. In accordance with this responsibility, the Department’s authorized agents periodically inspect mental health facilities and agencies. If regulatory requirements are met, certificates of compliance or approvals are granted under Article IX of the Human Services Code (62 P.S. §§ 901 – 922) or under Article X of the Human Services Code (62 P.S. §§ 1001 – 1080).

Pursuant to applicable regulations, a facility or agency may request a time limited waiver of regulations or program standards, or a portion of regulations or program standards. All regulatory waiver requests are subject to applicable waiver of standard requirements as outlined by each chapter or bulletin. In reviewing any such waiver request, OMHSAS will consider whether the facility or agency has demonstrated that substitute measures assure the health, safety, and welfare of all individuals who reside in the facility or who receive services from the agency.

Please contact RCPA COO and Mental Health Policy Director Jim Sharp with any questions.

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Image by Gerd Altmann from Pixabay

RCPA is excited to host a Membership Benefits webinar on Wednesday, January 15, 2025, at 1:00 pm, as an opportunity for members to orient themselves with all that RCPA membership includes. This is not just for new and future members. For current members, there may be benefits associated with our membership that you may not be aware of, including targeted meetings and groups that occur throughout the year.

Registration is required; please register here to attend the webinar. Items we will review include the below and much more:

  • Virtually meet the dedicated RCPA Policy Staff and RCPA lobbyists;
  • Discuss the 2025 Legislative and Administrative priorities;
  • Preview RCPA divisional committee and subcommittee meetings and what they offer;
  • View the RCPA member-only website;
  • Review exclusive yearly educational and networking events; and
  • Understand the value of the National Association memberships included with RCPA membership.

Visit the RCPA member benefits web page for more information, or contact Tieanna Lloyd for benefit details.

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