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Authors Posts by Jim Sharp

Jim Sharp

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The Office of Children, Youth and Families (OCYF), as a part of the ongoing revision process for the Regulatory Compliance Guide (RCG), is seeking feedback and comments on the most recent guide. The guide has been developed over the past year as part of summer providers’ convenings and other stakeholder forums.

It is important to note that this guide is to act as a companion to the Chapter 3800 regulations and not in place of the regulations. However, prior to finalization of this document, OCYF requests your feedback and comments in relation to the RCG document.

The department requests that all feedback and comments be submitted by Friday, February 14, 2020 to their established resource account.

The RCPA Children’s Residential Work Group will also be working on this area, and they are asking that RCPA Children’s Division Director Jim Sharp be included on the correspondence for the group’s information. The RCG guide link can be found here.

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Governor Tom Wolf is proposing a $5.1 million funding boost to the state’s oversight of residential juvenile programs, after Inquirer investigations into child abuse at the nation’s oldest reform school and the state’s failure to detect or stop it. The extra millions in the 2020/21 budget would fund more than 100 additional staff positions to several program areas within the Department of Human Services (DHS), the state agency that licenses and monitors privately run residential facilities for court-ordered youth. The funds would enable DHS to “complete timely inspections of facilities to ensure full compliance with regulations, investigate complaints, and monitor the implementation of corrective action measures,” according to materials provided by Wolf’s office. The Governor, who recently announced a juvenile-justice task force, is expected to pledge additional funding for the troubled system in the 2021/22 budget as well. Read full article here (subscription required).

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The Family First Prevention Services Act will dramatically change the federal funding priorities for child welfare. There will be a host of new requirements and some new opportunities in the areas of prevention and older youth. There is more of a push toward evidence-based programs. Pennsylvania is working to implement the provisions of the Family First Act in October of this year.

The Pennsylvania Children and Youth Administrators would like to invite you to join them for an update regarding the Family First Act and Transition Act, as well as hear the latest of where Pennsylvania is at regarding implementation. The Office of Children, Youth, and Families (OCYF) has once again graciously agreed to present and to answer what questions they can. This training is open to commissioners, CYS agencies, providers, and others interested in learning more about Family First and Pennsylvania’s implementation efforts.

The training will be Monday, February 24, 10:00 am – 12:30 pm at the CCAP Office: 2789 Old Post Road, Harrisburg, PA 17110. See the flyer for registration details.

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The Office of Children, Youth and Families (OCYF) Notification Protocol for Formal Licensing Actions and Incidents, is currently outlined in Bulletin #00-19-02 released in August 2019. On October 21, 2019, OCYF convened a meeting to bring together representatives from entities covered within the scope of OCYF Bulletin #00-19-02, to discuss the intent of the notification protocol, and to develop recommendations for improvements to the process.

From the meeting, the following improvements were agreed upon and will be released in new bulletins as described below.

  • A new bulletin will be issued promptly to remove the issuance of a notification regarding removal of staff under an approved plan of supervision. These notifications are no longer being sent. This bulletin will also remove any notifications listed that are duplicative of one another, specifically those that would equate to a citation and issuance of a licensing inspection summary (LIS), as those already trigger a notification.
  • Pending the implementation of CPSL amendments, another bulletin will be issued to include a quarterly report that will be provided to county agencies and dependency and delinquency judges, providing aggregate child abuse and substantiation data for child residential or day treatment facilities, approved foster or pre-adoptive homes, and youth development centers and youth forestry camps. If/when the CPSL is amended to permit the release of specific aggregate data, a new bulletin will be issued that will provide for county agencies and dependency and delinquency judges to receive substantiation information at the conclusion of an investigation, regardless of whether they are the placing county for the child or youth for these same placement settings.

RCPA was grateful to participate in this process and commends OCYF and the systems stakeholders for the collaborative partnership on this initiative The Department of Human Services (DHS) is moving forward with implementing these changes to ensure the safety and well-being of Pennsylvania’s children and youth. If you have any questions, please contact RCPA Children’s Division Director Jim Sharp.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) is aware that not all providers of intensive behavioral health services (IBHS), that are required to have obtained an IBHS license by January 17, 2020, have attained an IBHS license. In order to ensure services are not disrupted, the Department will not take action against an IBHS agency, as long as the IBHS agency is working with OMHSAS to obtain their IBHS license. Agencies that have questions about obtaining a license should contact their regional field office.

Providers that participate in the medical assistance program can continue to bill for BHRS after January 17, 2020. Providers that meet the requirements for providing IBHS will be available to bill IBHS when instructions are issued for IBHS billing by OMHSAS.

View the OMHSAS IBHS Correspondence. If you have any questions, please contact RCPA Children’s Division Director Jim Sharp.

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As part of the ongoing Intensive Behavioral Health Services (IBHS) Implementation, OMHSAS has released an updated FAQ. This guide represents a composite of updated inquiries regarding the standards and will be updated as a companion piece to the implementation. New questions appear as follows: Question #14 on page 26 and Question #7 on page 29.

We also stress the importance that our members continue to work with your BH-MCOs on the rate development process, by submitting the requested line by line budget cost analysis for the actual cost of programming IBHS based upon the regulations. RCPA will keep working with the OMHSAS Children’s Bureau and BH-MCO task force in the rate development process as well.

The RCPA Children’s IBHS Work Group continues its work on standards and implementation values for our members and will convey its findings to the Children’s Division via Alerts, Infos, and regularly scheduled divisional meetings. Contact RCPA Children’s Division Director Jim Sharp with questions.

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RCPA has been notified by the PA Department of Corrections (DOC) / Bureau of Community Corrections (BCC) of a new referral process for Alcohol and Other Drugs (AOD) or Mental Health (MH) services for reentrants. This initiative is part of a continued effort to reduce and maintain the Department budget, to streamline services, and to offer consistent and needed programming.

Effective immediately, any referrals made to the BCC for AOD or MH services should be made as a last resort. This includes any inpatient placements as well. It is the responsibility of the person making the referral to find placement through other community resources first, when possible. In many cases, reentrants either have or are eligible for medical assistance. Medical assistance will allow a range of services to be funded under their contracts.

If a reentrant is in need of services, reach out to the statewide single county authority (SCA) helpline first. The number to call is 800-662-HELP (4357). A more complete list of every SCA, every county MH office, and their contact person is being formulated and will be forthcoming in the near future. Until those lists are distributed, please use the SCA HELPLINE number that is provided. It can be a starting point for both AOD and MH services, and inpatient beds in the county.

The correspondence from the Department of Corrections / BCC can be found at this link.

For our RCPA members currently providing these services, please contact RCPA Criminal Justice Division Director Jim Sharp and/or RCPA Drug & Alcohol Division Director Kristen Houser to discuss the potential impact on your services.

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This afternoon’s ABA meeting PowerPoint has been posted to the website. The information is a summary of existing information and will be focused on helping providers new to MA, or only participating in commercial insurance, acclimate to licensing and the IBHS regulations. The WebEx is currently over the registration cap and many traditional BHRS providers registered for multiple slots. If you have been participating in previous IBHS Training and WebEx sessions, this material will be redundant. Please share with any providers you feel may benefit from the information. Thank you!

There will be an additional IBHS ALERT that goes out today with updated information on the implementation. Contact RCPA Children’s Director Jim Sharp with questions.

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On Thursday, January 9 from 10:00 am to 1:00 pm, OMHSAS will be offering an in-person training regarding IBHS implementation in the CRR Host Homes. Information is below and we apologize for the short notice.

  • January 9, 2020; 10:00 am – 1:00 pm
    Statewide Community Residential Rehabilitation: Host Home Providers Forum
    Behavioral Health Alliance of Rural Pennsylvania (BHARP), Auditorium – First Floor
    301 Science Park Road, State College, PA 16803

The forum is in-person only and will discuss CRR-HH providers implementation of the medical assistance treatment component through the IBHS license.

On Friday, January 10, OMHSAS will be conducting an IBHS WebEx for ABA providers regarding the implementation standards for IBHS specific to ABA services. The information is below and we apologize for the short notice.

  • January 10, 2020; 1:00 pm – 3:00 pm
    ABA Provider Webinar
    Please register for the webinar here. Participation is limited. Please consolidate viewing locations whenever possible to help ensure all interested parties are able to participate.

After registering, you will receive a confirmation email containing information about joining the webinar. If you believe that you have questions that will be helpful in developing upcoming trainings and FAQs, please submit them via email.

There will be additional IBHS Alerts coming out later today. If you have any questions, please contact RCPA Children’s Division Director Jim Sharp.

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As a follow up to December’s meeting of RCPA and the BH-MCO Task Force, and the development of the IBHS rates, we continue to strongly recommend providers consider the activities listed below.

We also request, in addition to providing this to your BH MCOs, that you provide RCPA with a copy of the information so we can develop a concise picture of the actual cost of care by our provider network. All agency information will be held securely and will remain confidential.

  • Agencies should do a line-by-line review of the IBHS Regulations to determine current and future costs to implement a specific regulation.
  • Areas such as training, supervision, staff credentialing, infrastructure redesign, hiring, quality improvement requirements, and individual staff training plan development/tracking should be considered, but be sure to consider all regulations impacting the delivery of service platform.
  • The cost calculations should be shared with your BH-MCO so they have a full understanding of the actual cost of care that your agency will require to deliver the IBHS service(s).

This rate development process will require a partnership with the providers to capture the actual cost of care and implementation. RCPA and the Children’s IBHS Work Group continue to work on the implementation values for IBHS. If you have questions or feedback, please contact RCPA Children’s Division Director Jim Sharp.

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