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Authors Posts by Jim Sharp

Jim Sharp

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This memo provides guidance and recommendations pertaining to visitation, meetings, and travel for entities operating as a Child Residential and Day Treatment Facility licensed under Title 55 Chapter 3800.

The Department of Human Services (DHS), Office of Children, Youth, and Families (OCYF) has developed these recommendations in response to growing concerns about the spread of COVID-19 and guidance issued by the Pennsylvania Department of Health. If you have any questions or concerns, please contact RCP Children’s Director Jim Sharp.

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The COVID-19 pandemic has had a profound impact on all of us; especially our providers who through adversity continue to strive to provide quality services to children, youth, or young adults. Due to our current situation, the PRTF Regulatory Work Group meeting scheduled for April 14, 2020 will be postponed. Information on the next work group meeting will be provided in the near future.

In an effort to continue to progress towards the development of foundational standards, we will be utilizing the information from the February work group (and other applicable resources) to provide you with regulatory language and general questions for you to review and comment on. Withstanding the difficulties that many of us have at this time, this information will be forwarded periodically over the coming month(s). This will occur through the resource account (RA).

Our first focus area will be on staff ratios and sleeping hours. Though we will be starting with the topic of staff ratios and sleeping hours, please know that the RA account is available for writing to us with your comments and suggestions regarding the PRTF Regulations, other specific regulation topic areas you would like us to request input on, and general work group processes.

Contact RCPA Children’s Division Director Jim Sharp with questions.

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The information below is an excerpt from the questions that were submitted during the stakeholder and legislator webinars held on Tuesday, March 17.

As a reminder, the departments of Health and Human Services continue to update websites with new information and guidance for both stakeholders and the public. Those resources are below:

RCPA has an open channel with OCYF that can assist in facilitating answers to ongoing questions nd concerns; please continue to forward that information to RCPA Children’s Division Director Jim Sharp.

Q & A
Office of Children, Youth, and Families (OCYF) Questions:

Can congregate care programs that have school programs continue those programs?

Congregate care programs should contact the Pennsylvania Department of Education for guidance on school programs.

RCPA Response: These programs fall into the PDE directive and we recommend for school closure until PDE is directed to resume school operations across PA.

Are there any changes to/interruption to the Kinship Care navigation support line? 

The Kinship Navigator hotline continues to operate as normal and can be reached at 866-KIN-2111.

Can OCYF waive the requirement for face-to-face check-ins with children in foster care and allow this to happen via video conferencing, or would that require a federal statutory change/address in the national emergency order?

The Federal Children’s Bureau released guidance to states permitting use of video or teleconferencing methods for completing the required 30-days caseworker visits for children in foster care. This guidance from the federal government along with the Governor’s emergency disaster declaration will allow OCYF to suspend state regulatory requirements for the check-in to be face to face. Video conferencing is still expected to occur within the normal timelines. OCYF has communicated this guidance to county children and youth agencies and providers.

Young people must meet eligibility requirements related to participation in activities like school and work to remain eligible for extended foster care. Since many of these activities are being disrupted significantly or canceled, are DHS and OCYF willing to direct county child welfare agencies to: 1) waive eligibility requirements during this time period and 2) prohibit agencies from discharging any youth from extended foster care during this time period to ensure their safety and well-being?

While the eligibility requirements for older youth to remain in extended foster care are set forth in statute, OCYF supports broad interpretation of the requirements at this time to allow for these older youth to remain in care.  For example, one eligibility option is that a youth be “enrolled” in a postsecondary or vocational education program, which means even if college or vocational classes are suspended, a youth could still be eligible for extended foster care as long as they remain enrolled. It should also be noted that the final determination that the child meets necessary eligibility criteria is made by the court, not the children and youth agency.

Is there a plan for if young children who need to enter foster care have COVID-19 and there is not a foster home willing to accept them or all available foster parents are high risk based on age/health conditions?

OCYF is working with county children and youth agencies and providers to explore contingency models in anticipation that this could become an issue; however, it is not something that has been brought to the attention of OCYF as a problem agencies are experiencing at this time.

Residential Providers are having trouble hiring new employees because of the closure of federal fingerprinting centers due to COVID-19. How is DHS handling this closure?

This affects numerous fields, so DHS is closely monitoring this issue alongside the Governor’s Office. We will issue guidance if necessary.

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A MESSAGE FROM OMHSAS: We are pleased to provide an update on the status of the expansion of behavioral health – telehealth.  On March 15, 2020, OMHSAS provided guidance supporting broad use of telehealth to deliver behavioral health services in the community, including in homes.  The guidance is based on the current allowable services in PA with additional flexibility that is aligned with CMS guidance.   Since the expansion guidance was issued, we have received over 1400 requests by providers who were provisionally approved to immediately initiate the expanded use of telehealth.  We are encouraged by these numbers and expect the expansion is being implemented consistently across all behavioral health networks according to the provided guidance.

We recognize these are unprecedented times as we come together to jointly address the COVID-19 crisis.  More than ever, it is incumbent upon each local community to continue to provide the necessary behavioral health supports and services to ensure individuals receive the services they need and in the delivery format that is necessary during this crisis.  During these times innovation is critical, such as expanding the use of telehealth, delivering services in the home, and allowing staff to work from home.  It is also critical to ensure sufficient office and clinic hours are available to meet the needs of new patients and established patients who either do not choose or cannot use telehealth or receive services in their homes.  As such, there should be a balance of service delivery modalities based on safety and the needs of individuals receiving services, staff providing services and overall community needs.

It is the expectation of the Department that all providers will be approved to render services as clinically appropriate through telehealth as described within the guidance based on individual needs.  Please take note of the below guidance that is being restated to reinforce the direction for the delivery of behavioral health services to support our behavioral health community needs related to telehealth during the emergency disaster declaration.

  • Telehealth will allow the use of telephonic video technology commonly available on smart phones and other electronic devices. In addition, telephone only services may be utilized in situations where video technology is not available.
  • The practitioner types that can provide services through telehealth will not be limited to psychiatrists, licensed psychologists, Certified Registered Nurse Practitioners and Physician Assistants certified in mental health; Licensed Clinical Social Workers; Licensed Professional Counselors; and Licensed Marriage and Family Therapists. Other individuals providing necessary behavioral health services will be permitted to utilize telehealth for services that are within their scope of practice.
  • The provider types that can bill for telehealth under MA FFS will not be restricted to Psychiatric Outpatient Clinics, Psychiatric Partial Hospitalization Programs, and Drug & Alcohol Outpatient Clinics. When completing the Attestation Form (Appendix B), the “Other” Field (section I.a.) is not limited to HealthChoices during this state of emergency. BH-MCOs may continue to allow billing for any provider type they determine appropriate.
  • The services (procedure codes) that can be provided through telehealth under MA FFS will not be restricted to the procedure codes identified in Attachment A of the Bulletin OMHSAS-20-02. BH-MCOs already have the flexibility to do this.
  • The provision of telehealth services in homes will not be limited to Assertive Community Treatment, Dual Diagnosis Treatment Team, or Mobile Mental Health Treatment.
  • Program requirements for the number or percentage of face-to-face contacts for various behavioral health services may be met with the use of telehealth.
  • Program limits on the amount of service that can be provided through telehealth are temporarily suspended.
  • Telehealth is a modality for delivering services that can be used across all levels of care for both mental health and substance use services.
  • Telehealth should not be the only service modality used in a community and sufficient office and clinic hours should remain available to meet the needs of new and established patients.
  • Telehealth includes the ability for providers to deliver services from locations outside of the office, including the home.

RELEVANT DOCUMENTS:

Should you have any further questions or concerns, please connect with us at this email.

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From RELIAS:

The well-being and safety of the individuals we serve is our top priority and will remain at the heart of every decision we make.

As you prepare for Coronavirus (COVID-19), Relias wants to directly support your efforts by providing accurate and impactful education on infection prevention and control. We are currently offering a free digital toolkit — How to Prepare for Coronavirus (COVID-19) and Influenza: Training & Resources, which contains unlimited access to courses and fact-driven information regarding COVID-19 preparedness and prevention.

This toolkit will continue to be updated with the latest resources; please check back often!

We encourage you to share this toolkit with colleagues, friends, and family to help combat coronavirus. At Relias, providing these types of resources is core to our mission to measurably improve the lives of the most vulnerable members of society and those who care for them.

Thank you for helping communicate this information. In times like these we listen, we learn, and we support each other.

Explore Our Toolkit

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Protecting our staffs, our residents in our facilities, and our communities are paramount as we face this public health issue. VitalCore Health Strategies has created a protocol response plan that provides a very clear COVID-19 pandemic response plan and we hope you find this document beneficial for the health and safety of your facility.

The response plan is based on current guidance from the Centers of Disease Control and Prevention (CDC). It provides an outline for infection prevention and control information that should be considered for facilities related to a COVID-19 response. Please keep in mind that the CDC’s guidance may continue to change so this plan may require updating. Please continue to visit the CDC’s website for updates. If you have any additional questions, please contact your RCPA Policy Director.

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As part of Philadelphia’s response to the COVID-19 outbreak, Community Behavioral Health is coordinating efforts aimed at maintaining access to services for our members and supporting the dedicated staff who are serving them. Given the rapidly evolving nature of the situation, CBH is requesting that this survey be completed by 5:00 pm on Monday, March 23, 2020.*

*Please Note: If you have already closed your programs, CBH would still be requiring you to complete this survey.

Any questions related to this matter, please feel free to contact your Provider Relations Representative or your RCPA Policy Directors Sarah Eyster or Jim Sharp.

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The Application and Approval Process for certification as a specialized setting outlined within the Office of Children, Youth and Families (OCYF) Bulletin # 3680-20-02, 3800-20-03, Specialized Residential Settings for Children and Youth, was released February 14, 2020.

OCYF understands the strains placed on provider agencies by the Government response to Coronavirus Disease 2019 (COVID-19). In an effort to ensure all agencies licensed under Chapter 3800 as a child residential facility, or Chapter 3680 as a Supervised Independent Living Program, interested in participating in the voluntary certification process for specialized services outlined in the above bulletin are able to submit all necessary documentation for consideration for certification, OCYF will extend the following deadline (which appears in Attachment B of the bulletin as 3/15/2020):

3/23/2020 – Interested providers must submit a letter of intent that will trigger an automatic 45-day extension of DHS’ requested due date (3/1/20) for pre-contractual budget documentation through this resource account. Acknowledgement of receipt will be sent from the resource account.

All other guidance and instruction within the bulletin and pertaining to the application process still applies. Those who have already submitted the letter of intent do not need to resubmit.

This specialized settings certification process coincides with the end of State Fiscal Year (SFY) 2019–2020, in order to allow the certifications to be issued in advance of SFY 2020–2021. Any agency or provider unable to participate in the certification process for SFY 2020–21 may participate in the process for SFY 2021–22. OCYF will provide information and instructions prior to the window for letter of intent and application submission for SFY 2021–22 certification.

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Please join OCDEL Deputy Secretary, Tracey Campanini, for a brief update around OCDEL’s response to COVID-19 on Wednesday, March 18, 2020, from 11:00 am – 11:30 am.

Join from PC, Mac, iOS or Android: https://paiu.zoom.us/j/538789318

Or join by phone:

    +1 312 626 6799 or +1 646 558 8656 (US Toll)
855 880 1246 (US Toll Free)
877 369 0926 (US Toll Free)
Meeting ID: 538 789 318
International numbers available: https://paiu.zoom.us/u/agJIfkvrD

Or join from a H.323/SIP room system:

    Dial: 162.255.36.11
Meeting ID: 538 789 318

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