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Authors Posts by Jim Sharp

Jim Sharp

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Photo by René DeAnda on Unsplash

RCPA provided some late updates yesterday on the Federal funding freeze, and late last evening, the National Council for Mental Wellbeing provided members a legal interpretation on the rescinding of the Office of Management and Budget (OMB) M-25-13 and the issuance of the new memorandum M-25-14.

The following is from the National Council:

On Wednesday afternoon, the White House Office of Management and Budget issued a new memorandum—M-25-14 — that rescinded the pause to federal funding contemplated in a previous memorandum first issued on Monday night.

The new memorandum, which was directed to “heads of executive departments and agencies,” features a two-sentence statement reading: “OMB Memorandum M-25-13 is rescinded. If you have questions about implementing the President’s Executives Order, please contact your agency General Counsel.”

In the short term, M-25-14 certainly relieves some of the confusion and anxiety that swept across the federal grants world since Monday night. Our previous client alerts have chronicled the chaos that emerged late Monday and throughout the day on Tuesday.

However, in our review, there are still five key Executive Orders issued by the Trump Administration not affected by the rescission of M-25-13. Those EOs include:

While the upheaval following the issuance of M-25-13 may have prompted the Trump Administration to change course and move away from pausing all federal funding, we certainly anticipate that federal grants in the above-listed areas will remain subject to a comprehensive review and new standards. Federal grantees with programs in these specific areas should undertake a detailed review and be prepared for future agency actions.

Federal grantees should continue to keep apprised of the Administration’s actions, orders, and statements relating to federal funding — as the rescinded memorandum likely foretells future clashes as the Administration attempts to exert control over federal spending.

Chuck Ingoglia
President & CEO
Strategic Leadership
National Council for Mental Wellbeing

In addition, ANCOR sent the following information last night:

In what’s turning from a whirlwind couple of days into a whirlwind week, there were notable updates today on the OMB memo on the freeze of certain federal funding issued earlier in the week. 

Today OMB withdrew the memo with a simple rescission statement after a federal judge temporarily blocked the funding freeze for open awards and current spending. The order remains in effect until February 3 when a hearing is scheduled to determine next steps.  

As you may have seen, later in the day, Press Secretary Karoline Leavitt posted to X, “[t]his is NOT a rescission of the federal funding freeze. It is simply a rescission of the OMB memo. Why? To end any confusion created by the court’s injunction. The President’s EO’s on federal funding remain in full force and effect, and will be rigorously implemented.” Without further specificity regarding the implicated executive orders, the situation remains fluid with the potential for later memos or other interpretive guidance which the White House maintains is authority held within the executive branch.

In other litigation, U.S. District Judge Jack McConnell made statements in court today indicating that another restraining order may be coming. With the memo rescinded, the Department of Justice Special Counsel argued the case is no longer relevant. However, the judge did not appear persuaded and asked for a draft protective order for response and consideration. 

We’ll continue to keep you posted as we know more and hope to see you Friday (1/31) for our extended Members-Only Weekly Briefing at 12:30 pm ET to provide updates and review all available information together. See login information below:
Join Zoom Meeting: ancor-org.zoom.us/j/… 
Meeting ID: 870 2745 7284 
Passcode: 977618 

In recent communications from the OMB, these actions will not impact programs that provide direct benefits to individuals and are explicitly excluded from the pause and exempted from this review process. In addition to Social Security and Medicare, already explicitly excluded in the guidance, mandatory programs like Medicaid and SNAP will continue without pause.

RCPA will continue to communicate new developments with members as they emerge. If you have any questions, please contact your RCPA Policy Director.

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Image by David Mark from Pixabay

RCPA continues its efforts to update members on the White House funding freeze while partnering with the National Council for Mental Wellbeing and ANCOR in examining the implications stemming from the White House Office of Management and Budget’s (OMB) January 27 memorandum temporarily freezing federal disbursements to many federal programs.

The National Council has provided the following update:

Federal agencies have been directed to fill out a spreadsheet as part of an analysis by Feb. 7 to ensure compliance with the president’s most recent executive orders. This is a breakdown of which health programs are included in this latest action.

Notably, we recognize conflicting guidance has been issued. While the above report identifies Medicaid programs, a Q&A document from the administration notes that Medicaid will continue without pause. As of Tuesday morning, all 50 states reported outages of their Medicaid online portals, and the Trump administration has stated they are aware of the outages and expect the portals to be back online shortly.

Also, several groups have taken action to block this funding freeze. As of this writing, several Democratic state attorneys general said they would ask a court to block the freeze from taking effect. Several groups representing nonprofits, public health professionals and small businesses have already filed suit in D.C. asking the court to prevent the freeze from continuing. On Tuesday evening, U.S. District Court Judge Loren L. AliKhan issued a temporary stay on the funding freeze until Feb. 3 at 5:00 pm ET.

The funding freeze may lead to project delays or cancellations, resulting in layoffs of workers involved in these programs, and may ultimately increase the unemployment rate, making it vital lawmakers understand the impact of this freeze on communities across the country.

Most notable are the concerns with the intersects of Medicaid funding though the information that has been released. The Q&A document states:

Q: Is this a freeze on benefits to Americans like SNAP or student loans?

A: No, any program that provides direct benefits to Americans is explicitly excluded from the pause and exempted from this review process. In addition to Social Security and Medicare, already explicitly excluded in the guidance, mandatory programs like Medicaid and SNAP will continue without pause.

RCPA will continue to communicate new developments with members as they emerge. If you have any questions, please contact your RCPA Policy Director.

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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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