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Authors Posts by Jim Sharp

Jim Sharp

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Behavioral health issues rarely occur in a vacuum. Many individuals with behavioral health needs also suffer from chronic physical ailments, including diabetes, asthma, and heart disease. This CHCS blog, The Thrust to Integrate Behavioral Health Services in Medicaid, highlights how policymakers are increasingly focused on the need to better coordinate care for this population. It outlines emerging state and federal efforts that are moving toward whole-person care on many fronts — including programs to integrate physical and behavioral health services, reduce homelessness, end the cycle of repeat jail visits, and, ultimately, improve this vulnerable population’s overall quality of life.

The Office of Vocational Rehabilitation (OVR) is conducting a comprehensive statewide needs assessment designed to meet and satisfy the state plan requirements in the Rehabilitation Act of 1973, as amended, and the Workforce Innovation and Opportunity Act. As part of this assessment, the Institute on Disabilities at Temple University is asking Pennsylvania employers and workforce professionals to complete a brief survey to identify how OVR can better support employers and employees across Pennsylvania.

This project is being conducted in cooperation with the Pennsylvania Rehabilitation Council and with the assistance of the Institute on Disabilities. If you are an employer or a workforce professional you are encouraged to complete this brief survey by Monday, August 1. Once you’ve completed the survey, you can enter in a drawing to win a $20 Target gift card.

The Institute on Disabilities is also seeking employer stakeholders to participate in brief phone interviews and share their expertise with the Institute. Interested employers can email or call 215-204-9544.

Integration is a hot topic and buzzword in health care. And, integrated primary and behavioral health care is the best approach to care for people with complex health care needs. But do you have an elevator speech when someone asks you about integrated care? What do you tell new staff during orientation and how do you communicate the value to potential partners and your board of directors? Join this webinar to go back to the basics of primary and behavioral health care integration and learn how to effectively communicate the importance of integrated care and the benefits to the people you serve.

Last week Insurance Commissioner Teresa Miller reiterated to consumers that enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA) is a priority for her department. Miller also encouraged consumers to understand what benefits they are entitled to under the law and to file complaints with the Insurance Department if they believe they are not getting proper insurance coverage. “The Pennsylvania Insurance Department takes this law very seriously, and we will us our statutory authority to enforce parity requirements on plans over which we have jurisdiction,” said Commissioner Miller.

The MHPAEA of 2008 requires health insurance plans to contain the same level of coverage for mental health and substance use disorders as for medical or surgical care. This coverage includes quantitative limitations (copays, deductibles, and limits on inpatient or outpatient visits that are covered) and non-quantitative limitations (pre-authorizations, providers available through a plan’s network, and what a plan deems “medically necessary”).

One important step toward a well-integrated system of health care, both physical and behavioral, is full implementation of the letter and spirit of MHPAEA. RCPA is actively working with health care advocates as part of the state’s Parity Coalition to assure consumers and providers/practitioners that Medicaid, CHIP, and private health plan coverage include quantitative and non-quantitative parity.

For more information on the MHPAEA or to file a complaint or ask a question, visit the insurance department website or call 877-881-6388.

The Office of Mental Health and Substance Abuse Services (OMHSAS) has released a draft bulletin and related documents for review and comment. The purpose of the draft bulletin and related forms is to inform behavioral health managed care organizations and providers of the procedures for requesting Applied Behavioral Analysis (ABA) using Behavioral Specialist Consultant-Autism Spectrum Disorder (BSC-ASD) and Therapeutic Staff Support (TSS) services. The draft documents describe the minimum qualifications needed to provide ABA using BSC-ASD and TSS services, and the procedure code and modifier combinations that can be used to bill for services when such services are used by appropriately qualified individuals to provide ABA.

Confirmation of Knowledge and Skills to Provide Applied Behavioral Analysis

Attestation for BHRS Providers That Provide ABA Using BSC-ASD and TSS Services

This draft bulletin is being shared at this time for public comment.  Comments should be sent to OMHSAS by Friday, July 8.

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During the recent RCPA Children’s Committee meeting, leadership from the Office of Child Development and Early Learning (OCDEL) informed members about plans to hold six regional policy forums throughout the state. Forum information and pre-registration is now available.
Regional Forums for Partnering to Strengthen Early Childhood Policies to Include All Children are being held from 9:00 am – 3:30 pm on:

  • Tuesday, August 16: Park Inn by Radisson Clarion, 45 Holiday Inn Road, Clarion
  • Wednesday, August 17: PaTTAN, Pittsburgh
  • Friday, August 19: PaTTAN, Harrisburg
  • Monday, August 22: The Woodlands, 1073 Highway 315, Wilkes-Barre
  • Tuesday, August 23: PaTTAN East – 333 Technology Drive, Malvern
  • Wednesday, August 24: Sheraton Philadelphia University City Hotel, 3549 Chestnut Street, Philadelphia

The Regional Policy Forums will focus on:
Offering input and creating strategies to support inclusion, including identifying strategies to build and sustain partnerships, developing a framework for addressing suspension and expulsion in early childhood programs, and providing input on statewide policy around inclusion, suspension, and expulsion. These policy forums will be work sessions with facilitated small group discussions to provide input to OCDEL on governance, professional development, and leadership support, related to these issues. Participants are expected to attend for the entire day and provide input based on their experiences and expertise. This is not a training or a conference where passive attendance is an option.
Pre-registration will be required for the Regional Policy Forums.

  • Go to the training calendar
  • Select the date for which you want to register and complete the online registration
  • Please use the registration key RFEC2016 (ALL CAPS)

For registration questions, please contact Linda Rhine. Registration will close on Friday, July 22, or earlier if maximum capacity is reached at a specific site.

Our colleagues at ASERT share important information and advice each month through their regular newsletter. In their most recent issue, ASERT offers suggestions for families that may be planning trips and vacations for the summer months ahead, noting that Pennsylvania has over 10 amusement parks designed for maximum family fun. Autism service providers and families, as well as those who work with and care for special needs children, know that sometimes these venues can be overwhelming and stressful for all involved. Some of the suggestions provided for families and for adults that are supporting and supervising children are to:

  • Call Ahead: Many parks offer special programs to individuals with special needs and their families.
  • Map it Out: Before arriving, be sure to review a map of the park and note where things like restrooms and quiet areas are so that you can access them easily when needed.
  • Pack Smart: Amusement parks can be loud and chaotic at times. If someone has sensitivities to noises, be sure to pack headphones, ear plugs, or other items to help them manage the environment.
  • Go Early or Late: Some parks offer “preview” packages or discounted admissions for arriving later in the day.

Read the full article on “Amusement Park Tips” as well as other information that supports the work of community providers of autism services and the families of individuals with autism – and consider signing up for regular ASERT updates.

The commencement of Certified Community Behavioral Health Clinics through Pennsylvania’s Department of Human Services, and the growing movement of individual providers to create medical homes to provide clients with co-located mental health and primary care providers in one facility, holds tremendous promise and opportunity for the coordination and enhancement of delivery of care to clients. These new provider relationships in shared office and facility spaces create new legal issues for providers under the federal Stark law and Anti-kickback statute. Providers must ensure that they do not inadvertently run afoul of these important federal fraud and abuse laws.

RCPA will offer a webinar presented by Renee H. Martin, JD, RN, MSN, a partner in the firm of Dilworth Paxson, LLP. This webinar will describe the legal requirements providers must be aware of under these federal laws and help to apply that knowledge in structuring financial relationships for use of these shared spaces. The webinar is intended for provider organizations’ executive staff, project planners, and legal counsel.

Stark Law and Integrated Health Care Webinar
Wednesday, June 29
12:00 – 1:00 pm
Register today

  • RCPA member registration is $25
  • Non-member registration is $40

Presenter: Ms. Martin exclusively practices health care law and advises both individual and institutional health care providers on regulatory and transactional matters. A significant portion of her practice centers on mental health and substance abuse law, including HIPAA, informational privacy, and fraud and abuse compliance. Ms. Martin has assisted in the formation of regional health information centers and mental health medical homes, working closely with federally qualified health centers and mental health providers.

RCPA will now distribute INFOS and ALERTS covering research, delivery and training models, policy issues, and other topics that will inform our members about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.

The Department of Human Services has issued Bulletin 99-16-04, Enrollment of Co-Located Providers. This bulletin informs providers of the process for enrollment or revalidation of providers that are in co-location arrangements. The bulletin addressed the process for Medicaid enrollment and revalidation for service providers that are “using the same distinct street address as a different currently enrolled provider.” It also addresses situations in which a provider is located within another provider’s offices and is accompanied by the department’s Co-Location Attestation form.

To further support members developing or providing co-located service provider relationships in a shared office and facility space, RCPA will conduct a Lunch and Learn webinar on June 29, focused on the legal issues for providers under the federal Stark law and Anti-Kickback statute. This webinar will describe the legal requirements providers must be aware of under these federal laws and apply that knowledge in structuring financial relationships for use of these shared spaces. Look for webinar information and registration in an RCPA INFO.