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On behalf of the RCPA IBHS Providers and the children and families of Pennsylvania, RCPA has requested the Independent Regulatory Review Commission (IRRC) to reopen for review Regulation #14-546: Intensive Behavioral Health Services, based on section 8.1 of the Regulatory Review Act (71 P.S. § 745.8a).

The premise of our recommendations addresses the challenges and barriers IBHS providers have faced in creating the staffing infrastructures and meeting the burdensome operational protocols for regulatory compliance. The overreaching nature of the regulations, coupled with the impact of the pandemic, has caused great strain on an already depleted behavioral health workforce. These system stressors limit the ability to provide vital, quality services to children and families. Due to the prohibition for the use of waiting lists, it is difficult to capture the true number of children and families going without these essential services. We contend there are thousands of children across the Commonwealth with unmet treatment needs and written orders for IBHS services who await care.

The current lack of access to care is a result of the workforce crisis and operational requirements of implementing the regulations. We feel these access issues and children waiting for services are compelling reasons, in the interest of the public, to merit a review of the regulations.

The COVID-19 DHS regulatory flexibilities provided initial relief for providers, and OMHSAS continues to offer waivers to agencies experiencing critical staffing shortages. Providers are grateful for these temporary solutions; however, these waivers do not address the long-term impacts of the current regulatory requirements. Providers continue to struggle to hire qualified staff and contend with burdensome operational requirements, many of which negatively contribute to the efficiency of care delivery.

The expressed purpose of the IBHS regulations was to ensure access to quality care in a consistent and efficient manner. Conversely, the result has been a labyrinth of regulatory and operational interpretations, differentiated reimbursement for the same services, and a human services workforce crisis with no upcoming relief.

RCPA would like to thank the members of the RCPA IBHS Steering Committee for their commitment to conduct the review and the Commission for their willingness to consider this request. We believe these recommendations, if implemented, can address the barriers identified without compromising the original vision for high-quality services and broad access to care.

At last correspondence, the IRRC is in receipt of the recommendations. We will be providing a copy to the Office of Mental Health and Substance Abuse Services (OMHSAS), as requested by the Commission. We will continue to keep members apprised of the review process. If you have further questions, please contact RCPA Policy Director Jim Sharp.

ODP Announcement 22-123 announces that a new Room and Board Residency Agreement (DP 1077) has been developed to align with 55 Pa. Code Chapter 6100 requirements. Please note that if a provider agency has a current, accurate room and board contract (DP 1051) in the participant’s file, the Office of Developmental Programs (ODP) is not requiring provider agencies to complete the new DP 1077. The intent is for provider agencies to begin using the new Room and Board Residency Agreement § 6100.687 (DP 1077) form when a new contract is needed.

ODP is continuing to revise the Room and Board Bulletin that was put out for public comment in the summer of 2021. Once this bulletin is finalized, ODP will communicate with stakeholders regarding the release of the Room and Board Bulletin that will contain the requirements found in the 55 Pa. Code Chapter 6100 regulations.

If you have any questions, please reach out to your ODP Regional Office.

ODP Announcement 22-122 is to remind providers that this is the time of year to being the Provider Qualification process. The Centers for Medicare and Medicaid Services (CMS) require a statewide process to ensure providers are qualified to render services to waiver-funded individuals. The Provider Qualification Process described outlines the steps the Assigned AE and provider must follow to meet these requirements and the steps Supports Coordinators (SCs) must take to transition individuals if needed. This communication does not describe the qualification process for SC organizations

The release of this communication obsoletes ODP Announcement 22-005 Provider Qualification Process. In addition, the qualification process for Providers enrolled in the Adult Autism Waiver can be found in ODP Announcement 20-110.

Providers that are shared across Intellectual Disability/Autism (ID/A) and the Adult Autism Waiver (AAW) must complete the Provider Qualification processes with both the AE for the ID/A waivers and the Bureau of Supports for Autism and Special Populations (BSASP) for the AAW.

Providers must submit the qualification documentation (Posted on MyODP — DP 1059 and the Provider Qualification Documentation Record with all required supporting documentation) by 03/31 of the year that their requalification is due.

Failure to meet this deadline will affect the assigned AE’s ability to requalify the provider by the due date of 04/30. The updated ODP Provider Qualification Documentation Record contains all instructions and qualification requirements.

For inquiries regarding this communication, contact the ODP Provider Qualification inbox.

Image by photosforyou from Pixabay

Thursday, February 2, 2023
1:00 pm – 2:00 pm EST, 12:00 pm – 1:00 pm CST
11:00 am – 12:00 pm MST, 10:00 am – 11:00 am PST

Sarah Economides, PT, DPT, PCS
Kristin Luethke, CTRS

Speaker Bios:

Sarah Economides, PT, DPT, PCS
Sarah Economides is a physical therapist on the inpatient pediatric unit at Madonna Rehabilitation Hospitals, joining the team 11 years ago. Sarah specializes in treating children with severe neurologic and pulmonary disabilities. Prior to joining the Madonna team, Sarah worked in multiple pediatric settings, including NICU, school-based, outpatient, and acute care. She is a Board Certified Specialist in Pediatric Physical Therapy and a Certified Child Passenger Safety Technician (CPST), with additional training for transporting children with special needs. Sarah has extensive experience managing positioning needs for transportation with children and adolescents with physical disabilities. As a graduate of Creighton University’s Doctor of Physical Therapy and Pediatric Physical Therapy Residency programs, she also enjoys collaborating with local PT and PTA programs as a guest lecturer and lab assistant, as well as a mentor for Creighton University’s Pediatric Residency Program.

Kristin Luethke, CTRS
Kristin Luethke is a recreation therapist at Madonna Rehabilitation Hospitals, bringing over 25 years of clinical experience to her team. During her tenure, she has worked across various teams, and in 2001, she settled into her role within Madonna’s pediatric and traumatic brain injury program. As a certified child passenger safety technician, child passenger safety instructor, and a Transporting Children with Special Healthcare Needs instructor, Kristin collaborated with others across the state to create the Nebraska All Kids Ride Safe Program. She also consults with various teams at Madonna to provide safe transportation options for pediatric and adult patients. Kristin graduated from Northwest Missouri State University in 1997.

Objectives:
At the end of this session, the learner will:

  • Discuss the impact of crash mechanics relative to body position, size, and restraints;
  • Identify the importance of car seat evaluation and safety;
  • Advocate for optimal seating and positioning for all children during transportation; and
  • Problem-solve common positioning challenges during transportation for pediatric clients with special health needs.

Audience: This webinar is intended for all members of the rehabilitation team, including medical staff, nurses, physical therapists, occupational therapists, speech language pathologists, licensed psychologists, mental health professionals, and other interested professionals.

Level: Intermediate

Certificate of Attendance: Certificates of attendance are available for all attendees. No CEs are provided for this course.

Registration: Registration is complimentary for members of IPRC/RCPA. Registration fee for non-members is $179. Not a member yet? Consider joining today. Multiple registrations per organization are permitted.

REGISTER

ODP Announcement 22-121 reports that the recording of the presentation provided by the Office of Developmental Programs (ODP) staff during the webinar on December 1, 2022, which was to provide an overview of the heightened scrutiny process and to listen to public comments, is now posted on MyODP.

Public comments are being accepted until 11:59 pm on December 19, 2022. Please review ODP Announcement 22-117: Open for Public Comment: Proposed Heightened Scrutiny Service Locations to be Submitted To CMS. This announcement gives a background description of Heightened Scrutiny, the documents available for public comment, and how to provide public comment

Questions about this communication should be directed via email.

The goal of this series is to provide information on how each diagnosis could impact communication and offer strategies to support effective communication. This series can be found on MyODP under Trainings > Special Populations > Infographics.

Diagnosis or conditions include:

Alzheimer’s Disease DeafBlindness Post-Traumatic Stress Disorder
Angelman Syndrome Disruptive Mood Dysregulation Disorder Reactive Attachment Disorder
Apraxia of Speech Down Syndrome Rett Syndrome
Attention Deficit Hyperactivity Disorder Dyslexia Schizophrenia
Autism Spectrum Disorder Fetal Alcohol Spectrum Disorder Sensory Processing Disorder
Borderline Personality Disorder Hearing Loss Stroke
Central Auditory Processing Disorder Huntington’s Disease Stuttering
Cerebral Palsy Idiosyncratic Speech Tourette Syndrome
CHARGE Syndrome Language Deprivation Traumatic Brain Injury
Communication Disorder Limited English Proficiency Usher Syndrome
Conduct Disorder Long COVID Visual Impairment
Cornelia de Lange Syndrome Multiple Sclerosis
Cortical Visual Impairment Parkinson’s Disease

Please contact the ODP Special Populations Unit via email with any questions.