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Counties Face Uncertainty on State Funding for Mental Health Services
By Robert Swift
Capitolwire Staff Reporter

HARRISBURG (Aug. 2) — County officials face some uncertainty in running their basic mental health programs upon learning they get flat funding under the new state budget.

Getting a level amount of state aid means counties will have difficulty reducing waiting lists for services which are widespread, hiring to address staff shortages, and expanding services to meet various mental health needs, said Lisa Schaefer, executive director of the County Commissioners Association of Pennsylvania, on Tuesday.

“We are certainly disappointed,” she said. “There is certainly a lot of good increased funding could do.”

CCAP learned this week there is no increase in that line item as analysis continues with the Fiscal Year 2022/23 budget enacted early last month.

CCAP is part of a coalition that lobbied this year to end level state funding for basic county mental health services for the past 11 years. Gov. Tom Wolf proposed a $36.6 million increase to restore much of a decade-old cut in state aid to county-run mental health programs, but that didn’t make the final budget enacted last month.

Instead the budget provides an additional $53 million for assorted mental health-related needs, including the county programs and state-run hospitals.

“Counties can continue to get grants for mental health programs from the Department of Human Services under the Community Mental Health Services Block Grant (CMHSBG),” said DHS spokesman Brandon Cwalina.

“This funding supports counties in their planning and implementation of mobile crisis services, as well as crisis receiving and stabilization services, that meet national standards for crisis intervention services,” he said.

“It can also be used to support service expansion efforts that ensure a full continuum of community crisis intervention services for anyone regardless of insurer or ability to pay…” said Cwalina. “Counties have until 2025 to use the funds available through these CMHSBG grant allocations to continue the building of crisis mental health service infrastructures across the commonwealth.”

And the budget directs $100 million in unspent federal COVID relief funds for general mental health programs and an additional $100 million in COVID funds for school mental health grants.

The one-time funding comes after lawmakers of both parties said this year that more needs to be done to address mental health issues among Pennsylvanians.

Counties could get a share of that, but Schaefer said annual funding is needed to rebuild the counties network of mental health programs.

The $100 million for general mental health programs can’t be spent until a new special state commission meets and makes recommendations for to how to spend it the money and the Legislature passes enabling legislation.

Whether that happens during the remainder of Gov. Tom Wolf’s term or after a new governor takes office next January is uncertain.

The 24-member Behavioral Health Commission for Adult Mental Health is charged with considering funding for the following areas: telemedicine services, mental and behavioral payment parity, workforce development and retention, expansion of peer support services, crisis services, integration of behavioral support and substances abuse disorder treatment, cultural issues in providing behavioral health care, impact of health on behavioral health, intersection of behavioral health and the criminal justice system, and timely delivery of psychiatric care.

The commission composed of state officials and legislative appointees, is supposed to hold its first meeting by September and hold at least two meetings, one with rural care providers and law enforcement and one with urban or suburban providers and law enforcement.

Counties will have a representative on the commission who can advocate for funding, said Schaefer.

“The $100 million in ARPA funding and the grants available through the CMHSBG are a start, but further investment will be necessary to support growing behavioral health care needs,” said Cwalina. “The Wolf administration is encouraged by the General Assembly’s recognition of ongoing need through their establishment of the Behavioral Health Commission for Adult Mental Health, and we hope the recommendations adopted by the commission will be considered for future investments outside of ARPA funds.”


RCPA has been asked to be a part of the Behavioral Health Commission process and will continue its collective efforts with the Mental Health Safety Net Coalition to create sustainable pathways for all mental health funding platforms in Pennsylvania.

If you have any questions, please contact your RCPA Policy Director.

On Tuesday, August 2, RCPA member Pyramid Healthcare joined the Department of Drug and Alcohol Programs (DDAP) to encourage use of the free and confidential Addiction Treatment Locator, Assessment, and Standards (ATLAS) platform in Pennsylvania.

ATLAS evaluates addiction treatment facilities’ use of evidence-based best practices based on the Shatterproof National Principles of Care, includes an assessment to understand the appropriate level of care, and offers an easy-to-use dashboard to allow those in need and their loved ones to search for and compare facilities using criteria such as location, services offered, and insurance accepted so they can find the best treatment for their unique needs. ATLAS is fully available in English and Spanish.

Founded in 1999 with headquarters in Altoona, Pyramid Healthcare is recognized as one of the largest, full-continuum providers of substance use treatment for adults and adolescents with 31 program locations in the commonwealth and 85 across seven eastern states.

“As a participating provider, Pyramid Healthcare proudly joins DDAP in support and promotion of ATLAS as an invaluable resource designed to bridge the gap between treatment access and client engagement within the commonwealth by helping individuals navigate available behavioral health treatment options that best fit their unique recovery needs,” said Jonathan Wolf, CEO of Pyramid Healthcare.

A multimedia package from the event is available online.

ODP Announcement 22-086 informs all provider agencies employing DSPs that the Human Services Research Institute (HSRI) will keep the portal for completing the 2021 National Core Indicators® (NCI) Staff Stability Survey open for an additional week. The portal will close on Monday, August 8, 2022.

HSRI is aiming for a 5% or lower margin of error for each participating state. The lower the MoE, the more representative and impactful the data will be. Pennsylvania currently has a 6.24 margin of error, and the Office of Developmental Programs (ODP) would like to see it reach the recommended level since it is within reach.

Therefore, ODP encourages eligible provider agencies to complete the survey if they have not already done so. Thank you to provider agencies that have completed the 2021 NCI® Staff Stability Survey. ODP will share the Staff Stability Survey Report when HSRI issues it.

For questions, contact Ms. Lee Stephens, ODP IM4Q/NCI Statewide Lead.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2023 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was published in today’s Federal Register. Some of the key provisions contained in the final rule are provided below:

Final FY 2023 Payment Updates
CMS estimates overall payments to IRFs will increase by 3.2 percent compared to FY 2022 levels (higher than the 2 percent estimated in the proposed rule). This update is the result of a 4.2 percent update to the IRF market basket reduced by a 0.3 percent productivity adjustment, which is required by law. As a result of this market basket increase and a few small budget neutrality adjustments, the standard payment conversion factor will increase from $17,240 to $17,878. ‎CMS is also adjusting the outlier threshold, which it says will reduce overall payments by 0.6 percent. CMS says the 3.2 percent overall increase will result in $275 million in increased payments to IRFs compared to 2022.

Proposed Expansion of IRF Transfer Policy to Include Home Health Services
CMS issued a Request for Information (RFI) in the proposed rule regarding the potential expansion of the current IRF transfer payment policy to include home health services. For background, IRFs receive a reduced case mix group (CMG) payment rate under the IRF transfer policy when the patient’s discharge occurs earlier than the average length of stay (for that respective CMG and tier) and the patient is discharged to a certain setting (an IRF, acute-care hospital, LTCH, nursing home that takes Medicare and Medicaid payment). The policy currently does not apply to home health.

The RFI in this year’s rule followed a December 2021 Office of Inspector General (OIG) report finding that Medicare could have saved over $993 million had the IRF transfer policy been expanded to include home health services (based on 2017 and 2018 data). The OIG therefore recommends that CMS explore ways to capture early discharges to home health care in the current policy, which CMS referenced in the proposed rule. Following a review of concern cited in stakeholder comments, CMS is not moving forward with any changes to the transfer policy at this time.

IRF Quality Reporting Program Changes & Requests for Information All-Payer IRF-PAI Reporting Proposal
CMS proposed to require collection of the IRF-PAI for all IRF patients, including those without Medicare, beginning with the FY 2025 IRF QRP (with data collection to begin on October 1, 2023). Currently the IRF-PAI is only required to be collected for Medicare Part A (fee-for-service) and Part C (Medicare Advantage) beneficiaries. In response to comments, CMS opted to finalize the proposal but with a revised implementation date. IRFs will now be required to collect IRF-PAIs on all patients, regardless of payer, for the FY 2026 IRF QRP (data collection to begin on October 1, 2024).

RFI on Future QRP Measure Expansions
CMS had issued a Request for Information (RFI) related to measures/concepts for use in the QRP in future years in the proposed rule. The agency specifically requested information on a cross-setting function measure that would include self-care and mobility items, and development of a patient-level COVID-19 vaccination measure. CMS referenced several of AMRPA’s comments, including concerns that IRF stays are typically not long enough to adequately capture COVID-19 vaccination for patients. CMS did not provide a response to comments but affirmed the agency would use the stakeholder feedback to inform future rulemaking.

The Pennsylvania Health Law Project (PHLP) will host a virtual information session on Wednesday, August 10 at 2:00 pm to review upcoming changes to the Physical HealthChoices program. Representatives from the PA Department of Human Services (DHS), PA Enrollment Services, and the Pennsylvania Health Access Network (PHAN) will be available to answer questions during the session. Space is limited, and registration is required.

Examples of the communications that DHS sent to plan participants are here (individuals who are required to change plans) and here (individuals who may but are not required to change plans).