RCPA to Host “The ABCs of ADA and FMLA,” Featuring Michael Cohen
Home Human Resources
HR Committee: November 6 Meeting Follow-Up
Telehealth Update: CMS Eliminates “4 Walls” Rule
Removes Barriers to Delivering Telehealth Outside the Clinics
On Friday, November 1, the US Centers for Medicare and Medicaid Services (CMS) released a final rule for calendar year 2025 that will give states the option to cover Medicaid telehealth behavioral health clinic services delivered outside the “four walls.” Previously, under 42 CFR § 440.90, the “Four Walls Rule,” it was required that during Medicaid outpatient behavioral health clinic telehealth services, either the patient or the clinician had to be physically onsite at the clinic.
CMS waived this requirement during the Public Health Emergency (PHE). Now that the PHE has ended, CMS has released this final rule to allow states to cover behavioral health outpatient clinic services outside the four walls. The final rule should take effect on January 1, 2025. In the meantime, it is the expectation that telehealth services will continue to be delivered as per current operating standards to ensure service access to individuals.
CMS amended the Medicaid clinic services’ regulation to authorize Medicaid coverage for clinic services furnished by IHS/Tribal clinics outside the “four walls” of their facility. In addition, states implementing the Medicaid clinic services’ benefit can opt to cover clinic services furnished outside the “four walls” of behavioral health clinics or clinics located in rural areas. For clinics located in rural areas, based on comments received, CMS is finalizing an approach to defining “rural area” where states will select either a definition used by a federal agency for programmatic purposes, or a definition adopted by a state agency with a role in setting state rural health policy.
For more information, view the CY 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Final Rule (CMS 1809-FC) Fact Sheet and the full Final Rule.
RCPA will be reviewing the implications of this final form ruling for Pennsylvania and our ongoing efforts to expand telehealth services through legislative action. RCPA offers thanks to our members, as well as DHS/OMHSAS, County Primary Contractors, BH-MCOs, the National Council on Mental Wellbeing, and our stakeholder groups and associations for their collaborative advocacy to remove the “4 Walls” barriers to equity and access through telehealth.
If you have any additional questions, please contact RCPA COO and Mental Health Division Director Jim Sharp.
HR Committee: August 7 Meeting Follow-Up Materials Now Available
Final Reminder for RCPA Member Webinar “Generative AI in Healthcare” on June 13
Reminder for RCPA Member Webinar “Generative AI in Healthcare” on June 13
Welcoming ADP as Our Newest RCPA Partner
Through this partnership created exclusively for RPCA members, organizations interested in partnering with ADP can take advantage of pre-established, preferred pricing and monthly promotions designed specifically for our valued RCPA members. Our partner program also includes:
- Free benchmarking (labor cost, compensation, employee benefits, etc.)
- Systems optimization services (system customization, utilization reporting, benefit carrier connections, etc.)
- Dedicated RCPA implementation teams
- Dedicated Service Account Manager.
- For those members who are existing ADP clients looking to enhance their experience/offering, there are options available to you as well.
Currently, ADP has over 45,000 health care & 21,000 nonprofit organization clients. No matter your human services setting – extended care, mental health, substance use disorder, IDD, brain injury, criminal and juvenile justice, medical and pediatric rehabilitation, or physical disabilities and aging services – health care professionals face unique payroll and HR challenges. With ADP, you get comprehensive solutions that can help you find and retain the best talent, support your people, and manage compliance obligations. Spend less time on manual processes and transform your HR operations. ADP’s solutions help you integrate HR systems, time and labor, and payroll so you can focus on what matters: aligning labor, productivity, and patient care.
Your dedicated ADP contact is Brett Ruina, who has been with ADP for the last 7 years, and has worked in the human capital management space for 16.
Brett is based out of Blue Bell, PA and the human services/health care space is near and dear to his heart as he is surrounded by medical professionals in his family. His wife is a nurse practitioner at a local university, his mother-in-law is a dental hygienist (yes, she is his hygienist as well 😊), and his sister-in-law is an ER nurse in the neurotrauma unit of a local hospital. This close to home experience, coupled with the expertise of working with human services/health care organizations over the last 7 years, has him excited to partner with RCPA to help its members navigate all of the challenges that exist in your space today. Below is Brett’s direct contact information, should you want to connect, and he will plan to introduce himself to the membership in the upcoming weeks!
Brett Ruina
ADP Human Capital Management Consultant
[email protected]
267-481-2932 (direct)
RCPA Member Webinar “Generative AI in Healthcare” to Be Held June 13
ADvancing States and the ARPA HCBS TA Collective Announce Release of Report Summarizing State Experiences With ARPA HCBS Initiatives
ADvancing States and the ARPA HCBS TA Collective Announce Release of Report Summarizing State Experiences with ARPA HCBS Initiatives
FOR IMMEDIATE RELEASE
April 23, 2024
CONTACT: Camille Dobson
202-898-2578
ARLINGTON, VA — ADvancing States and our partners in the American Rescue Plan Act (ARPA) home and community-based services (HCBS) Technical Assistance Collective (TA Collective) are proud to release a report sharing findings about states’ experience in implementing their ARPA HCBS initiatives. While the ARPA infusion of federal dollars into HCBS provided an historic opportunity to try bold, new approaches to supporting people in their homes and communities, states were challenged to make systemic improvements given the time-limited nature of the federal funds.
To gather insights into states’ experiences in implementing their ARPA HCBS spending plans, the TA Collective fielded a national survey in early 2024 that aimed to identify successful strategies used by states implementing their ARPA HCBS spending plans, as well as any barriers hindering their success. Based on responses to that survey, this report highlights the challenges and barriers states faced in thoughtfully executing their initiatives in the midst of a public health emergency. The thirty-three states that responded to the survey shared the top barriers to implementing their projects as planned. These barriers include:
- Delays in obtaining approval from CMS for both their spending plans and the necessary federal authorities to implement those plans;
- Lack of staff capacity to design and implement complex initiatives;
- The time it takes to complete state procurement processes to implement projects; and
- The need to secure legislative approval and/or budget authority before beginning work.
The report also suggests ways to make any future time-limited investments in the HCBS system more effective, including giving states more time to implement, easing the CMS approval process and providing resources to both states and CMS. Moreover, any future investments should be accompanied by a federal evaluation to glean insights into successful interventions that could be replicated across the country.
While this report highlights challenges and lessons learned, it should be noted that, against all odds, states created transformational change with their ARPA spending plan initiatives. Our hope is that this report — and the recommendations contained therein — serves as a roadmap for any future federal investment in the HCBS system.
This report is also informed by the TA Collective’s work supporting states with their ARPA initiative planning, implementation, and evaluation activities and by observations and analysis of state and federal ARPA HCBS activities. It builds upon the TA Collective’s past work including, Efforts to Evaluate the Impact of ARPA HCBS Investments, an issue brief examining state evaluation approaches, and a summary of the work of the HCBS Sustainability Summit, which provided valuable context on sustaining the HCBS commitment fostered by ARPA investments. Both reports can be found here.
We are grateful to The John A. Hartford Foundation, the Care for all with Respect and Equity (CARE) Fund, The SCAN Foundation, and the Milbank Memorial Fund for their support in making the work of the TA Collective possible.
RCPA Membership Renewal Period Now Open
RCPA’s 2024/25 membership year begins July 1, and this week marks the beginning of our membership renewal period. You can download the membership applications directly from the RCPA website on our Join/Renew page. Dues are owed by July 1, 2024.
Please contact Tieanna Lloyd at (717) 963-3609 or via email with any questions, and thank you for your continued support of the association. We look forward to working with you during the 2024/25 membership year!
