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Policy Areas

The Office of Developmental Programs (ODP) has shared the Medication Administration January – March 2026 Train-the-Trainer Face-to-Face schedule in ODPANN 25-112.

You may register for one of these sessions after completing the course materials in the Train-the-Trainer course on MyODP’s Medication Administration website. Please see the communication for training dates and more information.

The Office of Developmental Programs (ODP) has shared ODPANN 25-111. This communication clarifies new qualification requirements for providers of CPS, In-Home and Community Support and/or Companion services in the Consolidated, Community Living, and P/FDS Waivers that were recently approved by the Centers for Medicare and Medicaid Services (CMS). These requirements do not apply to services rendered by Support Service Professionals through a Participant-Directed Services option.

These amendments include the following provider qualification requirements:

  • Providers newly enrolling to render Community Participation Support, In-Home and Community Support, and/or Companion must provide Office of Developmental Programs (ODP) home and community-based services to a minimum of 3 separate and distinct participants in the first fiscal year after enrollment.
  • Starting July 1, 2026, currently enrolled providers must render ODP home and community-based services to a minimum of 3 separate and distinct participants each fiscal year. ODP will use the provider’s Master Provider Index number to determine if the provider is rendering any ODP waiver services to a minimum of 3 separate and distinct participants.
  • Additionally, the provider must render ODP home and community-based services each quarter.

Please review the announcement for more details.

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At the December 4, 2025, Medicare Payment Advisory Commission (MedPAC) annual session on payment adequacy for Medicare providers, draft fiscal year (FY) 2027 payment recommendations were issued. The recommendations, “Assessing Payment Adequacy and Updating Payments: Inpatient Rehabilitation Facility (IRF) Services,” were shared. Included in their presentation were their findings on admissions, financial performance by IRF provider type, quality metrics, and other relevant data points. In addition to the payment-focused sessions, the meeting included a general session on post-acute care trends and “key issues,” which compared various patient- and payment-focused data across IRFs, skilled nursing facilities (SNF), and home health agencies (HHA).

During the IRF payment session, MedPAC advanced a draft recommendation calling for Congress to reduce the 2026 Medicare base payment rate for IRFs by 7 percent in FY 2027. This draft recommendation is identical to last year’s recommendation and marks an increase over the FY 2025 recommendation (a 5% cut to the Medicare base payment rate) and the FY 2024 finalized recommendation (3% cut).

MedPAC’s recommendations are advisory in nature, and most of MedPAC’s work can only be implemented via Congressional action. RCPA will monitor the status of these recommendations through close collaboration with the American Medical Rehabilitation Providers Association (AMRPA).

Message from the Office of Mental Health and Substance Abuse Services (OMHSAS):

The Pennsylvania Department of Human Services’ (DHS) Office of Mental Health and Substance Abuse Services (OMHSAS) is issuing the bulletin OMHSAS-25-05 “Behavioral Health Clinic Services Provided Outside of the Clinic,” effective November 12, 2025, following changes to Federal Regulation 42 CFR 440.90(d).

OMHSAS 25-05 announces an amendment to Pennsylvania’s Medicaid State Plan which allows all behavioral health clinics that are enrolled in the Medical Assistance (MA) Program, who deliver services through the fee-for-service and managed care systems, to provide clinically appropriate services outside of the clinic. Behavioral health clinics include psychiatric outpatient clinics, outpatient drug and alcohol clinics, and methadone maintenance clinics.

Furthermore, OMHSAS-25-05 also announces the abrogation of 55 Pa Code §§ 1153.14(6) (relating to noncovered services) and 55 Pa. Code 1223.14(11) (relating to noncovered services) by Act 46 of 2025.

The guidance in OMHSAS-25-05 is separate from any “telehealth only” licensure and guidance that may be in place. The changes discussed in this bulletin also do not apply to the existing Mobile Mental Health Telehealth (MMHT) services.

Questions and comments can be directed to OMHSAS via email. RCPA members can also contact RCPA COO and MH Policy Director Jim Sharp with any questions.

Photo by Tai's Captures on Unsplash

The Office of Developmental Programs (ODP) has shared ODPANN 025-110. This communication announces the availability of the Center for Disease Control (CDC) data website for Flu, Respiratory Syncytial Virus (RSV), and COVID-19, as well as provide updated information about respiratory illness prevention strategies, including available vaccinations.

The CDC reports that influenza hospitalizations are increasing nationally, RSV hospitalizations are increasing in the Southeastern and Southern states, and COVID-19 hospitalizations are low. Weekly respiratory illness severity updates, hospitalization rates, and other related data trends can be found on the CDC’s website.

Please review the announcement for more details.

Communication Bulletin 00-25-05 was published and shared last week. The purpose of the bulletin was to establish the Office of Developmental Programs’ (ODP’s) policy on communication and assure all individuals have an effective way to communicate.

To further provide access to the bulletin, ODP has shared another version of the bulletin in easier-to-understand terms and with pictures. This version will be available on MyODP as an attachment to the original bulletin communication released on December 1, 2025.

The following bulletins below are no longer in use:

  • Office of Developmental Programs 00-14-04, Accessibility of Intellectual Disability Services for Individuals Who Are Deaf
  • Office of Developmental Programs 00-08-18, Communication Supports and Services