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Children's Services

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The Independent Regulatory Review Commission (IRRC) has published their comments on the proposed Licensure of Crisis Intervention Services regulations, summarizing the comments submitted by the stakeholder community during the public comment period. As part of the IRRC’s regulatory process, OMHSAS will have to address and clarify any questions that have been submitted.

Similar to RCPA’s public comments, the IRRC response highlights concerns regarding the proposed rulemaking in the following areas:

  • Potential issues with “one-size-fits-all” approach to crisis intervention.
  • Lack of availability of qualified staff and how to pay for them.
  • Elimination of an “in-between” level of care by imposing hospital-like standards that do not align with current outpatient structures.
  • Possibility of inadequate government funding to cover providers’ implementation costs.
  • Lack of inclusion and integration with law enforcement, first responders, 911 operators, and 988 lifeline centers.

In support of RCPA’s recommendation, the IRRC comments also urge the Department to reconvene the stakeholder work group that had been assembled in 2021, especially given the drastic shift in the mental health landscape that has occurred since the group last met.

Please contact Emma Sharp with any questions.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the proposed Mental Health Procedures regulations, which are open for public comment. The posting on the Independent Regulatory Review Commission (IRRC) website can be found here.

The proposed regulations are to be in compliance with Act 32 of 2022. OMHSAS is choosing to go beyond the updates required by Act 32 and is doing a full alignment of the chapter with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to increase the clarity of the regulations for stakeholders.

Starting December 6, 2025, and closing January 5, 2026, the public may submit written comments regarding the proposed rulemaking to the Department via email. Please be aware that all public comments must be published verbatim on the IRRC website with the name of the commenter included. OMHSAS fully supports and encourages individuals with lived experience to comment on the regulation. However, please ensure you are comfortable with the content of your comment being made public, with your name attached to it.

RCPA has conducted an internal review of the proposed regulations and is seeking member feedback and comments to be included in our submission. Members are encouraged to review and provide recommendation and guidance on the impacts of the proposed regulations on your organization.  Agencies may submit separately or in conjunction with RCPA.

Comments may also be submitted to RCPA COO and Mental Health Policy Director Jim Sharp by January 2, 2026, OR to the following address:

Department of Human Services
OMHSAS – Bureau of Policy, Planning, and Program Development,
Attention: BPPPD
Commonwealth Tower, 11th Floor
303 Walnut Street
Harrisburg, Pennsylvania 17105

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Tuesday, January 6, 2026
1:00 pm – 2:00 pm ET; 12:00 pm – 1:00 pm CT;
11:00 am – 12:00 pm MT; 10:00 am – 11:00 am PT
Register Here

Please join us as the IPRC hosts special guest Terry Carolan from CARF International, who will share the new Disorders of Consciousness Program Standards.

Presenter Bio:

Terrence Carolan
Terrence Carolan, Managing Director of the Medical Rehabilitation and Aging Services accreditation areas at the Commission on Accreditation of Rehabilitation Facilities (CARF), has more than 20 years of experience as a provider, administrator, and educator in the human services field. Terry joined CARF after working in clinical and administrative leadership positions within Select Medical’s Inpatient Rehabilitation Division and the Kessler Institute for Rehabilitation since 2001. Terry was a CARF surveyor for 10 years and holds a degree in physical therapy from Simmons College in Boston. He also recently completed his master’s degree in business administration from the University of Wisconsin-Eau Claire.

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

  • Describe recent research and guidance on the treatment of individuals with Disorders of Consciousness (DoC);
  • Discuss how CARF International has responded to guidance from the field to create Disorders of Consciousness Program Standards; and
  • Analyze how new DoC accreditation and recent research will enhance access to rehabilitation for children with DoC in the future.

Audience: This webinar is intended for all interested members of the rehabilitation team; attendees do not need to be CARF certified in order to attend.

Level: Beginner-Intermediate

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

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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.

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RCPA is excited to host a membership benefits webinar on Wednesday, January 14, 2026, at 1:00 pm, as an opportunity for members to orient themselves with all that RCPA membership includes. This is not just for new and future members. For current members, there may be benefits associated with our membership that you may not be aware of, including targeted meetings and groups that are held throughout the year.

Registration is required; please register here to attend the webinar. Attendees will have the opportunity to:

  • Virtually meet the dedicated RCPA Policy Staff and RCPA lobbyists;
  • Discuss the 2026 Legislative and Administrative priorities;
  • Preview RCPA divisional committee and subcommittee meetings and what they offer;
  • View the RCPA member-only website;
  • Review exclusive yearly educational and networking events; and
  • Understand the value of the National Council and ANCOR memberships included with RCPA membership.

Visit the RCPA member benefits web page for more information, or contact Tieanna Lloyd for benefit details.

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On November 13, 2025, President Trump signed the executive order “Fostering the Future for American Children and Families,” an initiative to be led by the Office of the First Lady. The order is aimed at supporting children transitioning out of foster care into adulthood by modernizing the out-of-date child welfare system.

The Secretary of Health and Human Services must take the appropriate actions for the following within the next 180 days:

  • Update regulations, policies, and practices to improve data collection;
  • Promote modernization of child welfare information systems;
  • Expand States’ use of technological solutions; and
  • Publish an annual scorecard to measure and evaluate State-level achievement.

The HHS Secretary, in coordination with the First Lady and heads of other applicable offices, are to establish a “Fostering the Future” initiative to develop partnerships with agencies, private sector organizations, academic institutions, and non-profit entities to aid in the transition out of the foster care system. The order also calls for the development of an online platform to assist in the navigation of the transition, and an increase in the role of Education and Training Vouchers and educational scholarships. This initiative will be funded by the reallocation of funds returned by the States from Federal programs designed to assist in the transition out of foster care, but further details have not been clarified.

The final section of the Executive Order outlines the role of HHS in coordination with the Director of the White House Office of Faith and the White House Office of Intergovernmental Affairs, to:

“(a) take appropriate action to address State and local policies and practices that inappropriately prohibit participation in federally-funded child-welfare programs by qualified individuals or organizations based upon their sincerely held religious beliefs or moral convictions; and (b) take appropriate actions to increase partnerships between agencies and faith-based organizations and houses of worship to serve families whose children have been placed in foster care or are at risk of being placed in foster care.”

This order explicitly encourages partnerships with faith-based organizations and removes barriers for faith-motivated foster/adoptive families. While faith-based groups currently play a significant role in the foster care system, this order increases ethical tensions regarding what safeguards exist to protect foster youth who come from non-religious or different religious/cultural backgrounds from pressure to conform.

Further concerns with this order lay with language regarding “biological truths.” This term implies that LGBTQIA+, non-binary, or gender non-conforming individuals somehow conflict with science and is used to delegitimize trans and nonbinary identities. There is concern that partnerships with faith-based and other community organizations may not align with youth’s identities, especially older youth in the LGBTQIA+ community. Further guidance will be needed to ensure that any partnerships with faith-based organizations must be voluntary and respectful of each youth’s identity.

Additional concerns arise regarding equity of family selection and pairing/matching systems. Preferential selection of faith-based foster/adoptive families may lead to “religious filtering.” Potential foster/adoptive parents may be selected not on their capacity to care or their qualifications, but on religious affiliation or ideological alignment — which could lead to unfair exclusion of qualified non-religious or differently religious households. Upcoming policy changes could undermine equity and non-discrimination in the foster care system.

RCPA will keep abreast of developments on this issue and further guidance for agencies and individuals involved in the foster care system.

Please contact Emma Sharp with any questions.

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