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