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On Friday, November 1, the Centers for Medicare & Medicaid Services (CMS) released an anticipated Final Rule titled “CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS 1809-FC),” which includes three new exceptions for the federal “four walls” rule. At present, the “four walls” rule prohibits Medicaid payment for clinic services when both the practitioner and individual receiving service are outside of the “four walls” of the clinic unless the services are being provided to unhoused individuals (such as through street medicine). The new exception for Indian Health Services and Tribal Facilities is required nationally. The exceptions for Behavioral Health Clinics and Rural clinics are optional. States who determine that their Behavioral Health Clinic and/or Rural Health Clinic populations served meet the four criteria established by CMS (see page 1323 of the final rule) must submit a Medicaid State Plan Amendment (SPA) and receive approval from CMS for these exceptions to be in place for their state.
The Office of Mental Health and Substance Abuse Services (OMHSAS) had been working toward a short-term state level solution to the four walls issue for both Outpatient Psychiatric Clinics and Drug and Alcohol Clinics. However, now that a long-term federal option has been made available, the team in OMHSAS will be pivoting to pursue this newly available federal exception for Behavioral Health Clinics. While OMHSAS is still in the process of developing a timeline for the new State Plan Amendment, their team will be working on this as a top priority, with the goal of having a SPA in place in early 2025.
It has been confirmed that OMHSAS will not be shifting their current enforcement policy around the four walls while they work through getting this waiver in place. RCPA will continue its collaboration with OMHSAS on the process as this move forwards. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.
For additional information, please see the following:
Mark your calendars and plan to join IPRC for our exciting 2025 educational webinar series! Complimentary registration for all IPRC webinars is a benefit of your RCPA/IPRC Membership.
Thursday, January 16, 1:00 pm – 2:00 pm EST
Neuro-Opthalmic Rehabilitation
Friday, February 7, 1:00 pm – 2:00 pm EST
POTS (Postural Orthostatic Tachycardia Syndrome)
Monday, March 3, 12:00 pm – 1:00 pm EST
Data-Driven Decision Making
Monday, March 24, 12:00 pm – 1:00 pm EST
Evidence-Based Practice: A Clinical Perspective
Tuesday, April 15, 11:00 am – 12:00 pm EDT
Part 1: Motivational Interviewing with Children
Tuesday, April 22, 11:00 am – 12:00 pm EDT
Part 2: Additional Strategies for Patient Engagement
Tuesday, May 20, 1:00 pm – 2:00 pm EDT
Treating FND: Functional Neurologic Disorder
Thursday, September 4, 12:00 pm – 1:00 pm EDT
The Therapy Intensive Model
Tuesday, October 7, 11:00 am – 12:00 pm EDT
Treating Non-Accidental Trauma
Monday, November 3, 12:00 pm – 1:00 pm EST
The Intersect of Functional Imaging and Clinical Presentations
Monday, December 8, 2:00 pm – 3:00 pm EST
Treating Pediatric Burns
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.
Wednesday, November 6, 2024
12:00 pm – 1:00 pm EST; 11:00 am – 12:00 pm CST;
10:00 am – 11:00 am MST; 9:00 am – 10:00 am PST
Register Here
Kelsey Titgen, PT, DPT
Rachel Stanley, OTR/L
Presenter Bios:
Kelsey Titgen, PT, DPT
Kelsey earned her Doctorate of Physical Therapy from Emory University in 2018. Since graduating, she has worked in the acute care rehabilitation departments at Children’s Healthcare of Atlanta Egleston and Arthur M. Blank hospitals. In her tenure at Children’s Healthcare of Atlanta, she has treated patients in all inpatient units of the hospital, including PICU, multi-trauma, brain injury, oncology, and technology-dependent ICU. Over the past three years, Kelsey has taken on a primary and co-lead role in the cardiac intensive care unit and step-down unit, focusing on mobilizing patients on ECMO, various types of ventricular assist devices, and those recovering from open-heart surgery. She most enjoys her work supporting pediatric patients with congenital heart defects.
Rachel Stanley, OTR/L
Rachel graduated from Brenau University in 2020 with a degree in Occupational Therapy. After receiving her degree, she joined the Children’s Healthcare of Atlanta acute care rehabilitation team. Rachel primarily treats patients in the PICU and serves as an OT representative on the ICU Liberation Committee, a multi-disciplinary hospital committee focused on minimizing the effects of pain, agitation/sedation, delirium, immobility, and sleep disruption. Rachel is passionate about working with patients in the intensive care unit, including those on ECMO, and is dedicated to advancing the ICU Liberation program at Children’s Healthcare of Atlanta.
Objectives: At the end of this session, the learner will:
Audience: This webinar is intended for all interested members of the rehabilitation team.
Level: Beginner-Intermediate
Certificate of Attendance: Certificates of attendance are available for all attendees. No CEs are provided for this course.
Complimentary webinars are a benefit of membership in IPRC/RCPA. Registration fee for non-members is $179. Not a member yet? Consider joining today.
Microsoft Tech for Social Impact is dedicated to providing affordable and accessible technology to help nonprofits of all sizes achieve their mission. That’s why they offer grants and discounts for their products and services to eligible nonprofits around the world, including solutions like Azure, Dynamics 365, and Microsoft 365.
Download the Microsoft Nonprofit Grants Proposal to learn about their most popular nonprofit offers:
Get started with free technology grants and discounts!
Get grants and discounts across Microsoft’s Cloud products, including Microsoft 365, Azure, and Dynamics 365. To get started, register and confirm your organization’s eligibility. Already registered as a nonprofit? Login to your Microsoft Nonprofit page and access Admin Center. Watch our guided demo to help you get your free Microsoft 365 licenses.
Learn more about nonprofit offers:
For general information on eligibility, accessing offers, the Nonprofit Hub, and technical support, please submit your question, and a Microsoft representative will contact you shortly. Contact us.
The Office of Mental Health and Substance Abuse Services (OMHSAS) recently sent out information to County Mental Health Administrators to alert each of them to an upcoming funding opportunity. This funding supports OMHSAS’s efforts to equip the ICWCs for alignment with the Certified Community Behavioral Health Clinics (CCBHC) model, which includes providing robust crisis services. Additional information regarding the OMHSAS plan for the expansion of the ICWC model is forthcoming, but clinics should still take advantage of this potential opportunity. The ICWCs are encouraged to contact their county representatives to express interest in participating in the start-up project for walk-in crisis services.
An informational meeting for County Partners will be held on Wednesday, October 23, 2024. Please do not submit any applications to OMHSAS, as the application must come from the County Partner(s) in order to be considered.
If you have any further questions, please reach out to your County Partner. Please see below for the information that was shared.
Upcoming Funding Opportunity: Emergency Behavioral Health Crisis Walk-In Centers (EBHC Walk-In Centers)
OMHSAS is excited to announce a new funding opportunity for County Mental Health Administrators aimed at supporting the establishment of Emergency Behavioral Health Crisis Walk-In Centers (EBHC Walk-In Centers). This opportunity offers up to five grants, with a total funding request of up to $3 million per project. Each grant will consist of a blend of $1 million in state funds and $2 million from the federal Community Mental Health Services Block Grant (CMHSBG).
Funding Breakdown:
Key:
If you have further questions, please contact RCPA COO and Mental Health Director Jim Sharp.