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Criminal Justice

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Image by Gerd Altmann from Pixabay

RCPA is excited to host a Membership Benefits webinar on Wednesday, January 15, 2025, 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 occur throughout the year.

Registration is required; please register here to attend the webinar. Items we will review include the below and much more:

  • Virtually meet the dedicated RCPA Policy Staff and RCPA lobbyists;
  • Discuss the 2025 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 Association 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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Join Drexel University Behavioral Healthcare Education’s visiting resident Radhika Rani, DO, for a special presentation titled “Mental Health Care for Migrants and Refugees in the U.S.: Culturally Informed Practices.”

Thursday, November 21, 2024
9:00 am – 12:15 pm ET
3 CE Hours
Live Webinar

This course aims to provide behavioral health professionals with the knowledge and skills needed to effectively address the mental health needs of migrant and refugee populations in the United States. Participants will explore the unique challenges and stressors encountered by these groups, including trauma, displacement, acculturation, and systemic barriers to care. Emphasis will be placed on culturally informed, trauma-sensitive approaches to diagnosis and treatment. In addition, the course will explore the legal, social, and policy implications impacting migrant and refugee communities as well as outline strategies for patient advocacy. Participants will also be able to gain practical skills while reflecting on personal biases and assumptions to foster more inclusive care and improve patient outcomes.

Register at the BHE website.

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The Center for Medicare and Medicaid Services (CMS) has released the Physician Fee Schedule CY 2025 Final Rule. You can view CMS’ press release, fact sheet, and final rule page in the Federal Register for more information. There were critical areas addressed in this year’s Physician Fee Schedule (PFS), including:

  • The extension of some telehealth flexibilities permitted under CMS’ authority absent Congressional action;
  • Updated payment for social determinants of health risk assessments as a part of Opioid Use Disorder intake activities furnished at Opioid Treatment Programs (OTP);
  • The establishment of a new add-on code to account for coordinated care, referral services, and peer supports at OTPs;
  • Payment for safety planning intervention and post-discharge follow-up;
  • The establishment of six G codes that mirror current interprofessional consultation Common Procedural Terminology codes used by practitioners who are eligible to bill E/M visits; and
  • Recognition of responses to CMS’ request for information on Certified Community Behavioral Health Clinics.

For the OPPS Final Rule, please see links to CMS’ press release, fact sheet, and final rule page in the Federal Register. Some highlights from this final rule include:

  • The maintenance of the Partial Hospitalization Program and Intensive Outpatient Program rate structures;
  • Narrowing the definition of “custody” in Medicare’s payment exclusion rule to mitigate barriers to Medicare access by individuals who have recently been released from incarceration or are on parole, probation, or home detention; and
  • Changes to Medicaid regulation, allowing states implementing the Medicaid clinic services benefit to cover clinic services outside the “four walls” of behavioral health clinics.

If you have any further questions regarding these final rulings or the application of the “four walls” impacts on Pennsylvania, please contact RCPA COO and Mental Health Director Jim Sharp.

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Image by DarkmoonArt_de from Pixabay

The Office of Mental Health and Substance Abuse Services (OMHSAS) has announced the 2025 quarterly meeting dates for next year’s OMHSAS Stakeholder Webinars and asks that you mark your calendars.

2025 OMHSAS STAKEHOLDER WEBINAR DATES:

  • January 30, 2025 — 3:00 pm – 4:00 pm
  • April 24, 2025 — 3:00 pm – 4:00 pm
  • July 17, 2025 — 3:00 pm – 4:00 pm
  • October 23, 2025 — 3:00 pm – 4:00 pm

In the meantime, if you have suggestions for agenda topics for January’s webinar, please submit them via email. We will monitor the account and will only reply to the sender if more information is needed. Responses will not be provided if additional information is not needed.

Please note that webinar links will be provided closer to each of the meeting dates as shown above.

Thank you for your review and please – SAVE THE DATE.

If members have any questions, please contact RCPA COO and Mental Health Director Jim Sharp.

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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:

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