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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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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.

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Photo by Glenn Carstens-Peters on Unsplash

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:

  • Improve cybersecurity, reduce costs, and empower staff and volunteers to work from anywhere with Microsoft 365 and Microsoft Teams. Free for up to 10 users and discounted pricing of $5.50 (USD) per user/month for additional users.
  • Move to the Cloud with the Azure grant for nonprofits. Leverage $2,000 (USD) Azure services credits per year and access the complete portfolio of Azure products and cloud services.
  • Easily develop mobile and web apps to support your mission — even if you have no technical or development experience. Power Apps is now free for up to 10 users with discounted pricing of $2.50 per user per month for additional users.

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.

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RCPA staff and Conference Committee members are grateful to all of our attendees, speakers, sponsors, and exhibitors for a great experience at the Hershey Lodge this past September. We are happy to report that we had 800 people in attendance throughout the week!

Participants were able to hear from over 150 speakers, and RCPA was able to record many of the workshops as well as the keynote and plenary sessions. The recordings are available to attendees who previously registered for the conference in the mobile app. For those who are interested in earning CEs, you can earn over 110 credits!

We were honored to host 86 exhibit booths in our Connections Hall, representing a variety of services and products from pharmacy initiatives to technology, furniture to HR services, insurance and electronic health record systems to education, and so much more.

Our conference in 2025 will be held in September once again! We ask you to save the date — the 2025 RCPA Conference will be held September 9 – 12, 2025.

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Image by Dirk Wouters from Pixabay

The Pennsylvania Commission on Crime and Delinquency (PCCD) is partnering with the Department of Human Services, Office of Mental Health and Substance Abuse Services, and the Council of State Governments Justice Center (CSG) to support a new statewide crisis intervention and response services assessment, gap analysis, and strategic planning initiative. This project will explore the intersections of the justice system and crisis response with a specific emphasis on crisis intervention team programs and their adherence to the Memphis Model, and is a component of PCCD’s federal Byrne State Crisis Intervention Program Funding Plan.

Through this assessment, it is essential to hear from stakeholders at the local and state levels across the behavioral health and criminal justice systems, including community members and people with lived experience, to identify assets, gaps, and challenges within the current crisis landscape. To accomplish this, CSG will be hosting 13 listening sessions, each for specific stakeholders, starting on Oct. 21, 2024.

More information about the project, including a direct link and QR code for listening session registration, is available. If you have any questions, please email Michael Leister.

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Providers who hold a license to operate a facility licensed by the Pennsylvania Department of Human Services (DHS) are being notified of a change to the Civil Rights Compliance process. There is a new Civil Rights Compliance form when submitting a new licensing application as well as a new Civil Rights Compliance Renewal form when submitting a licensing renewal application.

Entities seeking a new license will utilize a Civil Rights Compliance (CRC) form (HS2126). The prior Civil Rights Compliance (CRC) form is now obsolete and will be returned back to providers. This form must be included in the packet submitted as part of any new license request. The new application, supporting documents, and CRC form must be emailed to the DHS office that issues your license; the email address can be found in the chart below.

Entities licensed by OCDEL or ODP who use CLS or PELICAN to submit new applications must submit the form by email. The CRC forms are not part of the electronic CLS/PELICAN new application process. The updated CRC form for new applications can be found on the DHS website under the “Application for License” page.

For licensing renewals, a licensee will now submit a CRC Renewal form (HS 2125). The prior Attestation form is now obsolete and will be returned back to providers. The renewal form must be submitted as part of a renewal licensing application, and the renewal notice will still be sent out 130 days prior to expiration. The renewal application must be emailed to the DHS office that issues your license; the email address can be found in the chart below.

Entities licensed by OCDEL or ODP who use CLS or PELICAN to submit renewal applications must submit the renewal by email. The renewal is not part of the electronic CLS/PELICAN renewal application process. The CRC form for can be found on the DHS website under the “Application for License” page.

Previously, the DHS Bureau of Equal Opportunity (BEO) would issue you a letter verifying that you are compliant with applicable civil rights laws. With the new process, a letter from BEO will no longer be sent out to licensed entities. Instead, the issuance of the new license or renewal license will indicate that your CRC form or renewal form submission was approved. If there are issues or questions on the submitted CRC or renewal form, a staff member from BEO or DHS will contact you.

If your license is issued by… Submit your application AND your CRC form (if new license)
or  CRC Renewal (if license renewal) to:
The Bureau of Human Services Licensing (Renewals) – PCH & ALR [email protected]
For NEW applications for Personal Care Homes or Assisted Living Residences Send the application, supporting documents, Civil Rights Compliance Form (HS2126) and the application fee, check or money order payable to DHS to:

Via USPS:                              Or via courier:

DHS/BHSL                                 DHS/BHSL

Room 623                                  Health & Human Services Bldg.

PO Box 2675                              Rm 623

Harrisburg, PA 17105-2675        625 Forster Street

Harrisburg, PA 17120
The Office of Children, Youth, and Families [email protected]
The Office of Mental Health and Substance Abuse Services [email protected]
The Office of Developmental Programs* [email protected]
The Office of Child Development and Early Learning* Child care providers should include their MPI number in the subject line and email the appropriate regional office:  

Northeast Region:

[email protected]

Central Region:

[email protected]

Counties: Dauphin, Cumberland,

Lancaster, York, Adams, Lebanon and York

[email protected]

Counties: Snyder, Perry, Juniata, Centre, Mifflin, Tioga, Lycoming, Northumberland, Union and Clinton

South Region:

[email protected]
Western Region:

[email protected]

Counties: Allegheny, Armstrong, Beaver, Butler, Cameron, Clarion, Clearfield, Crawford, Elk, Erie, Fayette, Forest, Greene, Indiana, Jefferson, Lawrence, McKean, Mercer, Potter, Venango, Warren, Washington and Westmoreland

[email protected]

Counties: Bedford, Blair, Cambria, Franklin, Fulton, Huntingdon and Somerset

*Licensees who use CLS or PELICAN to submit renewal applications must submit the renewal by email. The renewal is not part of the electronic CLS/PELICAN renewal application process.

The new process is effective on Tuesday, October 1, 2024. Existing licensees and applicants must begin following the new process on or before that date.

If you have any questions about the new process, please contact the applicable DHS office, DHS Human Services Licensing Office at 717-705-0383, or, if your facility is a childcare facility, please reach the Office of Development and Early Learning (OCDEL) at Western Region 1-800-222-2149, Central Region (Harrisburg) at 1-800-222-2117, Northeast Region (Scranton) at 1-800-222-2108, or Southeast Region (North & South) at 1-800-346-2929.

If you have any questions or need assistance with the completion of your civil rights compliance application, please contact Bureau of Equal Opportunity Licensing office at 717-787-1579 or electronically.

Thank you for your commitment to protecting the rights of Pennsylvania’s most vulnerable citizens. If you have any additional questions, please contact your respective RCPA Policy Director.

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The 2024 RCPA Conference Embracing Challenges, Empowering Success kicks off in just a few days, and it’s your very last chance to contact RCPA and register to gain access to speakers who work on the cutting edge of health and human services.

In addition to keynote and plenary speakers as well as educational and interactive workshops, RCPA is hosting a variety of events throughout each day that will only be available to those onsite at the Hershey Lodge!

Tuesday, Sept. 24:

  • During the afternoon, the Oral Health + Disability Exhibit will highlight the urgent need for inclusive dental care for people with disabilities.
  • Attendees will join RCPA staff, Conference Committee members, and colleagues at the Welcome Reception for hors d’oeuvres, beverages, and plenty of networking opportunities!
Wednesday, Sept. 25:
  • The Association Awards Luncheon will recognize Rep. Eric Nelson, Kim Sonafelt, and Mike Hopkins for their dedication, commitment, and leadership in health and human services.
  • Throughout the day, the Bodhana Group, a 501(c)3 nonprofit based in York, will be on hand to discuss their mission of using tabletop games for education, skill building, and therapy.
Thursday, Sept. 26:
  • With Connections Hall open, attendees will have the day between sessions to explore exhibit booths, participate in the mobile app game, and enjoy both breakfast and lunch with RCPA staff and colleagues.
  • Silent Auction items will be distributed this day. Attendees will have a chance to earn prizes while supporting the RCPA PAC, which provides financial support to state legislators who have demonstrated a strong, consistent, and positive interest in our issues and priorities.

All of these and more will only be available onsite for in-person attendees. If you haven’t registered yet, registrations with credit card information included may be faxed to the office until September 20 at 5:00 pm, fax number 717-364-3287. Registration and payment for the RCPA conference is accepted on-site at the Hershey Lodge and Conference Center, provided space and materials remain available. Questions regarding registration should be directed to Allison Brognia, Conference Registrar.

Contact Carol Ferenz, Conference Coordinator, or RCPA with any additional questions. We look forward to seeing you at the Hershey Lodge!

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