Washingtonian Names National Council President/CEO Chuck Ingoglia One of the “Most Influential People Shaping Healthcare Policy” for 2025
National Council Releases H.R. 1 Implementation Journey Map
IRRC Releases Licensure of Crisis Intervention Services Comments
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.
OMHSAS Opens Public Comment Period for Proposed Regulations for State HIPAA Compliance
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
DDAP Seeks Provider Input On Barriers to Entering SUD Workforce
Act 66 of 2023 requires the Pennsylvania Department of Drug and Alcohol Programs (DDAP) to annually report to the Senate Health and Human Services Committee and House Human Services Committee, among other information, barriers to entry into the SUD workforce. To help fulfill that requirement, DDAP is surveying providers to get their input on this topic.
In addition to this reporting requirement, Act 66 of 2023 also put in place several regulatory flexibilities about which providers are also being asked through this survey, though DDAP is not legislatively mandated to report on the use of these flexibilities.
The deadline to submit the survey is 5:00 pm Sunday, December 21, 2025.
Mental Health Care Workers Face Too Many Needs and Not Enough Money on the Front Line of PA’s Self-Made Crisis, RCPA Member Scranton Counseling Center Featured
OMHSAS Releases 4 Walls Telehealth Bulletin
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.
CCBHC Legislation Introduced in the Senate
PA Rural Health Transformation Project Summary Now Available
RCPA to Hold Member Orientation Webinar on January 14, 2026
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.
