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Substance Use Disorder

DDAP Modifies ASAM Transition Web Page, Archives Addendums That Outlined IOP Ratio and Daily Therapeutic Hour “Expectations”

The Pennsylvania Department of Drug and Alcohol Programs (DDAP) has overhauled its ASAM Transition web page, removing previous references to “expectations for contractual compliance” in areas of ASAM Criteria where DDAP originally went beyond the Criteria as explicitly written. Newly revised information, including an updated “Guidance for the Application of The American Society of Addiction Medicine, 3rd Edition, 2013 in the Pennsylvania Substance Use Disorder Treatment System for Adults” and “ASAM Frequently Asked Questions” document, references the 1:15 intensive outpatient (IOP) counselor-to-patient ratio and the six to eight daily therapeutic hours at residential level of care as a DDAP “recommendation.”

The change is significant because, according to the Pennsylvania Department of Human Services (DHS) Office of Mental Health and Substance Abuses Services (OMHSAS), per its HealthChoices Behavioral Health Program Standards and Requirements for Primary Contractors document, “the Primary Contractor and its BHMCO must ensure that the SUD providers in the network comply with program standards in the ASAM Criteria, included but not limited to admission criteria, discharge criteria, interventions/types of services, hours of clinical care, and credentials of staff as set forth in the ASAM transition requirements found at https://www.ddap.pa.gov/Professionals/Pages/ASAM-Transition.aspx.” In other words, providers were expected to be in compliance with any information published as an expectation on that page.

For months following DDAP’s testimony in Commonwealth Court that the IOP and daily therapeutic overreaches were simply “guidelines,” the provider community remained unclear on whether they would be required to comply with the “guidelines” as part of their contracts with the BHMCOs. Still, providers have not yet seen the evaluation tool that will be used to audit their compliance with ASAM Criteria despite DDAP’s expectation that they be “substantially aligned” with those Criteria by Jan. 1, 2022.

The next Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting will be held on March 1, 2022, as a webinar from 10:00 am–1:00 pm.

You can register for the meeting here. After registering, you will receive a confirmation email containing information about joining the webinar. Remote captioning and streaming services will be provided; if you require these services, please visit here. If you require another accommodation, including an alternative method for submitting questions or comments about meeting topics, please send an email no later than February 18, 2022, so other accommodations can be scheduled.

Photo by Markus Winkler on Unsplash

RCPA staff reviewed the Governor’s proposed budget, and while many details still need to be sorted out, RCPA can provide some high-level facts about the proposed budget from the House Democrat Appropriations Committee 2022/23 Executive Budget Proposal At–A-Glance and the Governor’s 2022/23 Executive Budget Spreadsheet. Of note, please see pages 12–13 for the Department of Human Services line items and page 6 for the Department of Drug and Alcohol Programs.

The highlights of the Governor’s proposed budget include:

Education Funding

  • Spending $43.7 billion in state General Funds;
  • $1.55 billion, a 24% increase, in basic education funding;
  • $1.25 billion to be distributed through the fair funding formula;
  • $300 million in Level Up funding to the 100 most underfunded districts; and
  • $200 million, a 16% increase, in special education funding.

Economy

Proposed increase to state’s minimum wage to $12 per hour effective July 1, 2022, including tipped workers, with 50 cent annual increases up to $15 per hour ($74.6 million direct revenue increase).

Protecting the Most Vulnerable

  • $91.25 million ($190.1 million total funds) to increase MA rates for skilled nursing facilities, effective January 2023, to comply with regulatory changes planned for July 2023;
  • $50 million, or a 44% increase to state supplemental programs for aged, blind, and individuals with disabilities, to increase the personal care home state supplement from $439.30 to $1,351.80 per month;
  • $75 million in federal funds to recruit and retain behavioral health providers;
  • $36.6 million to invest in critical county behavioral health services;
  • $15 million in federal funds to stabilize payments to substance use disorder treatment providers and assist with pandemic related expenses;
  • NEW: $14.3 million to increase the monthly Supplemental Nutrition Assistance Program (SNAP) benefit from $20 to $35 for 75,000 to 95,000 seniors and individuals with disabilities;
  • NEW: $280,000 to implement Agency with Choice, preserving the ability for home and community-based waiver participants to choose their worker while allowing workers to obtain the support of an agency;
  • $18.8 million to serve an additional 832 individuals with intellectual disabilities and autism currently waiting for services;
  • $1 million to provide community placements for individuals residing in intermediate care facilities;
  • $1.25 million to discharge 20 individuals from state hospitals through the Community Hospital Integration Project Program (CHIPP);
  • $2.4 million for Department of Aging and Department of Human Services to strengthen older adult protective services (8 positions), create a child welfare crisis response team (4 positions), and support increased regulatory, licensing, budgetary, and administrative functions (30 positions) through increasing complement;
  • NEW: $8 million to extend postpartum coverage for birthing parents eligible for Medical Assistance to 12 months;
  • $15 million, a 77% increase, to implement additional evidence-based home visiting and family support services to 3,800 additional families;
  • $1.8 million to support court-appointed volunteer advocacy; and
  • NEW: $10 million for State Disaster Assistance, a new initiative to provide disaster assistance to individuals and to improve access to safe, secure, and weathertight homes.

In addition to the above proposed funding, the Governor and Democratic legislative leaders support allocating the unused American Rescue Plan funds from last year’s budget to various programs, which are outlined in the Democrat’s American Rescue Plan Act — State Fiscal Recovery plan, to help Pennsylvanians rather than letting the funds be transferred to the General Fund to sit in reserve.

The above information is a high-level overview of the Governor’s budget proposal. The specific line items contained in the Governor’s 2022/23 Executive Budget Spreadsheet are the overall dollars allocated for health and human services. The Department of Human Services (DHS) has not yet released their Budget Blue Book, which breaks down these line items and provides a detailed dollar amount allocated to specific human service programs. We are being told the DHS Blue Book should be available with this specific information at the end of February or the first week of March. Once RCPA obtains the Blue Book and reviews it, we will provide members with a more detailed summary and analysis.

As a reminder, the Governor’s Proposed Budget is just that: a proposal. The General Assembly will now hold budget hearings; a complete hearing list can be found here. The General Assembly and the Governor will conduct budget negotiations after the House and Senate budget hearings conclude to hopefully finalize the Commonwealth’s 2022/23 budget by June 30. If you have any questions, please contact Jack Phillips.

The Pennsylvania Department of Drug and Alcohol Programs (DDAP) is now offering “Co-Occurring Conditions: Promising Practices and Approaches.”

Co-occurring conditions are no longer the exception but the expectation, requiring treatment programs to design services that address the interrelationship among complex physical, psychiatric, and substance use conditions. This curriculum will review up-to-date principles, terminology, screening, assessment, treatment considerations, and programming guidelines, and the interactive program will engage participants through discussion and small group exercise. This six-hour virtual course is divided into two parts in DDAP’s Training Management System.

Participants of this course will:

  • Describe the foundations of integrated treatment;
  • Highlight key treatment considerations;
  • Employ screening and assessment for COD; and
  • Critique integrated treatment plans.

The Pennsylvania Department of Human Services is extending the public comment period for the renewal of the Section 1115 Medicaid Demonstration titled “Medicaid Coverage for Former Foster Care Youth from a Different State and SUD Demonstration” (Project Number: 11-W-003083/3). The public comment period, which was originally slated to end on Feb. 15, 2022, is now extended to March 10, 2022, so the public can see the clarifications made in the Demonstration Extension page on the DHS website. The effective dates of the current approved demonstration are Oct. 1, 2017, through Sept. 30, 2022. The extension requested will be for an additional five years through Sept. 30, 2027.

The Office of Mental Health and Substance Abuse Services (OMHSAS) has just published an FAQ on the Home & Community-Based Services (HCBS) workforce support payments. Any remaining questions may be sent to the RA Account.

Please note that after receiving anticipated payment amounts on the attestation forms that were sent to providers at the locations of qualifying services, some providers alerted us to apparent irregularities in the payment amounts. OMHSAS is pulling our data and rerunning our formulas to ensure that payments are based on proper calculations and a balanced distribution of funds. Revised attestation forms will be sent to any providers who may have been impacted in their total allocation (positively or negatively) with a new due date in early March.

RCPA continues to work with its members and OMHSAS on the attestation and allocation process. Please contact your RCPA Policy Director for guidance or questions.

Today, RCPA staff watched the Governor’s budget address and attended the Department of Human Services (DHS) 2022/23 Budget Overview webinar. After listening to the Governor and DHS, there were some positive takeaways for RCPA members. Specifically, the Governor is requesting:

  • $50 million, or a 44% increase to state supplemental programs for aged, blind, and individuals with disabilities, to increase the personal care home state supplement from $439.30 to $1,351.80 per month;
  • $75 million in federal funds to recruit and retain behavioral health providers;
  • $36.6 million to invest in critical county behavioral health services;
  • $15 million in federal funds to stabilize payments to substance use disorder treatment providers and assist with pandemic related expenses; and
  • $18.8 million to serve an additional 832 individuals with intellectual disabilities and autism currently waiting for services.

The Governor also proposed increasing the state’s minimum wage to $12 per hour effective July 1, 2022, including tipped workers, with 50 cent annual increases up to $15 per hour ($74.6 million direct revenue increase).

The above are some highlights from both the Governor’s budget request and the DHS presentation. While some of the Governor’s asks may seem beneficial to members, RCPA staff will be reviewing the more detailed spreadsheets we received from the Governor’s office. Once RCPA staff have had the opportunity to review and analyze these spreadsheets, members will receive a more detailed analysis of the Governor’s budget requests. RCPA plans to have the analysis done as soon as possible, so members can get a clearer picture. If you have any questions, please contact Jack Phillips.