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Image by Markus Winkler from Pixabay

Message from the Office of Long-Term Living (OLTL):

The Commonwealth is working collaboratively — Governor Shapiro’s office and the health hub agencies (Health, Human Services, Drug and Alcohol Programs, and Insurance) — to develop a statewide maternal health strategic plan. We need your help to make it a robust, comprehensive, collaborative, living, and most importantly, active plan.

As you are likely aware, Pennsylvania, like the nation, is experiencing a maternal health crisis.

According to the Pennsylvania Maternal Mortality Review Committee report, in 2020, Pennsylvania residents experienced a pregnancy-associated mortality ratio of 83 deaths per 100,000 live births with large disparities identified. In total, 107 individuals lost their lives during pregnancy, delivery, or up to one year postpartum.

Those numbers are far worse for Black women, where the rate was twice as high at 163 deaths per 100,000.

We also know that women and birthing people with disabilities experience unique challenges and needs on their health journey, so we are inviting you to join us for a 90-minute Zoom listening session where members of the Commonwealth’s health agencies and members of the statewide maternal health strategic plan can engage with you to learn what specific needs you have and how you feel the Commonwealth should address those needs.

We want our strategic plan to address all Pennsylvania women and birthing people, and sharing your voice at this listening session will help inform our plan.

The Zoom listening session is scheduled from 10:00 am – 11:30 am, on Friday, December 6, 2024. Please RSVP electronically by December 1 if you plan to attend. We will send the Zoom link by end of day December 4 to those who RSVP.

Thank you for considering spending 90 minutes with the disability community and state health team members to share your thoughts and needs around maternal health.

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

Do you have a great topic or know a fantastic presenter? Please reach out to Cindi Hobbes, IPRC Director.

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.

Photo by Chris Montgomery on Unsplash

Registration is now open for the 32nd Annual PA Forensic Rights and Treatment Conference, titled “What We Know: Myths or Facts.” Sponsored by Drexel University’s Division of Behavioral Healthcare Education, College of Medicine, the virtual conference will be held December 4 and 5 with both live and pre-recorded presentations addressing topics such as trauma-informed care; working with victims of trafficking and partner violence; neuro and gender diversity; and identifying methods to enhance belonging and inclusion.

The conference brochure includes the schedule, workshop descriptions, plenary bios, and registration information. CE credits will be available.

For more information, email Drexel or visit the BHE conferences website.

Photo by Glenn Carstens-Peters on Unsplash

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