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Register Today for the Pennsylvania Technology Innovation Luncheon
Thursday, January 12, 2023
11:00 am – 2:00 pm ET
777 E Park Drive, Harrisburg, PA 17111
Eleos Health invites all RCPA behavioral health provider members to participate in this informational, in-person session.
Let’s give frontline providers more:
Eleos Health’s motto is more care, less ops. Our proprietary technology digitizes behavioral health conversations, tracks evidence-based care and reduces documentation work for providers by over 50%. We’re dedicated to giving providers the ability to focus more of their time on what they do best – caring for their clients.
During this luncheon, you’ll join a select group of Pennsylvania behavioral health leaders to discuss how innovative technology can help solve top workforce challenges and improve care.
Speakers will include Susan Blue, CEO & President of Community Services Group (CSG), Josh Cantwell, COO of GRAND Mental Health in Oklahoma, and Andrew Schmitt, LCSW, Director of Outpatient Services of Gaudenzia, Inc., who will share how they approach technology decisions and why they chose Eleos as a valued partner.
GRAND’s efforts to tech-enable their providers were recently featured by the Philadelphia Citizen in the article “Ideas We Should Steal: A Comprehensive Approach to Mental Health Care.”
We’d love to have you join the conversation at this special event!
Attendees can expect to:
Join RCPA for a Membership Benefits webinar on Wednesday, January 4, 2023, at 1:00 pm in order to orient yourself with all that an RCPA membership entails. This webinar will review the benefits that come with RCPA membership, including many that you may not be aware of. Those considering membership are also invited to become acquainted with the benefits.
Register here to attend this webinar. Items we will review include the below and much more:
Visit the RCPA member benefits page or contact Tieanna Lloyd for more information. We look forward to your participation in this webinar.
OMHSAS Approves RCPA Telehealth Extension Request
Deadline for Consent/Service Verification Compliance Now March 31, 2023
In an effort to assist provider members in their efforts toward consent and service verification compliance, RCPA requested an extension of the December 31, 2022, deadline. RCPA outlined ongoing challenges towards meeting these standards that included integrating new platforms into existing infrastructure, funding, training, and internal process changes.
Yesterday, we met with the Office of Mental Health and Substance Abuse Services (OMHSAS) to outline these concerns and review provider progress towards compliance. In response, OMHSAS has agreed to extend the date for meeting the consent and service verification standards to March 31, 2023. Funding concerns, especially in the middle of a budget year, were also discussed, and OMHSAS will make available funds to aid providers in implementing these practices.
As part of the RCPA Telehealth Work Group meeting at 10:00 am on Tuesday, December 20, 2022, we will be covering this and other telehealth topics on the agenda. These include our hope to conduct online polling on specific telehealth issues. You can register for the meeting here. Additionally, the second half of the meeting will feature OMHSAS Policy Director Jenna Mehnert Baker, who will provide updates, guidance, and a Q&A. We hope you are able to join us for this call, as your participation in the meeting will provide up-to-date information on your efforts and information that will assist RCPA in our collective endeavors.
We are grateful for the collaboration with OMHSAS and their willingness to extend the compliance timeframe. RCPA is committed to working with providers to ensure telehealth services remain a viable part of the service delivery continuum.
Please forward all questions you may have for OMHSAS to RCPA Policy Director Jim Sharp.
Read the OMHSAS response from Dr. Dale Adair below:
The purpose of this communication is to address concerns expressed by RCPA specific to the impact of ending OMHSAS’ bulletin suspensions on 12/31/22. There appears to be a significant amount of concern about providers’ ability to have telehealth platforms in place by 01/01/2023. Just to clarify, at no point has OMHSAS stated that providers must have HIPAA-compliant platforms in place by January 2023? It is important to note that the Pennsylvania General Assembly has defined telebehavioral health to specifically include platforms. Act 76 of 2022 defined: “Telebehavioral health technology. (i) Any of the following:(i) Real-time interactive audio and video communication using technology that conforms to industry-wide standards and is in compliance with Federal and State privacy and security laws.(ii) Real-time interactive audio-only telecommunication, provided that the use of audio-only telecommunication technology is consistent with Federal and State laws, guidance and requirements.(2) The term does not include technology solely using voicemail, electronic mail messages, facsimile transmissions or instant messaging, or a combination thereof.”
OMHSAS Memorandum dated February 18, 2021, that temporarily suspended portions of bulletins and other guidance documents, stated that “verbal consent must be documented at the time of service, and providers are strongly encouraged to obtain electronic signatures when possible.” This language allowed verbal consent without a second witness during the public health emergency. At that time, OMHSAS also stressed the need for providers to acquire platforms capable of securing electronic signatures. Given OMHSAS’ previous recommendation, providers have had nearly two years to secure a platform capable of securing electronic signatures for consent and service verification. DHS is intending to provide a funding opportunity for providers per the approved HCBS spending plan. OMHSAS continues to look for additional ways to support compliance with the expectations of the Pennsylvania Act 69 of 1999 (Electronic Transactions Act).
It remains imperative for all entities delivering MA funded behavioral health services to have policies in place to capture consent in a way that creates an auditable trail. There are multiple ways that providers of telebehavioral health can meet this requirement including messages typed into the chat box of an audiovisual platform, email, text messaging, USPS mail and two-person verification of a verbal consent secured over the phone. Given the options available to providers and the fact that since 02/2021 OMHSAS has stressed the importance of developing appropriate systems to capture electronic signatures, OMHSAS asks that providers meet federal and state expectations. Understanding the challenges providers are experiencing, OMHSAS will extend the bulletin suspension specific to consent to treat, service verifications and treatment plans only that is scheduled to end on 12/31/2022 until 3/31/23. Effective on April 1, 2023, providers are expected to capture consent to treat, service verifications and approval of treatment plans in a manner that creates an auditable file and in accordance with the timelines expected within regulation. While we understand the operational challenges, waiving the requirement that consent and service verification are secured in a manner that would withstand an audit any longer than three additional months is simply not possible. We believe the definition created in Act 76 serves to govern the delivery of telebehavioral health in the Commonwealth moving forward.
The Substance Abuse and Mental Health Services Administration (SAMHSA) is proposing to expand access to treatment for opioid use disorder (OUD) by making permanent medication flexibilities put in place during the COVID pandemic, including an increase in number of take-home doses of methadone and the use of telehealth in initiating buprenorphine at opioid treatment programs (OTPs).
In its Notice of Proposed Rulemaking to update 42 CFR Part 8, SAMHSA is proposing to improve access to OUD treatment through OTPs. The proposed changes reflect the widespread desire by many stakeholders for SAMHSA to provide greater autonomy to OTP practitioners, positively support recovery, and continue flexibilities that were extended at the start of the nation’s COVID-19 public health emergency. For example, in March and April 2020, SAMHSA published flexibilities for the provision of take-home doses of methadone and for the use of telehealth in initiating buprenorphine in OTPs. Patients deemed stable by physicians have been able to take home up to 28 days’ worth of methadone doses; other patients — again, so determined by their physicians — received up to a 14-day supply. A recent study showed that patients who received increased take-home doses after federal flexibilities were enacted during COVID-19 saw positive impacts on their recovery, including being more likely to remain in treatment and less likely to use illicit opioids.