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Substance Use Disorder

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The Department of Drug and Alcohol Programs (DDAP) has issued Licensing Alert 03-2024, effective immediately, which introduces updated guidance on complying with Act 66 of 2023, signed into law by Governor Shapiro in December. The guidance specifically outlines all regulatory flexibilities for SUD treatment facilities enabled through the law and describes the process for project directors to notify DDAP of their intent to use any of these flexibilities. In part, Act 66 allows:

  • An increase in staff-to-client ratio for adult nonhospital residential treatment and rehabilitation programs, from 1:8 to 1:12;
  • Certified Registered Nurse Practitioners (CRNP) and Physician Assistants (PA) to serve as counselors;
  • Individuals lacking previous clinical experience to still qualify as counselors if they possess a bachelor’s or associate degree in relevant fields or hold a current Registered Nurse license; and
  • Facilities to hire up to three counselor assistants for each staff person meeting clinical supervisor or counselor qualifications.

Additionally, the alert underscores the importance of continued compliance with other regulations, such as clinical supervisor ratio requirements, counselor assistant supervision, and evaluation requirements. For additional questions, contact the Bureau of Program Licensure.

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Photo by Markus Winkler on Unsplash

The Department of Drug and Alcohol Programs (DDAP) has issued Licensing Alert 02-2024, effective immediately, to inform opioid treatment programs (OTP) about the recent final rule issued by the Substance Abuse and Mental Health Services Administration (SAMHSA) on February 2, 2024, concerning medications for the treatment of opioid use disorder (OUD). RCPA issued an alert to its members on February 1 announcing the final rule.

This rule modifies and updates regulations pertaining to OTP accreditation, certification, and standards for the treatment of OUD. The most crucial aspects of SAMHSA’s final rule include the permanent adoption of COVID-19 era flexibilities, allowing patients to receive more take-home doses of methadone, which is proven to enhance treatment retention and reduce illicit opioid use. The update also permits the initiation of methadone and buprenorphine treatment via telehealth through OTPs and removes stringent admission criteria, thereby improving access to care for individuals in need.

DDAP is currently reviewing the final rule, set to take effect on April 2, 2024, with a compliance deadline of October 2, 2024, and plans to issue a follow-up Licensing Alert soon. For further information, contact the Bureau of Program Licensure.

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Last week, Governor Shapiro presented his proposed budget for 2024/2025. The PowerPoint with the Human Services Spending Overview outlines the priorities, and the recording is available on the DHS YouTube channel.

RCPA staff will continue to advocate for appropriate levels of funding for our members’ services in the community. We will keep you updated with information as the process continues. If you have any questions, please contact your RCPA Policy Director.

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RCPA is pleased to report several successful collaborative efforts this week, including a meeting with DHS, OMHSAS, and a delegation of House and Senate Representatives. We reviewed proposed language for a new bill that would address the 4 walls standard for ongoing telehealth with practitioners not within the 4 walls of a clinic. The bill will also include language previously introduced on the Psychiatric Outpatient Regulatory requirements for the 50% in-office time for clinics and the use of advanced practice professionals to meet those time requirements.

The language for both target areas was approved by all parties and will now move on to the House Human Services Committee. RCPA has a meeting scheduled for early next week to review the finalized version prior to its introduction. We have also met with Senate counterparts to support the measure.

Lastly, RCPA continues its dialogue with OMHSAS for guidance and clarification, including sharing members’ and stakeholders’ feedback. We have had the opportunity to speak with our BH-MCO members and understand OMHSAS Deputy Secretary Jen Smith will be meeting with that group and the county contractors on the processes moving forward.

We are hopeful for an expedited legislative solution that will aid OMHSAS in making any resulting policy, practice, or program changes that will support the initiative. We are extremely encouraged by the system’s efforts and focus this week and will continue to provide key updates to members and stakeholders.

If you have any questions, please contact RCP Policy Director Jim Sharp.

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The Department of Human Services (DHS) just announced that, due to reaching capacity in the February 9 meeting, they are adding a second session at 1:30 pm on the same day. If you are already registered for the morning session, do not register for the afternoon session so that they can keep enough space for all who are interested. Both sessions will be recorded and posted publicly to YouTube, and content will be roughly similar within the two sessions. DHS will share Question and Answer (Q&A) sessions from both, and a follow-up Q&A document will be shared next week.

Visit here to register for the afternoon session.

(If the registration link above does not work, please try copying this link directly into your browser: https://events.gcc.teams.microsoft.com/event/9f3d9e64-6d38-45a7-84eb-b0ae2b1aafd9@418e2841-0128-4dd5-9b6c-47fc5a9a1bde)

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The Pennsylvania Commission on Crime and Delinquency (PCCD) announces the opening of registration for the 2024 Criminal Justice Advisory Board (CJAB) Conference, themed “An Evolving Justice System: Adapting and Navigating New Directions.” The conference is scheduled for April 9 – 10, 2024, at the Penn Stater Hotel and Conference Center in State College. The event will convene criminal justice, behavioral health, and treatment partners for a dynamic one and a half-day gathering. Featuring a lineup of national and local experts, discussions will center on emerging issues impacting criminal justice and behavioral health systems, offering innovative strategies and collaborative solutions.

Registration and conference details are available on the 2024 CJAB Conference page on PCCD’s website. Additionally, notable sessions include a plenary by Jason Snyder, RCPA SUD Policy Director, on April 9, and a workshop on SUD confidentiality facilitated by RCPA, which will include representatives from the SUD treatment and criminal justice systems on April 10. Attendees should be aware that the discounted room rate deadline is Friday, March 8, 2024.

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The Pennsylvania Department of Human Services (DHS) is hosting a post-award forum regarding the federal Section 1115 Demonstration, which includes Medicaid coverage for out-of-state former foster care youth and substance use disorder (SUD) services. It will take place at 1:00 pm – 2:30 pm on Friday, March 8, 2024, via WebEx. The forum aims to gather public feedback on the progress of these initiatives, both of which were approved by the Centers for Medicare & Medicaid Services (CMS). The Former Foster Care Youth (FFCY) component allows Medicaid coverage for individuals under 26 who were in foster care in another state upon turning 18. The SUD component provides funding for essential SUD services, including residential care.

Register for the forum here. Written comments are also acceptable until the same date. For inquiries, contact Shivani Patel. Further details and the announcement can be found here. Please contact RCPA Policy Director Jim Sharp for any further questions.

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