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Mental Health

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Last week, the Department of Human Services (DHS) Bureau of Children’s Behavioral Health, Bureau of Policy, Planning and Program, and Bureau of Autism Services, convened the Behavioral Health Rehabilitation Services (BHRS) Regulation Work Group. More than 60 managed care, advocacy, and community provider organizations attended, including a strong representation from RCPA autism and general BHRS provider organizations. Initial discussions ranged from a possible name change for BHRS to the regulations that will reflect the federal and state standards for the unique array of services currently included as BHRS for children with a severe emotional disturbance, as well as children with autism.

Work group members have begun to provide DHS with comments and suggestions. Subgroup meetings/conference calls are now being scheduled for early June, when discussions related to service array and evidence-based practices will be the first areas addressed. The determination of the service array is expected to impact broader discussion related to the other key areas.

OMHSAS Leadership to Attend Children’s Committee Meeting
The directors of the Bureau of Children’s Behavioral Health, and Bureau of Policy, Planning and Program will be attending the June 8 RCPA Children’s Committee meeting/webcast, to review and discuss the status of the work group, as well as other important OMHSAS initiatives. In addition to the Children’s Committee meeting, RCPA will provide regular updates on the OMHSAS BHRS Regulation Work Group and seek member input to inform the work group process.

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RCPA has become aware that there have been higher than normal claims denials by both Medicare and Medicaid related to certain diagnoses. Those diagnoses are Schizophrenia and Post Traumatic Stress Disorder (PTSD) as defined by the DSM-V and ICD-10.

The DSM-V only identifies Schizophrenia Not Otherwise Specified (NOS) and PTSD NOS, versus the ICD-10 which offers eight schizophrenia diagnoses and three PTSD diagnoses. As a result, our practitioners are likely choosing Schizophrenia or PTSD NOS, since they are mostly using the DSM-V. Billing staff have options of eight or three diagnoses respectively, but will use what the practitioner has selected, the only DSM-V diagnosis available. It is highly probable that the individual being evaluated meets something other than NOS. There are very specific criteria for the NOS diagnosis which can certainly be used as the criteria is met, but when the criteria is not met, the claims are accurately denied. RCPA wants to hear from you about how this is affecting your business.

The second billing issue is related to electronic health records (EHR) that have not yet loaded the ICD-10 codes for billing. It is our understanding that there are at least two vendors doing business in Pennsylvania who have not loaded the ICD-10 billing codes into the EHR. RCPA wants to hear from members about how they are billing in the absence of the EHR, not having the ICD codes, and other universal billing concerns.

Please find more information about claims rejections here. Send comments to Sarah Eyster by Friday, April 15.

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In recent years, the Office of Mental Health and Substance Abuse Services (OMHSAS) had received concerns regarding the Bureau of Children’s Behavioral Health Services (Children’s Bureau). Four major themes emerged from this feedback relating to communication, regulations and policy, operational consistency, and system partner engagement. Last spring, OMHSAS engaged Mercer Consulting to conduct a study of the Children’s Bureau that included three two-hour focus groups with OMHSAS system partners, including representatives from RCPA. The primary goal of the review was to identify ways in which OMHSAS can improve internal operations as well as communication and collaboration.

On Tuesday, Deputy Secretary Dennis Marion shared both an executive summary of the Mercer Independent Study as well as his description of the steps forward that OMHSAS has initiated in response to the concerns and findings. The action items outlined by Deputy Secretary Marion are:

  • Review and consolidation of regulations related to Behavioral Health Rehabilitation Services (BHRS). OMHSAS will engage with stakeholders to draft regulatory changes with the expectation that proposed BHRS regulations will be released for public comment in mid-2017.
  • Strategic reorganization of OMHSAS leadership. On March 7, Shannon Fagan joined OMHSAS as Children’s Bureau director, and Sherry Peters became director of the Bureau of Policy, Planning, and Program Development.
  • Organization-wide effort to improve consistency and quality. Moving forward, OMHSAS senior staff will focus on identifying areas of potential improvement, developing strategies to strengthen internal and external processes, promoting an organizational culture of collaboration, coordination, communication, and cohesiveness, and monitoring progress towards addressing the concerns voiced by OMHSAS stakeholders.
  • Emphasis on family and stakeholder engagement. The involvement of PACA, RCPA, BH-MCOs, and their contractors, played an integral role in working to identify issues of concern.
  • A redefining of “customer service.” To address concerns relating to responsiveness and professionalism, internal meetings have been held to stress the importance of holding OMHSAS staff to high standards of customer service.
  • Renewed focus on communications. In response to concerns regarding effectiveness of internal and external communications, Shanna Klucar was appointed as executive assistant to the deputy secretary on January 30.

OMHSAS invites RCPA members and other stakeholders to share comments and concerns regarding Children’s Behavioral Health Services to Shannon Fagan, bureau director, as well as the RCPA Children’s Division. In addition, members may contact OMHSAS leadership Sherry Peters and Shanna Klucar with more general comments and concerns.

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The Department of Human Services (DHS) Medical Assistance Online Provider Enrollment Application information is now electronic, online, and available to provider organizations. The improvements and modernization of the PROMISe system have been strongly encouraged by RCPA and a significant goal of DHS. Some of the benefits of online enrollment application submissions are:

  • Allowing documents that previously had to be mailed or faxed to be uploaded directly to the portal;
  • Permitting providers see the status of their submissions; and
  • Decreasing wait time to review applications.

The information you will need to submit an application for enrollment:

  • Access the online enrollment application
  • Review the training guide
  • Review the frequently asked questions document for important clarifications
  • A “Help” feature is available at any time during the completion of an application
  • Supplemental Services require the Behavioral Health Managed Care Organization to attest that a provider is credentialed

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This week the Pennsylvania Department of Human Services (DHS) announced several new initiatives to reduce the use of psychotropic medication among our state’s most vulnerable children. Speaking at The Children’s Hospital of Philadelphia, DHS Secretary Ted Dallas reported on the partnership of DHS with the Pennsylvania Chapter of the American Academy of Pediatrics and the Pennsylvania Psychiatric Society. A state-commissioned PolicyLab study that found that in 2012 in Pennsylvania, the use of psychotropic medications was nearly three times higher among 6-18 year olds in foster care than among youth in Medicaid overall. Based on this study and the collaborative effort mentioned above, Pennsylvania has initiated the following:

  • Best practice guidelines are being developed for clinicians regarding comprehensive assessments of behavior and treatment interventions;
  • Managed care organizations will be required to give prior authorization for antipsychotic medications for children;
  • A new electronic dashboard will make it easier for DHS to monitor what medications children are taking and improve care coordination;
  • In April, DHS will open a telephonic child psychiatric consultative service to help prescribing physicians, physician assistants, and nurse practitioners appropriately prescribe psychotropic medication for children; and
  • In July, the department will begin training child welfare caseworkers and caregivers on the appropriate use of psychotropic medication.

“The inappropriate use of these powerful medications for children in the foster care system compounds the trauma experienced by children who have been the victim of abuse and neglect and is simply unacceptable,” Dallas said, “The recommendations and analysis from PolicyLab provide Pennsylvania with an invaluable roadmap to improve the safety and quality of life for foster children served by the Medicaid system.”

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