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Policy Areas

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The Independent Regulatory Review Commission (IRRC) has published their comments on the proposed Licensure of Crisis Intervention Services regulations, summarizing the comments submitted by the stakeholder community during the public comment period. As part of the IRRC’s regulatory process, OMHSAS will have to address and clarify any questions that have been submitted.

Similar to RCPA’s public comments, the IRRC response highlights concerns regarding the proposed rulemaking in the following areas:

  • Potential issues with “one-size-fits-all” approach to crisis intervention.
  • Lack of availability of qualified staff and how to pay for them.
  • Elimination of an “in-between” level of care by imposing hospital-like standards that do not align with current outpatient structures.
  • Possibility of inadequate government funding to cover providers’ implementation costs.
  • Lack of inclusion and integration with law enforcement, first responders, 911 operators, and 988 lifeline centers.

In support of RCPA’s recommendation, the IRRC comments also urge the Department to reconvene the stakeholder work group that had been assembled in 2021, especially given the drastic shift in the mental health landscape that has occurred since the group last met.

Please contact Emma Sharp with any questions.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the proposed Mental Health Procedures regulations, which are open for public comment. The posting on the Independent Regulatory Review Commission (IRRC) website can be found here.

The proposed regulations are to be in compliance with Act 32 of 2022. OMHSAS is choosing to go beyond the updates required by Act 32 and is doing a full alignment of the chapter with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to increase the clarity of the regulations for stakeholders.

Starting December 6, 2025, and closing January 5, 2026, the public may submit written comments regarding the proposed rulemaking to the Department via email. Please be aware that all public comments must be published verbatim on the IRRC website with the name of the commenter included. OMHSAS fully supports and encourages individuals with lived experience to comment on the regulation. However, please ensure you are comfortable with the content of your comment being made public, with your name attached to it.

RCPA has conducted an internal review of the proposed regulations and is seeking member feedback and comments to be included in our submission. Members are encouraged to review and provide recommendation and guidance on the impacts of the proposed regulations on your organization.  Agencies may submit separately or in conjunction with RCPA.

Comments may also be submitted to RCPA COO and Mental Health Policy Director Jim Sharp by January 2, 2026, OR to the following address:

Department of Human Services
OMHSAS – Bureau of Policy, Planning, and Program Development,
Attention: BPPPD
Commonwealth Tower, 11th Floor
303 Walnut Street
Harrisburg, Pennsylvania 17105

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The Centers for Medicare and Medicaid Services (CMS) recently published an errata document to the inpatient rehabilitation facility patient assessment instrument (IRF-PAI) Manual, Version 4.2, related to the coding of items J1750, J1800, and J1900. This errata document was issued to update guidance related to the Falls with Major Injury (FMI) measure in the IRF Quality Reporting Program (QRP), which is effective on January 1, 2026. Specifically, the guidance related to item J1900 Number of Falls Since Admission item has revisions to the definition of Injury (except Major) and Major Injury.

CMS also released the official Technical Specification Report for the Falls with Major Injury (FMI) measure. This report incorporates feedback received during the cross-setting Technical Expert Panel (TEP) held in May 2025. The report provides an overview of the measure, a high-level summary of the key features of the re-specified measure, a description of the methodology used to construct the FMI measure, and an overview of measure testing results. Additional guidance and related updates to the IRF-PAI Manual, Quality Measure Calculations and Reporting User’s Manual, and public reporting timelines will be provided at a future date. The report is available in the Downloads section on the IRF QRP Measures Information web page.

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Please share these important workshops and support groups with your networks! Register for upcoming events at PA Family Network’s website.

Good Life Group, Support Groups

LifeCourse Workshops

Waiver Workshops

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Act 66 of 2023 requires the Pennsylvania Department of Drug and Alcohol Programs (DDAP) to annually report to the Senate Health and Human Services Committee and House Human Services Committee, among other information, barriers to entry into the SUD workforce. To help fulfill that requirement, DDAP is surveying providers to get their input on this topic.

In addition to this reporting requirement, Act 66 of 2023 also put in place several regulatory flexibilities about which providers are also being asked through this survey, though DDAP is not legislatively mandated to report on the use of these flexibilities.

The deadline to submit the survey is 5:00 pm Sunday, December 21, 2025.

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Photo by Markus Winkler on Unsplash

The Office of Developmental Programs (ODP) has shared an update to ODPANN 24-082. This communication advises providers of the availability of the ODP updated Guidance for Reviewing Data for Performance-Based Contracting (PBC) Measures RM-IM 01.2 and 01.3. The guidance and recorded webinar can be found on MyODP at Performance-Based Contracting – MyODP in the Data Folder. Updates appear underlined in red text.

Please view the announcement for more details.

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The Long Game Behind Sustainable Services w/ RCPA
Ep. 63 • December 15, 2025

In this conversation, host Nate Beers sits down with Tim Sohosky from RCPA to talk about the long game in disability services: how change actually happens, why efficiency alone isn’t enough, and what leaders need to pay attention to now if they want their organizations — and their people — to thrive long-term.

This is Part 2 of their conversation. They explore:

  • How advocacy moves from frustration to real system change;
  • Why outcomes matter more than ever (and what we’re measuring wrong);
  • The hidden strain leaders feel when innovation collides with regulation;
  • What sustainable leadership looks like five to ten years out; and
  • How building a bench of future leaders protects everything you’re working toward.

This episode isn’t about quick fixes. It’s about perspective, patience, and making decisions today that future leaders — and the people you support — will thank you for.

Watch/listen to the podcast here. Visit the IDD Leaders podcast website for more information on the podcast and organization.

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