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DDAP Modifies ASAM Transition Web Page, Archives Addendums That Outlined IOP Ratio and Daily Therapeutic Hour “Expectations”

The Pennsylvania Department of Drug and Alcohol Programs (DDAP) has overhauled its ASAM Transition web page, removing previous references to “expectations for contractual compliance” in areas of ASAM Criteria where DDAP originally went beyond the Criteria as explicitly written. Newly revised information, including an updated “Guidance for the Application of The American Society of Addiction Medicine, 3rd Edition, 2013 in the Pennsylvania Substance Use Disorder Treatment System for Adults” and “ASAM Frequently Asked Questions” document, references the 1:15 intensive outpatient (IOP) counselor-to-patient ratio and the six to eight daily therapeutic hours at residential level of care as a DDAP “recommendation.”

The change is significant because, according to the Pennsylvania Department of Human Services (DHS) Office of Mental Health and Substance Abuses Services (OMHSAS), per its HealthChoices Behavioral Health Program Standards and Requirements for Primary Contractors document, “the Primary Contractor and its BHMCO must ensure that the SUD providers in the network comply with program standards in the ASAM Criteria, included but not limited to admission criteria, discharge criteria, interventions/types of services, hours of clinical care, and credentials of staff as set forth in the ASAM transition requirements found at https://www.ddap.pa.gov/Professionals/Pages/ASAM-Transition.aspx.” In other words, providers were expected to be in compliance with any information published as an expectation on that page.

For months following DDAP’s testimony in Commonwealth Court that the IOP and daily therapeutic overreaches were simply “guidelines,” the provider community remained unclear on whether they would be required to comply with the “guidelines” as part of their contracts with the BHMCOs. Still, providers have not yet seen the evaluation tool that will be used to audit their compliance with ASAM Criteria despite DDAP’s expectation that they be “substantially aligned” with those Criteria by Jan. 1, 2022.

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PDE and DHS are offering the following policy clarification on the Head Start/Early Head Start vaccination mandate:

PDE and DHS are cognizant of the staffing challenges that many providers are facing. Providers are thus encouraged to work creatively to ensure that children continue to receive a free and appropriate public education during these trying times. In this regard, providers should examine whether unvaccinated individuals may continue to provide services in accordance with an allowable exemption, and, where appropriate, consider whether parental agreement to alternative delivery of services may be prudent.

OCDEL has clarified that this is to include all individuals working with Head Start enrolled children and families, including early intervention and behavioral health. OCDEL further requests that agencies work with Head Start partners to address this requirement and asks for support considerations, including; encouraging staff and contractors to become fully vaccinated; working to identify fully vaccinated EI personnel to support children in Head Start; when possible, working to provide written assurance to Head Start partners to only send fully vaccinated staff and contractors to go into classrooms; and exploring technological solutions to help support children within their Head Start classroom activities and routines.

The United States Department of Health and Human Services (HHS) has implemented an Interim Final Rule (IFR) requiring all staff who work with Head Start/Early Head Start (Head Start) children and families in any capacity to be vaccinated. According to HHS guidance, this includes those individuals who do not have any contact with children. The IFR also requires contractors whose activities involve contact with or providing direct services to Head Start children and families and volunteers in classrooms or working directly with Head Start children and families be vaccinated. The IFR is now understood to apply to all individuals working with Head Start children and families, including but not limited to services provided by Preschool Early Intervention, 0-3 Early Intervention, and behavioral health specialists in Head Start programs, including those provided pursuant to a memorandum of understanding or other agreement by which Head Start programs provide for or permit the provision of such services.

The Federal Office of Head Start (OHS) is responsible for ensuring compliance with the IFR through their identified monitoring processes. PDE or DHS is not responsible for monitoring programs for compliance with this mandate.

Head Start IFR and guidance do allow for exemptions for individuals who are not vaccinated. In the event individuals meet this exemption, OHS has issued guidance regarding circumstances in which unvaccinated individuals may be able to continue to work with Head Start children and their families.

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Photo by Christina @ wocintechchat.com on Unsplash

Adult Autism Waiver (AAW) and Adult Community Autism Program (ACAP) providers are invited to sign up for a scheduled one-on-one VOH session to discuss incident management topics with the Office of Developmental Programs’ (ODP) Bureau of Supports for Autism and Special Populations (BSASP).

Providers may sign up for one 30-minute session, and multiple staff from the provider may join at the provider’s discretion. Topics for discussion may include: provider-specific IM issues or concerns; EIM reports; general questions about certified investigations; brainstorming ideas of how to improve “performance” related IM tasks; review of provider IM data and compliance; discussion of provider trends; etc.

Due to the positive feedback received from attendees of our previous sessions, ODP will be offering additional 30-minute sessions on a first-come, first-served basis.

Sessions begin Wednesday, March 9, 2022, with the first scheduled session beginning at 12:30 pm.

Register here. Be sure to complete all required information to reserve a time slot.

Please contact the Provider Support Mailbox with questions.

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Capitolwire: Wolf Budget Proposal Spurs Debate on Mental Health Funding
By Robert Swift

HARRISBURG (Feb. 14) — A budget proposal by Gov. Tom Wolf is spurring a new debate about providing more state mental health services during this time of pandemic-related stress.

The governor proposes spending $36.6 million from the taxpayer-supported General Fund in Fiscal Year 2022-23 to restore much of a decade-old cut in state aid to county-run mental health programs.

He would also direct $75 million in federal American Rescue Plan funds for support payments to help keep and hire new employees for qualifying home and community service providers.

A 21-member Mental Health Safety Net Coalition sent a letter Monday to lawmakers asking them to consider the proposed $36.6 million increase as a starting point in budget negotiations.

“The governor’s proposed increase will help offset the loss in purchasing power due to a decade of level funding,” wrote the coalition that includes service providers, hospitals, treatment centers and professional groups. “This money is critical to help counties get back to the effective level of resources they had 10 years ago, but it does not even begin to address all the gaps in our mental health system or surging demand for mental health services as we enter the third year of the global pandemic.”

Not only has the pandemic increased demand for services, it has also led to significant health staff shortages and increases in suicides and opioid deaths, the coalition said.

Also the County Commissioners Association of Pennsylvania issued a statement Monday calling on lawmakers to support Wolf’s proposal. It would restore two-thirds of a 10 percent cut to the budget line item in 2012 if enacted.

“If the funding continues to be uneven with the growing demand, counties will continue to struggle to in meeting the needs of their residents,” said CCAP President and Bradford County Commissioner Daryl Miller.

A key feature of county mental health programs is they are available to the entire community regardless of income, said Brinda Penyak, CCAP deputy executive director.

CCAP made rebuilding a “crumbling” mental health system its top priority this year. For the past six decades, counties have carried the responsibility to provide and contract for a range of community-based mental health services, including crisis intervention, treatment, education and prevention.

“We would strongly support advance planning and (mental health funding) increases that are practical and sustainable to ensure increased system availability for the long term,” said Dr. Kathy Quick, executive director of the Pennsylvania Mental Health Consumer Association while voicing concern that the proposed funding hikes for this year can’t be sustained in the future.

The issue of pandemic-related mental health challenges facing the general population and students as well has been the subject of several legislative hearings during the past two years.

The Senate Agriculture and Rural Affairs Committee held a hearing last month focusing on mental health issues facing agricultural workers. Pennsylvania has received a $500,000 grant from the U.S. Department of Agriculture to provide more resources to support mental health programs in rural areas by linking to national hotline networks and providing education and training, said state Agriculture Secretary Russell Redding at that hearing.

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