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Policy Areas

For providers that may be adding behavioral health services to a primary care practice, you’ll need to be sure you’re getting reimbursed for these new services. That means knowing what you can bill for, learning a web of new codes and numbers, identifying which staff can be reimbursed for providing these services, and training staff to code services appropriately. National Council is inviting primary care providers and their behavioral health partners to join integration experts from primary care centers for a webinar on the practical ins and outs of billing for behavioral health services, to a variety of third-party payers, including Medicare and Medicaid.

Participants need to be ready to discuss the menu of billing options available that can match your center’s needs. After this webinar, participants will:

  • Identify billing options for integrated behavioral health services;
  • Ask questions to identify if Medicaid and Medicare numbers are appropriately linked to the mental health services provided; and
  • Employ tips for working with clinical and billing staff at the same time.

This webinar will be held on Monday, June 6, at 2:00 pm. Practitioners and providers can register here.

RCPA will now distribute information on integrated health care. RCPA INFOS and ALERTS will cover research, delivery and training models, policy issues, and other topics that will inform our members (and their physical health care partners) about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.

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People with serious mental illness (SMI) in publically funded mental health organizations have a life expectancy of 25–30 years less than the general population. Mental health organizations from across the United States have the opportunity to apply for support in implementing InSHAPE® within their organizations. InSHAPE® is a wellness program designed to improve the physical health of people with serious mental illness. Organizations who are selected will also participate in a research study to advance understanding of how to implement wellness programs. Applications are due by Friday, June 24.

RCPA will now distribute information on integrated health care. RCPA INFOS and ALERTS will cover research, delivery and training models, policy issues, and other topics that will inform our members (and their physical health care partners) about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.

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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The General Assembly and other community leaders are striving to understand the many challenges facing county and private providers working in the Commonwealth’s child welfare field. The nature of working with the community’s most at-risk children and families, conducting a dramatically growing number of suspected abuse reports, and providing an array of services to children and youth in the dependency and delinquency systems, are daunting professional challenges for case workers and line supervisors. The challenging working conditions, vicarious traumatization, and the ever present fear of an error in judgment or action all contribute to an unacceptable rate of staff attrition across the state. The National Child Welfare Workforce Institute recently issued an infographic looking at the cost of staff turnover and the causes, impact, and potential solutions to this growing problem.

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On May 3, 2016, the Centers for Medicare and Medicaid Services (CMS) issued an update to the additional documentation request (ADR) limits for Medicare institutional providers under the Medicare fee-for-service (FFS) recovery audit program, which will allow recovery audit contractors (RACs) to request more documents from providers who have high claims denial rates.

For example, a provider with a 0 to 3 percent denial rate will receive no additional RAC document requests for three 45-day review cycles, while providers with denial rates between 91 percent and 100 percent could potentially receive RAC document requests of up to 5 percent of their paid claims. A baseline annual ADR limit is established for each provider based on the number of Medicare claims paid in a previous 12-month period. Using the baseline annual ADR limit, which is one-half of one percent (0.5%) of the provider’s total number of paid Medicare claims from a previous 12-month period, an ADR cycle limit is also established. After three 45-day ADR cycles, CMS will calculate (or recalculate) a provider’s denial rate, which will then be used to identify a provider’s corresponding “Adjusted” ADR limit. Recovery auditors may choose to either conduct reviews of a provider based on their adjusted ADR limit (with a shorter look-back period of six months) or their baseline annual ADR limit (with a longer look-back period of three years).

Questions concerning this update can be submitted via email.

Dear Colleagues:

We are excited to announce that we have received 14 responses to the recent request for proposal (RFP) issued for Community Health Choices (CHC). This vital program will allow the departments of Human Services and Aging to serve more Pennsylvanians in their communities and allow consumers to have an active voice in the services they receive.

The Centers for Medicare and Medicaid Services (CMS) released a final rule in the May 4, 2016 Federal Register that updates health care facilities’ fire protection guidelines to improve protections from fire for Medicare beneficiaries in facilities.

The new guidelines apply to hospitals; long-term care (LTC) facilities; critical access hospitals; inpatient hospice facilities; programs for all-inclusive care for the elderly; religious non-medical health care institutions; ambulatory surgical centers (ASCs); and intermediate care facilities for individuals with intellectual disabilities (ICF-IID). This rule adopts updated provisions of the National Fire Protection Association’s (NFPA) 2012 edition of the Life Safety Code, as well as provisions of the NFPA’s 2012 edition of the Health Care Facilities Code.

Some of the main provisions in the final rule include:

  • Health care facilities located in buildings that are taller than 75 feet are required to install automatic sprinkler systems within twelve years after the rule’s effective date;
  • Health care facilities are required to have a fire watch or building evacuation if their sprinkler system is out of service for more than ten hours;
  • The provisions offer LTC facilities greater flexibility in what they can place in corridors;
  • Fireplaces will be permitted in smoke compartments without a one hour fire wall rating;
  • Cooking facilities now may have an opening to the hallway corridor;
  • For ASCs, all doors to hazardous areas must be self-closing or must close automatically; and
  • Expanded sprinkler requirements for ICF-IIDs.

Health care providers affected by this rule must comply with all regulations within 60 days of the May 4, 2016 publication date, unless otherwise specified in the final rule.