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The Office of Long-Term Living (OLTL) is partnering with the Office of Developmental Programs (ODP), The Institute on Disabilities at Temple University, College of Education and Human Development, and the University of Kansas Center on Disabilities’ State of the States team to host Pennsylvania Technology Summits as part of a statewide initiative called PA Tech Accelerator.

The goal of the Summits is to expand the awareness of, and access to, assistive technology and remote technologies in order to build capacity of technology users throughout the Commonwealth of Pennsylvania.

The Summits will be held on March 6, 2025, in Philadelphia and March 13, 2025, in Pittsburgh. To attend, please register here.

The Summits will feature a keynote address by Rebekah Taussig, PhD; a panel of technology users giving advice, sharing their stories, and answering questions; and vendors showcasing services, devices, and solutions.

Who is invited?

  • People with disabilities and their families.
  • Direct Support Providers and professionals working with people with disabilities, such as Direct Care Workers, Direct Support Professionals, Support Service Professionals, Supports Coordinators, Job Coaches, and healthcare professionals.
  • Organizations and providers who serve people with disabilities.
  • Policymakers, advocates, and allies for people with lived disability experience.
  • Students looking to work in disability-related fields.
  • Anyone interested in technological supports for people with disabilities.

If you have additional questions about the Summit, please contact Kristy Crocetto at (215) 204-1356 or via email.

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Separate Notice of Proposed Rulemaking Would Completely Eliminate In-Person Evaluation for Prescribed Medications

The Substance Abuse and Mental Health Services Administration (SAMHSA) and the U.S. Drug Enforcement Agency (DEA) this month released three new prescribing-related telehealth rules.

The Final Rule On the Expansion of Buprenorphine Treatment Via Telemedicine Encounter authorizes DEA-registered practitioners to prescribe Schedule III-V controlled substances, including buprenorphine, for opioid use disorder, through an audio-only encounter for an initial six-month supply (split among multiple prescriptions over six calendar months). Although the rule has been published in the Federal Register and is set to take effect February 18, 2025, President Trump issued a regulatory freeze pending review that requires executive departments and agencies to consider postponing the rule’s effective date for 60 days to review “any questions of fact, law, and policy that the rules may raise.”

Under this final rule, practitioners must first review the patient’s prescription drug monitoring program data for the state in which the patient is located during the telemedicine encounter. Additional prescriptions can be issued under other forms of telemedicine as authorized under the Controlled Substances Act, or after an in-person medical evaluation is conducted. SAMHSA advises practitioners to check with their state medical boards about what specific telemedicine practices are currently authorized for prescribing controlled medications after this six-month period. RCPA has reached out to the Pennsylvania Department of State to determine whether there are telemedicine pathways in place to enable prescribing beyond the initial six-month period without an in-person examination.

This regulation also requires the pharmacist to verify the identity of the patient prior to filling a prescription. This final rule does not apply to practitioners who have already evaluated their patient in person.

Separate Proposed Rule Would Completely Eliminate In-Person Evaluation for Prescribed Medications

However, a separate proposed rule on Special Registrations for Telemedicine and Limited State Telemedicine Registrations would establish special registrations that will permit a patient to receive prescribed medications through telemedicine visits without ever having an in-person medical evaluation from a medical provider. According to the DEA, the special registration is available to medical providers who treat patients for whom they will prescribe Schedule III-V controlled substances. An Advanced Telemedicine Prescribing Registration is available for Schedule II medications when the medical practitioner is board certified in one of the following specialties: psychiatrists; hospice care physicians; physicians rendering treatment at long term care facilities; and pediatricians for the prescribing of medications identified as the most addictive and prone to diversion to the illegal drug market. This regulation allows specialized medical providers to issue telemedicine prescriptions for Schedule II-V medications.

DEA is seeking public comment by March 18, 2025, on additional medical specialists that should be authorized to issue Schedule II medications. Public comments will also be requested on additional patient protections for the prescribing of Schedule II medications by telemedicine, including whether the special registrant should be physically located in the same state as the patient being prescribed Schedule II medications; whether to limit Schedule II medications by telemedicine to medical practitioners whose practice is limited to less than 50 percent of prescriptions by telemedicine; and the appropriate duration needed for the rules’ provisions to be enacted.

For the first time, online platforms that facilitate connections between patients and medical providers that result in the prescription of medications will be required to register with DEA. This is critical, as DEA has found some unscrupulous medical providers on online platforms have used flexible telemedicine rules to put profit ahead of the well-being of patients.

The special registration rule will also require the establishment of a national PDMP to help the health industry protect against abuse and the diversion of controlled substances into the illegal drug market. A national PDMP will provide pharmacists and medical practitioners with visibility of a patient’s prescribed medication history.

Additionally, a Final Rule on Continuity of Care Via Telemedicine for Veterans Affairs (VA) patients was issued, allowing practitioners acting within the scope of their VA employment to prescribe controlled substances via telemedicine to a VA patient with whom they have not conducted an in-person medical evaluation. VA practitioners are permitted to prescribe controlled substances to VA patients if another VA practitioner has, at any time, previously conducted an in-person medical evaluation of the VA patient, subject to certain conditions.

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The Office of Developmental Programs (ODP) has shared ODPANN 25-010. This announcement notifies trainers of the following:

  • The 2022 student courses deadline has been extended to February 28, 2025, due to system issues experienced after January 13, 2025;
  • Fillable forms are now available on the Trainer Resources page; and
  • Provides guidance on the number of attempts permitted for each Medication Administration course before requesting a course reset from the Helpdesk.

Please view the announcement for information and details.

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The Office of Long-Term Living (OLTL) recently shared additional guidance for providers related to the Centers for Medicare & Medicaid Services (CMS) Home and Community-Based Services (HCBS) Settings Final Rule.

This clarification applies to Residential Habilitation and Personal Care Home Providers.

Regulations at 42 CFR 441.301(c)(4)(vi)(B) require that participants in residential settings have the ability to close and lock doors within their living units. As a part of the Office of Long-Term Living (OLTL) residential provider reviews, it was found that several sites did not meet this requirement. As remediation, some providers opted to have participants sign a form stating that they do not wish to have a lock on their doors, which OLTL’s settings review panel accepted as compliant.

The Centers for Medicare & Medicaid Services (CMS) has reviewed OLTL’s oversight activities and has deemed that participant sign-off waiving installation of locks does not sufficiently satisfy the requirement. CMS has determined that all doors with access to participant units or private spaces (such as a bedroom) must have locks installed. The participant’s choice is whether to utilize the lock or not. Based on this feedback, as OLTL moves forward with ongoing oversight of HCBS settings requirements, all doors to participant units/private spaces in residential settings will be required to have working locks in order to be deemed compliant for future settings reviews.

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The Substance Abuse and Mental Health Services Administration (SAMHSA) has released updated National Behavioral Health Crisis Care Guidance aimed at enhancing the nation’s response to mental health and substance use crises. This effort is part of an ongoing initiative to address record-high rates of suicide and overdose, while also building on the transition to the 988 Suicide & Crisis Lifeline in 2022.

The updated National Behavioral Health Crisis Care Guidance is comprised of three key documents. These are the 2025 National Guidelines for a Behavioral Health Coordinated System of Crisis Care, Model Definitions for Behavioral Health Emergency, Crisis, and Crisis-Related Services, and a draft Mobile Crisis Team Services Implementation Toolkit, which is open for public comment until March 21, 2025. Together, these resources set forth a framework for reshaping community crisis care systems and ensuring timely access to care.

SAMHSA’s framework is built on three foundational pillars essential to an integrated crisis care system:

  1. Someone to Contact — The 988 Lifeline and other hotlines provide immediate, accessible support for individuals in crisis.
  2. Someone to Respond — Mobile crisis teams are a critical component, delivering rapid, on-site assistance to de-escalate crises and connect people with appropriate care.
  3. A Safe Place for Help — Stabilization services offer facilities where individuals in crisis can access care, resolve crises, and transition to ongoing treatment when necessary.

The new guidance emphasizes scalability and sustainability for these systems, equipping state, tribal, local, and territorial governments with the tools needed to design and improve crisis care services. It also provides practitioners with actionable steps for delivering quality care.

The 988 Suicide & Crisis Lifeline, launched nationwide in 2022, represents a significant shift in behavioral health crisis response. The easy to remember three digit number aims to provide individuals with immediate access to trained crisis counselors, significantly reducing reliance on law enforcement and emergency departments for mental health emergencies. The updated guidance builds on this progress while addressing the urgent need for comprehensive crisis care systems.

The guidance reflects substantial input collected through listening sessions, expert consultations, and public feedback. Crucially, it underscores the importance of a coordinated, flexible, and compassionate approach to behavioral health crises at a time when the nation continues to grapple with increasing demand for services.

With public comments being sought on the draft Mobile Crisis Team Services Implementation Toolkit, SAMHSA aims to refine and finalize tools that advance the capacity of crisis teams to stabilize situations and connect individuals with long-term support. Please forward your comments to RCPA COO and Mental Health Services Director Jim Sharp for inclusion in the RCPA response to SAMHSA. This will addressed in the February 18, 2025, RCPA 988/Crisis Services meeting. You can register for the meeting here.

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The Long-Term Services and Supports (LTSS) Subcommittee has released its agenda for the February 5 virtual meeting. The meeting will have no onsite options for attendance and will be held via webinar at 10:00 am – 1:00 pm. You can view the agenda, which includes the webinar link, here.

The key agenda items are:

  • Office of Long-Term Living (OLTL) Updates
  • Assisted Living Residences — In Lieu of Services Policy Updates
  • Assisted Living Residences and Personal Care Homes — MCO Updates

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The Office of Long-Term Living (OLTL) Critical Incident Management Unit monitors provider compliance in the application of guidance specific to critical incident management. OLTL has identified compliance concerns and is issuing the following clarification.

This communication focuses on required critical incident notification by provider agencies to the participant’s assigned service coordinator and the documentation of such notification in the Enterprise Incident Management (EIM) entry. The OLTL Critical Incident Management Bulletin, which is also available on OLTL’s website, indicates the following:

  • Within 48 hours, the Managed Care Organization (MCO), Service Coordinator (SC), provider agency that discovers or has independent knowledge of the critical incident is to submit the First Section of the critical incident report to OLTL using OLTL’s critical incident management system. If the critical incident was discovered on a weekend or holiday, the 48 hours begin at 12:00 am on the first business day after discovery of the critical incident.
  • Providers must inform the participant’s SC within 24 hours of discovering or first learning of a critical incident.

Notification to the participant’s SC that a critical incident was discovered must not be made using the HHAeXchange system. The required notification to the participant’s SC must be made by telephone call, electronic mail communication, or any other method that is agreed upon by all parties involved, excluding the HHAeXchange system.

In addition, the notification by the provider to the participant’s SC that a critical incident was discovered must be clearly documented in the EIM incident report, specifically within the “Agencies Contacted” page. Instructions are below:

  1. Enter the first name of the SC in the Person Contacted (First Name) Field.
  2. Enter the SC’s last name in the Person Contacted (Last Name) Field.
  3. Enter the contact phone number. Note that the email address field is not mandatory; however, it should be completed when notification to the SC was made via email.
  4. Click the SAVE button when all information has been entered.

See an example of page completion below.

Providers who are experiencing difficulty meeting the Critical Incident Management Bulletin requirements may email concerns to the resource account. Additionally, questions related to critical incidents may be emailed to the Critical Incident Management team member identified in any case-specific communication.

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You’re Invited!

Thursday, January 30, 2025
12:00 pm – 1:00 pm

The Office of Developmental Programs (ODP) would like to invite you to the Performance-Based Contracts Webinar for Individuals and Families. This webinar will provide individuals and families with a general overview of how the Office of Developmental Programs (ODP) proposes to implement Performance-Based Contracting for residential services effective January 1, 2025.

Audience: Individuals, caregivers, and families.

Register Here

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