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Throughout 2021, RCPA’s top priority for its drug and alcohol treatment provider members has been the ASAM transition. Most specifically, RCPA has been working against requirements the Department of Drug and Alcohol Programs (DDAP) is imposing on providers that go beyond ASAM Criteria. Although RCPA members support the ASAM Criteria as a placement, continued stay and discharge tool, changes to intensive outpatient counselor-to-client ratio, required daily therapeutic hours at the residential level of care, and credentialing requirements all constitute unlawful rulemaking. In other words, DDAP and the Department of Human Services (DHS) have circumvented the regulatory review process in creating requirements that should have been put before the Independent Regulatory Review Commission (IRRC). DDAP’s and DHS’s failure to do so means that costs to implement and stakeholder input, among other considerations, were ignored.

In the months-long effort to reach a more manageable transition for providers, December is shaping up to be a decisive month. On Oct. 28, Commonwealth Court heard a request for a preliminary injunction filed by the Drug and Alcohol Service Providers Organization of Pennsylvania (DASPOP) that would stop implementation of the overreaching requirements. In its defense, DDAP asserted that the requirements in question are not requirements at all but actually guidelines that are not subject to IRRC approval. Yet with DDAP in the lead, these “guidelines” have been placed in provider contracts with single county authorities (SCAs) and behavioral health managed care organizations, and deadlines for compliance with them have been set by DDAP. Ultimately, the court will decide whether the actions of DDAP and DHS have created binding norms using the Medicaid managed care system as a workaround to the lawful regulatory review process. As of this writing, Commonwealth Court still had not made a decision.

On a parallel track, House Bill 1995 is making its way through the legislature. Rep. Carrie Lewis DelRosso introduced legislation that would require DDAP to undergo the regulatory review process any time it makes changes that would affect licensed drug and alcohol providers, including changes such as the requirements DDAP is imposing as part of the ASASM transition. DDAP’s overreach on the ASAM transition was the impetus for Rep. Lewis DelRosso’s bill. Despite facing strong opposition from the administration and the SCAs, the bill passed out of the House of Representatives into the Senate, which is expected to consider the bill when it is back in session Dec. 13 – Dec. 15.

The timing of decisions related to DASPOP’s lawsuit and Rep. Lewis DelRosso’s legislation is made all the more critical by the expiration of the ASAM alignment extension, which the legislature allowed for earlier this year. Through Act 70, the legislature created a process whereby providers could apply for an ASAM alignment extension to Jan. 1, 2022. Providers that applied for and were granted the extension do not have to align with DDAP’s requirements on ratio, daily therapeutic hours, and credentialing until Jan. 1.

These overreaching mandates come at a time when addiction treatment providers are struggling with an unprecedented workforce shortage. Any mandates that force the hiring of additional staff only exacerbate the issue and narrow access to treatment. In addition, the treatment system continues to reel from the Covid pandemic and the ongoing fallout from it. By imposing these requirements on a chronically underfunded system, DDAP and DHS are further weakening a system so desperately needed by so many Pennsylvanians. With more than 100,000 Americans having died from drug overdose in the 12 months ending April 2021, the administration’s unlawful actions have the real possibility of contributing to, rather than lowering, this shameful record.

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Image by Gerd Altmann from Pixabay

The Western Pennsylvania Disability History and Action Consortium Project Director
(20 hours/week)

Function:
The Project Director is responsible for the overall operation of the Western Pennsylvania Disability History and Action Consortium (WPDHAC). The mission of the WPDHAC is to preserve and honor the historic struggle of people with disabilities to attain human and civil rights and to share the lived experiences of today, in order to promote community access, participation and equal opportunity. Reports to the Executive Committee of the WPDHAC Steering Committee.

Responsibilities:

  1. Works with the Executive Committee of the Steering Committee to set long-term goals and the strategic plan for the Consortium.
  2. Identifies sustainable funding sources, develops and submits grant proposals to funders. Meets with funders upon request.
  3. Prepares and submits required reports to funders.
  4. Oversees progress on Consortium projects and benchmarks.
  5. Maintains budgets and creates financial reports for funders and Achieva, the fiscal sponsor.
  6. Oversees marketing, public relations, and social media for WPDHAC.
  7. Manages virtual and in person events and programs.
  8. Works with Achieva to hire, supervise and manage staff and independent contractors.
  9. Oversees Steering Committee members and community volunteers in the development and implementation of Consortium projects.
  10. Serves as spokesperson for the Consortium with the media, funders and in other contexts.
  11. This job description is not designed to cover or contain a comprehensive listing of activities, duties, or responsibilities that are required of the employee for this job. Duties, responsibilities, and activities may change at any time with or without notice.

Qualifications:
The equivalent of a Bachelor’s degree and/or 1–2 years of related experience with fundraising, strategic planning, volunteer and staff management, and budget management. Proven ability to problem-solve, and work effectively with funders and other professionals. Excellent written and oral communication skills. Ability to set priorities and organize multiple tasks. Ability to work well both independently and with others. Ability to travel locally. Computer literacy. Act 33/34 clearances.

Send Resume and Salary Requirement to:
Nancy Murray, Senior VP of Achieva
711 Bingham Street
Pittsburgh, PA 15203
[email protected]

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Image by Gerd Altmann from Pixabay

October 22, 2021

Ladies and Gentlemen:
I alert you to the transactions described below.

Transaction

Pittsburgh-based Abraxas Youth and Family Services (“Abraxas”) has entered into a definitive affiliation agreement with Inperium, Inc. Founded in 1973, Abraxas is a nonprofit provider of residential, community-based, detention and alternative education services to over 6,500 youth, adults and families in Pennsylvania, Ohio, Illinois, South Carolina, and Colorado. The transaction, which will add $85 million to the consolidated revenues and $10 million to the consolidated net assets of the Inperium Constellation, is expected to close on December 31, 2021.

Jon Swatsburg, Abraxas President and CEO commented, “Inperium is a fantastic strategic partner that will allow Abraxas to continue to build on its 48-year history serving youth, adults and families without sacrificing its Board structure, culture and identity. I am excited for our employees, clients, and customers for the opportunity to leverage both companies’ strengths and I want to thank Ryan, Jeff and the Inperium team for their work leading to this deal. I am thrilled to continue in my role as CEO of Abraxas while also working directly with Ryan as Inperium’s Chief Development Officer.”

Inperium COO Jeff Giovino, who effectuated the transaction, commented: “Abraxas CEO Jon Swatsburg and I have maintained a professional relationship for over 20 years. I am thrilled that Abraxas is becoming an affiliate of Inperium. This partnership will provide Abraxas the ability to grow its existing services into new markets and states.”

Discussing this latest transaction, Inperium Founder and Chief Executive Ryan Smith commented: “The Abraxas affiliation both extends and expands the services of the Inperium Constellation in important ways. Together with our recent acquisition of the businesses of Connections Community Support Programs in Delaware, the Abraxas affiliation adds $150 million to Inperium’s annualized revenues. This growth benefits every member of the Constellation by enabling us to allocate fixed overhead over a significantly larger revenue base. I anticipate Inperium will close at least two additional transactions this fiscal year as our pipeline of affiliation prospects remains robust.”

About Inperium, Inc.

Inperium, the nation’s fastest growing nonprofit human services organization, offers a broad array of human services, including programs that improve the quality of life for children and adults with intellectual or developmental disabilities or behavioral health needs. Additional information concerning Inperium may be found on its website.

About Angler West Consultants

Angler West is an intermediary that assists nonprofit consolidators in the execution of acquisition and divestiture programs involving specialty healthcare and human services organizations. Founded in 1996, Angler West has the transaction experience and industry relationships to help your company grow profitably. To discuss how we can assist in your business development efforts, contact the undersigned.

Angler West Consultants, Inc.
J. Kevin Fee
President
Email
Phone: 215-630-8336

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Two of the most significant public health crises of our lifetime – the Covid pandemic and the opioid overdose death epidemic – have hit the addiction treatment system and the patients it serves especially hard. Add to a chronically underfunded system struggling with an alarming workforce shortage the Pennsylvania Department of Drug and Alcohol Programs’ (DDAP) ill-timed transition to the American Society of Addiction Medicine (ASAM) Criteria that includes unfunded mandate add-ons, and the very integrity of the system is at risk. Fortunately, the federal government has stepped in with resources to combat the epidemic and the pandemic. In fact, by this fall, DDAP will have received just this year more than $100 million in special grant money, including $55 million in Covid supplemental funds and $48 million in American Rescue Plan (ARP) dollars. Now, perhaps more than ever, addiction treatment providers desperately need this money. Unfortunately, none of it has made its way to providers yet.

Despite urgent pleas for help – by way of either rate increases, regulatory relief, or other one-time funding infusions to address multiple short-term crises within the system – the Wolf administration has not operated with urgency. Consider that in early June, the Substance Abuse and Mental Health Services Administration (SAMHSA) approved DDAP’s plan to spend the $55 million in Covid supplemental money. Nearly two months later, the most-needed chunks of those dollars — $10 million in provider stabilization payments and $15 million in workforce development funding – have not made their way to providers. The $10 million in provider stabilization funds is expected to be available to providers in October, more than four months after their approval. There is no estimate on when the $15 million in workforce development dollars will be available.

Providers recognize that this $25 million across a system comprised of approximately 800 licensed facilities is no panacea. But what message is being sent when providers continually stress to DDAP the real possibility of program closures because of burdensome mandates, no counselors, and insufficient reimbursement rates while money sits unused? There is a disconnect between the front lines and the regulators.

Then there is the $48 million in ARP money. It is supposed to be available to DDAP by the fall, at which point it’s entirely possible that the department will be sitting on more than $100 million (not to mention the $5 million annually for the next five years from the McKinsey opioid settlement) with none or very little having reached the providers.

Although the governor had sought to extend his latest opioid disaster declaration beyond August 26, now that his ability to do so unilaterally has been limited to 21 days, the legislature said “no.” While on the surface this would seem problematic for the D&A treatment community, this may not be the case. When RCPA informally polled its provider members on what the end of the opioid disaster declaration would mean, none who responded could identify any practical or operational benefit of the declaration. Those things they did mention – broader access to naloxone, for example – are not tied to the declaration.  Thus, while well intended, from a day-to-day standpoint for D&A treatment and access to services, there are many other ways that the administration and the legislature could greatly assist without necessitating a further extended emergency declaration.

The provider system needs meaningful help, including a more transparent, effective reimbursement rate-setting process and relief from burdensome mandates that create barriers to effective treatment. We have demonstrated repeatedly that the very thing DDAP purports to seek through its mandates – improved quality – will actually be negatively affected, because providers cannot find staff to meet these new mandates or afford to pay them, in part, as a result of a vastly changed pandemic job market. Ultimately, access to treatment will be limited, and Pennsylvania’s most vulnerable citizens will continue to be the collateral. The fact that funding meant to ease these real burdens has not reached the providers yet is salt in the wound. RCPA will continue its work educating the legislature on the tenuous situation in an effort to get the help that we need.

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In early 2017, the Pennsylvania Department of Drug and Alcohol Programs (DDAP) announced the beginning of a major transition to the ASAM Criteria, a comprehensive set of guidelines governing the level of care most appropriate for patients and the services provided at those levels. Improved quality of care through outcome-oriented and results-based treatment was among the many changes this transition promised.

DDAP cited several reasons for the change, from ensuring the necessary federal Medicaid funding through an 1115 waiver to support the continuation of residential services, to the consistency that the most widely used system would bring to the Pennsylvania provider and payer world.

Today, the commonwealth’s addiction treatment system is little more than four months away from DDAP’s July 1 deadline for implementation, yet providers still have questions about the specifics of many of the changes taking place. Some of these changes go beyond ASAM Criteria, creating additional questions and confusion.

And as providers analyze the cost implications of the change, driven by increases in required treatment services, decreases in counselor-to-patient ratios, and requirements for more highly trained counselors, therapists, and doctors, it is becoming clear to them how significant those costs will be. With no plan from the commonwealth to increase reimbursement rates to cover these mandates and a funding environment in which reimbursement is already often inadequate in comparison to costs, providers are frustrated. Some have lamented the possible closure of facilities because of the exorbitant cost increases. Yet perhaps most troubling, at a time when the Covid pandemic is helping to drive overdose deaths to a level not seen since the peak of the opioid overdose death epidemic in 2017, these costs could limit patient access to care.

Despite these issues, RCPA drug and alcohol treatment provider members support efforts to increase quality in Pennsylvania’s addiction treatment system. They recognize the strength of the ASAM Criteria. But to put their full support behind ASAM, they need reimbursement increases to cover the costs and favorable resolution of the mandates that go beyond the ASAM Criteria in a way that seriously considers provider input.

RCPA enjoys and appreciates strong working relationships with DDAP, the Department of Human Services and its Office of Mental Health and Substance Abuse Services, county drug and alcohol administrators, and the commonwealth’s Medicaid managed care organizations. In the spirit of avoiding any unintended consequences and ensuring a quality system is available to continue to treat all Pennsylvanians in need of addiction treatment services at all levels of care, RCPA will continue to collaborate with these groups to highlight the issues and identify and work toward solutions, all the while bringing to bear its resources to effect these changes on behalf of its members.

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The Intensive Behavioral Health Services (IBHS) regulations went into effect on January 17, 2021 after a one-year implementation period. Recently, the regulations have gone through some adaptations to address the clinical needs of children and families. One such change was the release of a bulletin outlining the approval to deliver 1:1 services for both ABA and Individual IBHS Services in a community or site-based setting, as well as the compatible billing codes.

These bulletins are both retroactive to January 17, 2021; the full bulletins can be found below.

As part of the ongoing IBHS implementation, the Office of Mental Health and Substance Abuse Services (OMHSAS) also released an updated IBHS Frequently Asked Questions (FAQ) Guide. This guide represents a composite of updated inquiries regarding the standards and will be updated as a companion piece to the implementation.

RCPA continues its efforts to support our members in the IBHS implementation through its IBHS Work Group, including work to create an equal billing platform for the delivery of individual services like its ABA counterpart. For more information on IBHS, please contact RCPA Children’s Policy Director Jim Sharp.

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