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The Commission on Accreditation of Rehabilitation Facilities (CARF) recently convened an International Standards Advisory Committee (ISAC) to develop new accreditation standards for an Integrated Primary Care specialty designation. A specialty designation requires a program seeking accreditation to meet an additional set of standards that reflects its expertise in a specific type of service delivery or for a specific population of persons served. Integrating primary care into a mental health or substance use disorder program allows the program to holistically address the behavioral health, physical health, and social needs of the persons served, enhance the level of care provided, and improve outcomes for the persons served. Through the efforts of the ISAC, the program standards for Health Home were also updated. The final standards will be published in CARF’s 2026 standards manuals for Behavioral Health, Child and Youth Services, and Opioid Treatment Programs.
CARF is seeking comments on each of the proposed descriptions and standards. The deadline to submit comments is Tuesday, February 25.
As I watched Pennsylvania Governor Josh Shapiro give his budget address last Tuesday, it occurred to me that the light Pennsylvania government had brightly shined on the addiction epidemic for nearly the past 10 years has greatly dimmed.
In a speech of nearly 11,000 words, not one of them was “addiction.” Not one mention of treatment. No mention at all of an overdose death epidemic. Over the course of a 90-minute budget address, Gov. Shapiro, a man who likes to “get stuff done,” did not even attempt to take credit for overdose death numbers that are trending downward. He didn’t acknowledge them at all.
Granted, the Pennsylvania Department of Drug and Alcohol Programs (DDAP) continues to release pots of opioid settlement and federal money, including State Opioid Response (SOR) funding, into the behavioral health ecosystem, though not all of it is available to DDAP-licensed treatment providers. Counties also continue to spend opioid settlement dollars from multiple sources, including a national settlement with the three largest pharmaceutical distributors that netted more than $1 billion for Pennsylvania.
In arguing that everyone else is legalizing adult-use recreational marijuana, so Pennsylvania should, too, the governor ignores the evidence of the harms of marijuana, including a link between legalized adult recreational marijuana and an increase in adolescent suicides, as well as the broader implications for addiction treatment such that not one dime of the $536,000,000 in estimated Fiscal Year 2025/26 revenue is proposed to be directly allocated to DDAP. Although it appears recreational legalization is inevitable at some point, failing to acknowledge its potential to harm some Pennsylvanians is disingenuous.
Dig a little deeper into the budget, and it looks no brighter for addiction treatment providers.
Behavioral HealthChoices — the name for Pennsylvania’s Medicaid managed care program for behavioral health — currently is in a financial crisis. Pennsylvania counties and behavioral health managed care organizations (BH-MCO) are reporting to be significantly underfunded due to a Department of Human Services’ (DHS) actuarial error made in calculating the effects of the unwind of the Medicaid rolls post-Covid. The underfunding is affecting the counties’ abilities to meet contractual obligations to provide behavioral health services. In other words, the $6.3 billion comprised of state and federal dollars in the current fiscal year (2024/25) budget (see p. 104 of 372 of DHS’s budget book) for Behavioral HealthChoices capitation — capitation being a form of payment based on a complex formula that determines an amount of money needed per Medicaid recipient per month — is not enough money to pay for addiction and mental health treatment for everyone who wants and needs it.
Although we see an 18 percent increase in the HealthChoices capitation line item that amounts to $660 million in state dollars in the governor’s proposed executive budget, significant questions are still unanswered and even bigger concerns remain.
For example, we do not know how much of the 18 percent increase is earmarked for Behavioral HealthChoices, which is concerning because the Physical HealthChoices program also is underfunded, and the Physical HealthChoices program is a significantly higher expenditure. Estimates suggest that the Behavioral and Physical HealthChoices systems combined need an additional $2.5 billion (state and federal combined) in the current calendar year, which is partly funded by two separate fiscal year budgets, to meet their obligations to Pennsylvania’s most vulnerable. There is a $230,000,000 supplemental payment in the proposed budget, which would help to address the immediate need for additional funds in the current fiscal year, but we are hearing only a small percentage of this is for the HealthChoices issue.
As a result of the underfunding and uncertainty, BH-MCOs and primary contractors have announced to addiction and mental health treatment providers that they will not receive any increases in reimbursement rates in 2025, despite escalating provider costs. At the same time, in certain regions of the Commonwealth, addiction and mental health treatment providers are beginning to report increasing challenges in getting appropriate treatment authorized (e.g., decreased lengths of stay, increased denials). Although anecdotal, RCPA will continue to have these discussions and look to substantiating data.
The current HealthChoices crisis has been building since early 2024 and has caused much anxiety. So far, the proposed 2025/26 budget only exacerbates the worry. Add in the federal Medicaid and grant funding uncertainty coming out of Washington, DC following recent executive orders that potentially put funding streams like the Substance Use Prevention, Treatment, and Recovery Services Block Grant and SOR dollars at risk, and the calamity grows exponentially. Right now, we are looking at a real possibility of ongoing behavioral health service cuts that would be akin to rationing of care.
At this point, I am left with a few fundamental questions. How is $6.3 billion not enough to provide behavioral health services — addiction and mental health treatment — to Pennsylvania’s Medicaid population? How could the state have been so wrong on its calculations? How sustainable is a behavioral health system that needs at least upwards of $7 billion per year? Does the legislature have an appetite for such a system?
And, perhaps most importantly, what are the implications for the future of addiction treatment and the sustainability of the system as we currently know it? Beyond the funding crisis, the field continues to beg for relief from administrative burden and crushing oversight, pleas that have amounted to shouting into the void.
With DHS’s budget hearings coming up in early March in front of the Senate and House Appropriations Committees, I would expect the legislature to also be asking these same questions. Stay tuned.
RCPA Partner Eleos knows how to throw a party, and their virtual event next month is no exception. Join them for the debut of Eleos Compliance at their Winter 2025 Launch Event.
This 1-hour virtual event will kick off with a product launch video, then AI experts and real-life Eleos customers will present New Year, New AI Advancements with Eleos Documentation and Compliance.
Eleos Compliance is a new AI-powered solution that enables behavioral health CDI and CQI teams to continually scan 100% of notes for six of the most common compliance red flags. By quickly identifying high risk areas, there’s more time to spend on staff education and training to prevent further issues.
Register now to join them on February 19 at 12:00 pm Eastern, when Alon Joffe, Eleos Co-founder and CEO, will be joined by Eleos’ customers Rony Gadiwalla, CIO at GRAND Mental Health, and Tom Morgan, CIO at Merakey, to:
It’s a great opportunity to get familiar with all the operational benefits specialized AI has to offer — and to discover why Eleos is the behavioral health technology providers (and leaders) actually love.
Stay tuned for their next launch event in Q2!
Register for this exciting event now. If you can’t make it to the live event, you’ll receive an on-demand recording afterwards.
The Department of Human Services (DHS) Secretary Val Arkoosh met with systems stakeholders to provide an overview of the Governor’s proposed 2025/26 DHS budget. The Secretary began by reviewing the accomplishments of DHS under the administration and highlighted areas around Medicaid, systems enhancements, and the expansion in the delivery of services to Pennsylvanians.
The projected spending across DHS showed an investment of $21.17B, with the following breakdowns:
This budget number represents a $1.95B increase over last year’s executive budget. The most significant increases included:
RCPA submitted questions during the webinar in an effort to gain greater clarity on the proposed $2.4B increase in the Health Choices capitation. Several questions remain unanswered, including:
There was clarification on the proposed $170M increase in the ID/A budget, but Secretary Arkoosh stipulated that this was not new investments but rather funds to sustain last year’s increase.
The remainder of the webinar was spent outlining current DHS initiatives, including the Keystones of Health 1115 Waiver, which was approved in December 2024. This year’s priority will focus on reentry services as well as planning for future implementation. The Secretary concluded her comments supporting the minimum wage increase, reinforcing the workforce infrastructure, and tackling Commonwealth-wide challenges.
The DHS Bluebook is scheduled for release in the coming weeks and will provide line item details of the budget. RCPA will continue to work with DHS and PA legislators on the budget specifics and our ongoing advocacy efforts. You can view the DHS budget webinar here.
RCPA will continue to update members on the budget as information becomes available. If you have further questions, please contact your RCPA Policy Director.
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:
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.
The Pennsylvania Department of Drug and Alcohol Programs (DDAP) announced a joint initiative with Carlow and Waynesburg Universities to address the shortage of qualified addiction professionals within Pennsylvania’s behavioral health workforce.
Funded by DDAP, this pilot program will focus on the recruitment and retention of behavioral health professionals by providing financial assistance for participating students’ educational expenses. At its core, this initiative is designed to strengthen the substance use disorder (SUD) workforce pipeline by financially supporting master’s-level students at Carlow and Waynesburg Universities. Through the DDAP funding, both universities will offer tuition assistance, a stipend during the students’ practicum/internship with a community-based treatment provider, and additional SUD-related training offered by DDAP for students who qualify under each university’s respective programs.
The Substance Abuse and Mental Health Services Administration (SAMHSA) is welcoming public comments on the draft SAMHSA Now Accepting Public Comments on Draft Model Behavioral Health Crisis Services Definitions.
SAMHSA developed the draft Model Behavioral Health Crisis Services Definitions document for state, territory, Tribal, and local entities; crisis services providers; public and private payers; regulators; and help seekers and their supporters to clarify and distinguish the different types of crisis services for people across the nation.
Interested people are invited to submit written comments for these draft definitions from Thursday, November 21, 2024, through Thursday, December 5, 2024, at 11:59 pm ET.
For more information on the definitions and to submit comments, please visit the Model Behavioral Health Crisis Services Definitions web page on the Crisis Systems Response Training and Technical Assistance Center website at the link below.