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Photo by Markus Winkler on Unsplash

The Office of Mental Health and Substance Abuse Services (OMHSAS) Deputy Secretary Jen Smith recently provided an update on the federal four walls rule. The Centers for Medicare and Medicaid Services (CMS) has issued a proposed rule, or Notice of Public Rulemaking, that could create exceptions to the existing four walls requirement for IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas.

The official language posted to the federal register can be found on page 15 of the Federal Register, which is scheduled to be published on July 22, and is copied below.

“This proposed rule includes a proposal to create exceptions to the Medicaid clinic services benefit four walls requirement, to authorize Medicaid payment for services provided outside the four walls of the clinic for IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas. Our current regulation at 42 CFR § 440.90(b) includes an exception to the four walls requirement under the Medicaid clinic services benefit only for certain clinic services furnished to individuals who are unhoused. We believe these proposed exceptions would help maintain and improve access for the populations served by IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas.”

As a reminder, this is a proposed rule intended to announce and explain CMS’s plan to address the problem. As such, all proposed rules must be published in the Federal Register to notify the public and give them an opportunity to submit comments. The proposed rule and the public comments received on it form the basis of a final rule. More information on the final rulemaking process is available here. Interested parties should provide public comments on this proposed rule to the addresses listed in the federal register by September 9, 2024.

While CMS works through this process, OMHSAS, RCPA, and the PA General Assembly continue efforts to address this through the recently released HCO 3450 legislation that will address the psychiatric outpatient in-office requirements and the Medicaid “4 walls” standards. RCPA will work with our members and the National Council for Mental Wellbeing on developing public comments for submission regarding this proposed rule. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

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The Centers for Medicare & Medicaid Services (CMS) announced the availability of $500 million in grants over the next five years to increase the number of organizations who help people enroll in health coverage through the Federally-Facilitated Marketplace (FFM) on HealthCare’s website. This is the largest funding allocation CMS has made available for Navigator grants to date. With the additional funding, CMS encourages eligible entities and individuals to apply, especially those that focus on education, outreach, and enrollment efforts to underserved and diverse communities.

Please read the the full announcement details and guidance below. If you have questions, please contact RCPA COO and Policy Director Jim Sharp.

What’s new for this year’s Navigator Notice of Funding Opportunity (NOFO)?

  • Focuses on increased participation of smaller, community-based organizations as part of CMS efforts to reach people where they are.
  • Provides longer multi-year grant funding.
  • Shorter and easier to understand application.

Who can apply?
Eligible organizations may include but are not limited to community and consumer-focused nonprofit groups; trade, industry, and professional associations; commercial fishing industry organizations; ranching and farming organizations; chambers of commerce; unions; resource partners of the Small Business Administration; and non-healthcare licensed insurance agents and brokers. Such other entities may include but are not limited to Indian tribes, tribal organizations, urban Indian organizations, and state or local human service agencies.

How much funding is available through this funding opportunity?
CMS expects to award $500 million total over the five-year period of performance, provided in five budget periods of 12 months each; $100 million is available for the first 12-month budget period.

Will there be technical assistance available for applicants?
CMS will hold two technical assistance sessions for potential applicants. These sessions will provide applicants with an overview of this project, relay budget guidance, and review the instructions for applying outlined in the 2024 Navigator funding opportunity. Applicants are encouraged to submit questions in advance of each session to CMS via email.

Technical Assistance Session #1

Technical Assistance Session #2

What is the deadline to submit an application for the NOFO?

Applications must be submitted by July 8, 2024 at 11:59pm ET. You must submit your application through the Grants website. Grants.gov creates a date and time record when it receives the application. If you submit the same application more than once, we will accept the last on-time submission.

For instructions on how to submit in Grants.gov, see the Quick Start Guide for Applicants.

Can my organization help promote the NOFO?

CMS encourages partners to share this listserv with your networks and to use the below social media and attached graphics on your social accounts.

  • CMS has announced $500 million in grants over the next 5 years for Navigator programs, as part of the continued efforts to connect people to the ACA Marketplace and other health coverage options. Learn more.
  • CMS has announced $500 million in grants over the next 5 years for Navigator programs, as part of the continued efforts to connect people to the ACA Marketplace and other health coverage options. These awards mark the first time the grants have been awarded for a period of more than three years of funding, allowing grantees to better retain and add more staff who are trained to help consumers find affordable, comprehensive health coverage.

For more information about the Navigator NOFO, visit the links below:

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Photo by Christina @ wocintechchat.com on Unsplash

The Centers for Medicare and Medicaid Services (CMS) has announced that the next hospital/quality initiative open door forum has been scheduled for June 4, 2024, from 2:00 pm – 3:00 pm. The agenda topics will include:

Register for the webinar.
Meeting ID: 160 823 4591
Passcode: 200020

After registering, you will receive a confirmation email containing information about joining the webinar.

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RCPA’s Brain Injury Committee meeting with representatives from the Office of Long-Term Living (OLTL), originally scheduled for May 22, 2024, has been rescheduled to Wednesday, June 26, 2024, from 10:00 am – 12:00 pm. The meeting will include Deputy Secretary Juliet Marsala and Director of the Bureau of Coordinated and Integrated Services Randy Nolen. Additionally, representatives from the Centers for Medicare and Medicaid Services (CMS) advised they will be attending the meeting.

While this will be a hybrid meeting, members are encouraged to attend in person if possible. Register for the meeting here.

We are asking members to send topics and/or questions to Melissa Dehoff by Friday, May 31, 2024.

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The Office of Developmental Programs (ODP) has received approval from the Centers for Medicare & Medicaid Services (CMS) to make one-time payments for workforce recovery efforts. Payments will be calculated at 6% of the fee schedule revenue received for services rendered between July 1, 2023, through December 31, 2023, for the waiver services listed in the announcement. Don’t miss this opportunity for additional funding for your organization!

The intent of these funds is to assist providers in covering costs related to staffing programs and services. Other than the restriction that payments may not be used to increase or supplement compensation for agency executive staff, there are no specific restrictions, timeframes, or reporting due for these funds other than completing the ODP Workforce Recovery Supplemental Payments survey. ODP has indicated that this revenue would be considered similar to any other service revenue and advises providers to keep a record of how funds were used in the event that they are reviewed as part of the normal claim review process.

As of the morning of May 6, 2024, ODP has received requests from 350 providers. If your MPI is on this file, this will serve as confirmation that your agency’s request has been received. ODP will release a similar file next week prior to the deadline. Late requests will not be accepted. Providers must request the subject payments no later than May 15, 2024. See ODP Announcement 24-041 for additional information.

For any questions, contact Carol Ferenz.

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The Centers for Medicare and Medicaid Services (CMS) has announced the next Medicare Updates and Education webinar. The webinar, “Medicare & Other Programs for People With Disabilities,” is scheduled for May 9, 2024, from 1:00 pm – 2:30 pm and will include information about:

  • What’s Happening in Medicare – May 2024;
  • NTP Announcements and Resources;
  • Women’s Health Week (May 12 — May 18);
  • National Osteoporosis Prevention Month;
  • World No Tobacco Day (May 31);
  • Older Americans Month;
  • Arthritis Awareness Month;
  • Mental Health Awareness Month; and
  • Coverage to Care.

To participate, please register here.

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ADvancing States and the ARPA HCBS TA Collective Announce Release of Report Summarizing State Experiences with ARPA HCBS Initiatives

FOR IMMEDIATE RELEASE
April 23, 2024
CONTACT: Camille Dobson
202-898-2578

ARLINGTON, VA — ADvancing States and our partners in the American Rescue Plan Act (ARPA) home and community-based services (HCBS) Technical Assistance Collective (TA Collective) are proud to release a report sharing findings about states’ experience in implementing their ARPA HCBS initiatives. While the ARPA infusion of federal dollars into HCBS provided an historic opportunity to try bold, new approaches to supporting people in their homes and communities, states were challenged to make systemic improvements given the time-limited nature of the federal funds.

To gather insights into states’ experiences in implementing their ARPA HCBS spending plans, the TA Collective fielded a national survey in early 2024 that aimed to identify successful strategies used by states implementing their ARPA HCBS spending plans, as well as any barriers hindering their success. Based on responses to that survey, this report highlights the challenges and barriers states faced in thoughtfully executing their initiatives in the midst of a public health emergency. The thirty-three states that responded to the survey shared the top barriers to implementing their projects as planned. These barriers include:

  • Delays in obtaining approval from CMS for both their spending plans and the necessary federal authorities to implement those plans;
  • Lack of staff capacity to design and implement complex initiatives;
  • The time it takes to complete state procurement processes to implement projects; and
  • The need to secure legislative approval and/or budget authority before beginning work.

The report also suggests ways to make any future time-limited investments in the HCBS system more effective, including giving states more time to implement, easing the CMS approval process and providing resources to both states and CMS. Moreover, any future investments should be accompanied by a federal evaluation to glean insights into successful interventions that could be replicated across the country.

While this report highlights challenges and lessons learned, it should be noted that, against all odds, states created transformational change with their ARPA spending plan initiatives. Our hope is that this report — and the recommendations contained therein — serves as a roadmap for any future federal investment in the HCBS system.

This report is also informed by the TA Collective’s work supporting states with their ARPA initiative planning, implementation, and evaluation activities and by observations and analysis of state and federal ARPA HCBS activities. It builds upon the TA Collective’s past work including, Efforts to Evaluate the Impact of ARPA HCBS Investments, an issue brief examining state evaluation approaches, and a summary of the work of the HCBS Sustainability Summit, which provided valuable context on sustaining the HCBS commitment fostered by ARPA investments. Both reports can be found here.

We are grateful to The John A. Hartford Foundation, the Care for all with Respect and Equity (CARE) Fund, The SCAN Foundation, and the Milbank Memorial Fund for their support in making the work of the TA Collective possible.

Visit here to read the new report.

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