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RCPA, in partnership with its members, has submitted public comments in response to the Office of Mental Health and Substance Abuse Services’ (OMHSAS) proposed Licensure of Crisis Intervention Services regulations. RCPA thanks OMHSAS for their effort in creating licensing standards that align with national best practice standards for the Commonwealth’s crisis intervention system and their receptivity to further recommendations from current crisis providers.

The proposed regulations have been reviewed by members of RCPA’s 988/Crisis Work Group, who are some of the most experienced and knowledgeable leaders in Pennsylvania’s Crisis System. With their expertise, RCPA developed comments and recommendations to guide the State towards meaningful regulations for Crisis Intervention Licensure.

The largest areas of concern in the proposed regulations are in regard to the staffing requirements and fiscal impacts, which led to the following recommendations:

  • Flexibility in the staffing requirements to account for the national behavioral health workforce shortage.
  • A transparent cost analysis of the true cost of implementing the regulations to ensure that the regulations do not become an unfunded mandate.
  • Increased clarity on the role of community outpatient clinics that are not connected to larger hospital systems.
  • The assembly of a stakeholder work group, similar to the forums that OMHSAS convened for their PRTF regulations, to ensure that provider and other stakeholder concerns are addressed before promulgation of the regulations.

Read RCPA’s full public comments here. Contact Emma Sharp with any questions.

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On July 14, the National MLTSS Health Plan Association submitted comments on the “Preserving Medicaid Funding for Vulnerable Population – Closing a Health Care-Related Tax Loophole” proposed rule. Per the Association:

This rule proposes to refine how CMS evaluates whether a health care-related tax is considered “generally redistributive.”

In our comments, we noted that we appreciate CMS’ efforts to strengthen the oversight and quality of Medicaid programs but raised concerns about the timelines and administrative burden on states, as well as the potential impact on individuals receiving long term-services and supports (LTSS).

The recommendations included:

  • Extending the transition period to three years for all states.
  • Providing clear implementation guidance and technical assistance to states.
  • Postponing finalization of the rule until further research and data analysis on provider-related taxes and impacts are conducted.

Read the full letter here.

In Pennsylvania, this rule would impact participants’ funding of approximately $1B in federal matching funds for HealthChoices, Community HealthChoices, and Behavioral HealthChoices. No immediate action is required. If you have any questions, contact Fady Sahhar.

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Image by Werner Moser from Pixabay

Spotlight PA is covering Pennsylvania’s drug addiction crisis, its impact on children and families, and the potential to use opioid settlement funds to address associated problems. To help inform its coverage, the publication is seeking stories about how the opioid epidemic and addiction has affected Pennsylvanians, including frontline perspectives from healthcare workers, child welfare workers, counselors, first responders, and others addressing these issues regularly.

More information, including a form for submitting responses, can be found on Spotlight PA’s website.

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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.

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RCPA submitted comments to the Office of Developmental Programs (ODP) regarding the proposed amendments to the Consolidated, Person/Family-Directed Support (P/FDS), Community Living, and Adult Autism Waivers to allow providers to request a one-time supplemental payment to cover recruitment, retention, and any unusual staffing expenses resulting from the COVID-19 pandemic for direct support professionals, frontline supervisors, or supports coordinators.

ODP will review and consider all comments received by 11:59 pm today.

While we are grateful for the opportunity for members to access additional funds this fiscal year, we wanted to express our strong belief that the calculation of the dispersal of funds includes the NEA rates. There has been discussion with ODP staff that indicates they may not be including those amounts in the calculation.

Please see our comments and feel free to share your thoughts with ODP as well by 11:59 pm tonight.

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The Centers for Medicare and Medicaid Services (CMS) recently released a Request for Information (RFI) requesting public comments on the Medicare Advantage program. CMS is asking for input on ways to achieve the agency’s vision so that all parts of Medicare are working towards a future where people with Medicare receive more equitable, high quality, and person-centered care that is affordable and sustainable, essentially asking for ways to strengthen this program.

CMS’s intent is to better align the Medical Assistance (MA) program with the agency’s vision for Medicare and the CMS Strategic Pillars. CMS is strongly emphasizing the importance of stakeholder comments for this process. This openness to feedback presents MA plans, providers, and other stakeholders an opportunity to inform the agency’s early thinking as it considers potential regulatory actions impacting supplemental benefits, value-based contracting arrangements, risk adjustment, prior authorization, and marketing among other issues.

CMS will accept comments on the RFI until August 31, 2022.

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