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Tags Posts tagged with "Crisis Intervention"

Crisis Intervention

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The Independent Regulatory Review Commission (IRRC) has published their comments on the proposed Licensure of Crisis Intervention Services regulations, summarizing the comments submitted by the stakeholder community during the public comment period. As part of the IRRC’s regulatory process, OMHSAS will have to address and clarify any questions that have been submitted.

Similar to RCPA’s public comments, the IRRC response highlights concerns regarding the proposed rulemaking in the following areas:

  • Potential issues with “one-size-fits-all” approach to crisis intervention.
  • Lack of availability of qualified staff and how to pay for them.
  • Elimination of an “in-between” level of care by imposing hospital-like standards that do not align with current outpatient structures.
  • Possibility of inadequate government funding to cover providers’ implementation costs.
  • Lack of inclusion and integration with law enforcement, first responders, 911 operators, and 988 lifeline centers.

In support of RCPA’s recommendation, the IRRC comments also urge the Department to reconvene the stakeholder work group that had been assembled in 2021, especially given the drastic shift in the mental health landscape that has occurred since the group last met.

Please contact Emma Sharp with any questions.

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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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The Office of Mental Health and Substance Abuse Services (OMHSAS) has announced that the proposed Licensure of Crisis Intervention Services regulations will be published in the Pennsylvania Bulletin on October 18, 2025. The package is also posted on the Independent Regulatory Review Commission (IRRC) website and can be found here. OMHSAS’ proposed regulation seeks to codify minimum standards for the issuance of licenses to provide emergency behavioral health crisis intervention services (crisis intervention services) in the Commonwealth in alignment with national best practices for crisis services.

Starting October 18, 2025, and closing November 17, 2025, the public may submit written comments regarding the proposed rulemaking to the Department via email. Please be aware that all public comments must be published verbatim on the IRRC website with the name of the commenter included. OMHSAS fully supports and encourages individuals with lived experience to submit comments on the regulation, but please be sure you are comfortable with the content of your comment being made public with your name.

Comments may also be submitted to the following address:

Department of Human Services
OMHSAS – Bureau of Policy, Planning, and Program Development, Attention: Tara Pride
Commonwealth Tower, 11th Floor
303 Walnut Street
Harrisburg, Pennsylvania 17105

RCPA will be convening a Crisis Intervention Regulatory Review Team to evaluate the proposed regulations and submit comments. If any member is interested in participating in the review group, please contact Emma Sharp.

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