Guidance
ODP Issues Guidance on Use of Cameras and Video Monitoring Equipment
The Office of Developmental Programs (ODP) has shared updated guidance through ODPANN 24-109. The use of cameras and video monitoring equipment in individual bedrooms and bathrooms is strictly prohibited for Pennsylvania’s CMS-approved Consolidated, Community Living, Person/Family Directed Support, and Adult Autism Waivers. Please view the announcement for information and details.
OMHSAS Provides Updated Telehealth Guidance on “Four Walls”
On Friday, November 1, the Centers for Medicare & Medicaid Services (CMS) released an anticipated Final Rule titled “CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS 1809-FC),” which includes three new exceptions for the federal “four walls” rule. At present, the “four walls” rule prohibits Medicaid payment for clinic services when both the practitioner and individual receiving service are outside of the “four walls” of the clinic unless the services are being provided to unhoused individuals (such as through street medicine). The new exception for Indian Health Services and Tribal Facilities is required nationally. The exceptions for Behavioral Health Clinics and Rural clinics are optional. States who determine that their Behavioral Health Clinic and/or Rural Health Clinic populations served meet the four criteria established by CMS (see page 1323 of the final rule) must submit a Medicaid State Plan Amendment (SPA) and receive approval from CMS for these exceptions to be in place for their state.
The Office of Mental Health and Substance Abuse Services (OMHSAS) had been working toward a short-term state level solution to the four walls issue for both Outpatient Psychiatric Clinics and Drug and Alcohol Clinics. However, now that a long-term federal option has been made available, the team in OMHSAS will be pivoting to pursue this newly available federal exception for Behavioral Health Clinics. While OMHSAS is still in the process of developing a timeline for the new State Plan Amendment, their team will be working on this as a top priority, with the goal of having a SPA in place in early 2025.
It has been confirmed that OMHSAS will not be shifting their current enforcement policy around the four walls while they work through getting this waiver in place. RCPA will continue its collaboration with OMHSAS on the process as this move forwards. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.
For additional information, please see the following:
- Full Final Rule
- CMS FAQ on the Final Rule
- Email for Questions Regarding OMHSAS Telehealth Policy
Updated Guidance Released on Requesting Death Certificates From Families
The Office of Developmental Programs (ODP) has shared ODPANN 24-098. This communication is to provide guidance when requesting death certificates from family members in relation to death incident reports and investigations. Updates are in red.
Comprehensive Guide to EVV, Version 3.0, Now Available
The Office of Developmental Programs (ODP) is thrilled to announce this updated guide, packed with valuable information to support you in navigating EVV requirements effectively.
What’s New in the Version 3.0:
- Clearer Guidance: ODP has improved the guide’s readability so you can locate the information you need more quickly.
- Improved Review: Version 3.0 ensures you are up-to-date with rules by providing a complete overview of the most recent EVV requirements.
- Enhanced Accessibility: To better serve a wide range of users, ODP improved accessibility features, making the guide easier to use for all.
- Streamlined Processes: Based on your feedback, ODP streamlined processes to help you enhance your EVV implementation.
Reminder: Update Your Administration Information!
ODP noticed that many of their quarterly EVV Manual Edit Compliance reports are being returned due to bad addresses. To ensure you receive important updates and reports, please update your administration information in the Sandata Aggregator with your current email address. If you have any questions or need assistance with updating your information, please contact the Sandata EVV Customer Care Portal (Sandata On-Demand).
If you have any questions about the ODP Comprehensive Guide to EVV, please contact the ODP EVV inbox.
FY 2024/25 ISP Renewal Guidance Released
The Office of Developmental Programs (ODP) has shared ODPANN 24-037. The purpose of this announcement is to provide guidance for the Fiscal Year (FY) 2024/25 renewal period.
The following topical areas are addressed in this communication:
- Leap Year to Non-Leap Year;
- Guidance for Updating FY 2024/25 Renewal Plans with Partial Year Service Segments;
- FY 2024/25 Waiver Rate Load/Rate Changes;
- Variance Process for Established Service Requirements;
- NG5 and Residential Rate Exception NEA Process;
- Remote Supports;
- Reserve to Encumbrance; and
- Resources.
Please view the announcement for information and details.
FEMA Releases Disaster Preparedness Guide for Caregivers
The Office of Developmental Programs (ODP) has shared this important announcement from FEMA and the Rosalynn Carter Institute for Caregivers (RCI).
In recognition of caregivers’ dedication and commitment to those in their care, the Federal Emergency Management Agency (FEMA) and the Rosalynn Carter Institute for Caregivers (RCI) have created the Disaster Preparedness Guide for Caregivers to help them navigate unique challenges that may arise during disasters.
When forced to evacuate, relocate to emergency shelters, or find temporary housing, care recipients and caregivers require support and services that meet them where they are and account for unmet needs. FEMA is pleased to announce this new guide that focuses on the lived experience of caregivers who often serve as a lifeline for others, whether the skies are blue or gray.
See the new guide for the three essential steps that can help caregivers feel more prepared and in control when disaster strikes.
One-Time Workforce Recovery Supplemental Payment Waiver Amendments Submitted to CMS
The Office of Developmental Programs (ODP) has shared ODPANN 24-031, which informs all interested stakeholders of the submission of the Consolidated, Community Living, Person/Family Directed Support (P/FDS), and Adult Autism Waiver (AAW) amendments that contain Workforce Recovery Supplemental Payments to CMS and provides guidance for requesting these payments. The submitted waiver amendments are available on the Department of Human Services website.
Please view the announcement for information and details, and note that providers are required to complete ODP’s survey to request these payments.
DDAP Licensing Alert Provides and Organizes Guidance on Staffing Regulations
The Pennsylvania Department of Drug and Alcohol Programs (DDAP) has issued Licensing Alert 05-2024 to provide and organize guidance on the interpretation and implementation of regulatory licensing requirements for staff education, training, and supervision, as well as client-to-staff/counselor ratios for drug and alcohol treatment providers.
DDAP has issued individual licensing alerts over time that focus on specific regulation topics. This licensing alert organizes previous relevant active licensing alerts, as well as provide additional guidance for Chapter 704 staffing regulations.
Licensing Alert 05-2024 is available online.
ODP Shares PDF Guide for Infection Control and Vaccination Status Survey
The Office of Developmental Programs (ODP) has shared a downloadable PDF of the questions within the Infection Control and Vaccination Status Survey that was sent out earlier this week. Since the online survey does not permit you to save and return, reviewing the questions ahead of time may make it easier to have all your necessary data when you complete the survey. If you have not already done so, please enter your responses online.
