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Tags Posts tagged with "Guidance"

Guidance

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Photo by René DeAnda on Unsplash

RCPA provided some late updates yesterday on the Federal funding freeze, and late last evening, the National Council for Mental Wellbeing provided members a legal interpretation on the rescinding of the Office of Management and Budget (OMB) M-25-13 and the issuance of the new memorandum M-25-14.

The following is from the National Council:

On Wednesday afternoon, the White House Office of Management and Budget issued a new memorandum—M-25-14 — that rescinded the pause to federal funding contemplated in a previous memorandum first issued on Monday night.

The new memorandum, which was directed to “heads of executive departments and agencies,” features a two-sentence statement reading: “OMB Memorandum M-25-13 is rescinded. If you have questions about implementing the President’s Executives Order, please contact your agency General Counsel.”

In the short term, M-25-14 certainly relieves some of the confusion and anxiety that swept across the federal grants world since Monday night. Our previous client alerts have chronicled the chaos that emerged late Monday and throughout the day on Tuesday.

However, in our review, there are still five key Executive Orders issued by the Trump Administration not affected by the rescission of M-25-13. Those EOs include:

While the upheaval following the issuance of M-25-13 may have prompted the Trump Administration to change course and move away from pausing all federal funding, we certainly anticipate that federal grants in the above-listed areas will remain subject to a comprehensive review and new standards. Federal grantees with programs in these specific areas should undertake a detailed review and be prepared for future agency actions.

Federal grantees should continue to keep apprised of the Administration’s actions, orders, and statements relating to federal funding — as the rescinded memorandum likely foretells future clashes as the Administration attempts to exert control over federal spending.

Chuck Ingoglia
President & CEO
Strategic Leadership
National Council for Mental Wellbeing

In addition, ANCOR sent the following information last night:

In what’s turning from a whirlwind couple of days into a whirlwind week, there were notable updates today on the OMB memo on the freeze of certain federal funding issued earlier in the week. 

Today OMB withdrew the memo with a simple rescission statement after a federal judge temporarily blocked the funding freeze for open awards and current spending. The order remains in effect until February 3 when a hearing is scheduled to determine next steps.  

As you may have seen, later in the day, Press Secretary Karoline Leavitt posted to X, “[t]his is NOT a rescission of the federal funding freeze. It is simply a rescission of the OMB memo. Why? To end any confusion created by the court’s injunction. The President’s EO’s on federal funding remain in full force and effect, and will be rigorously implemented.” Without further specificity regarding the implicated executive orders, the situation remains fluid with the potential for later memos or other interpretive guidance which the White House maintains is authority held within the executive branch.

In other litigation, U.S. District Judge Jack McConnell made statements in court today indicating that another restraining order may be coming. With the memo rescinded, the Department of Justice Special Counsel argued the case is no longer relevant. However, the judge did not appear persuaded and asked for a draft protective order for response and consideration. 

We’ll continue to keep you posted as we know more and hope to see you Friday (1/31) for our extended Members-Only Weekly Briefing at 12:30 pm ET to provide updates and review all available information together. See login information below:
Join Zoom Meeting: ancor-org.zoom.us/j/… 
Meeting ID: 870 2745 7284 
Passcode: 977618 

In recent communications from the OMB, these actions will not impact programs that provide direct benefits to individuals and are explicitly excluded from the pause and exempted from this review process. In addition to Social Security and Medicare, already explicitly excluded in the guidance, mandatory programs like Medicaid and SNAP will continue without pause.

RCPA will continue to communicate new developments with members as they emerge. If you have any questions, please contact your RCPA Policy Director.

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assistance, support, guidance - business concept words in color hexagons over blue background, flat design

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:

  1. Someone to Contact — The 988 Lifeline and other hotlines provide immediate, accessible support for individuals in crisis.
  2. Someone to Respond — Mobile crisis teams are a critical component, delivering rapid, on-site assistance to de-escalate crises and connect people with appropriate care.
  3. A Safe Place for Help — Stabilization services offer facilities where individuals in crisis can access care, resolve crises, and transition to ongoing treatment when necessary.

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.

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The Office of Developmental Programs (ODP) is informing stakeholders of updates to the Performance-Based Contracting (PBC) Residential Services Implementation Guide. Revisions to the Implementation Guide appear in red.

Some significant changes to the Performance-Based Contracting Proposal (Appendix A) are as a result of public comment and feedback from the first round of tier determinations. These changes include:

Performance Standard:

  • Revision: (RM-IM.01.3) Data pull will be for 2024 calendar year (CY) quarters 1-2 (Q1-2), and an adjustment variable of 1% will be applied.
  • Revision: (RM-IM.01.3) Temporarily changing the threshold from 90% to 86%. For fiscal year (FY) 2027-28, the threshold will return to 90% using CY 2026 data.
  • Revision: (RM-IM.01.4) Moved to future measure in FY 2027/28 using CY 2026 data.

Scoring Tool:

  • Revision: Measures RM-IM.01.1, RM-IM.01.2, and RM-IM.01.3, RM-IM.01.1 – RM-IM.01.3 Scoring as composite requiring 2 out of 3.

Attachments:

  • Attachment 1: Performance-Based Contracting Residential Implementation Guide
  • PBC Residential Services Provider Self-Assessment Toolkit
    • Attachment 2A: Provider Performance-Based Contracting Preparedness Self-Assessment
    • Attachment 2B: Provider Preparedness Workbook 2025 Updates (20250107)
  • Attachment 3: Residential Performance-Based Contracting Attestation

Please view ODPANN 25-003 for additional changes, information, and details.

The updated version of the PBC Residential Services Implementation Guide is located on the Performance-Based Contracting Information web page on MyODP.

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The Office of Developmental Programs (ODP) has shared ODPANN 24-127 to notify trainers and learners of the following information:

  1. Reach out to the MA Help desk if the student does not pass their second attempt at the Post Test for account reset.
  2. If a student earns a Post Test total of 89.5 points, it will be rounded up to 90 and considered a passing score.
  3. 3 additional Observation checks are now available in the 2024 online student courses for those that did not complete the initial 4 observations within 30 days of passing the exams.
  4. A link is now available on the student course page for students to view their User Report.
  5. Reminder: The “Trainer Attestation of Qualification” and the “Complete to access Acknowledgement of Qualification” activities serve as the ‘online’ signatures, replacing the physical signatures.
  6. Reminder: The 2022 student courses should no longer be used after January 31, 2025. Activities will no longer be available to students after this date. Please complete the 2022 student courses before this date and start new classes with the 2024 student courses.

The announcement contains a Proof of Qualification guide for Qualified Medication Administrators, Certified Trainers, and Qualified Practicum Observers.

Guidance is also available to trainers on how to do the following in the online Medication Administration system:

  1. Enter the grade and date of the medication observations;
  2. Enter the trainer attestation grade; and
  3. Print the user report.

The Schedule from January – March 2025 is available for Train-the-Trainer Face-to-Face.

Please view the announcement for additional information and details.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) is pleased to release the Partial Hospitalization Regulatory Compliance Guide (RCG). This guide has been developed to provide clear explanations of the regulatory requirements of Title 55 Pa. Code Chapter 5210 “Partial Hospitalization” regulations. It is meant to help agencies providing partial hospitalization services with the goal of ensuring safe environments and effective services to individuals through regulatory compliance, and to help OMHSAS Licensing Representatives protect individuals served by these programs by conducting consistent and comprehensive inspections.

This guide is a companion piece to Title 55 Pa. Code Chapter 5210 regulations. It is intended to be a helpful reference for these regulations. The explanatory material contained in this guide in no way supplants the plain meaning and intent of the regulations set forth in 55 Pa. Code Chapter 5210.

The guide can be accessed here.

Feedback or questions on the RCG can be sent electronically. If you have additional questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

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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.

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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:

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