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Guidance

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The sustained funding of community-based mental health services, such as community residential programs, family-based support, outpatient care, and crisis intervention, are critical to the wellbeing of our constituents and our communities. Funding levels for county mental health services have direct impacts on whether these important community and family supports will be available. Yet for too many years, state funding for mental health services has lagged far behind its needs. Counties find themselves advocating to prevent funds from being cut instead of achieving the increases that are needed to catch up from years of underfunding.

This year, RCPA and other system stakeholders have teamed with the County Commissioner Association of Pennsylvania (CCAP) through the Mental Health Safety Net Coalition. We join this campaign to bring awareness of the critical funding needs of mental health services for vulnerable Pennsylvanians. We ask our members, stakeholders, and partners to join us in this collaborative effort by engaging with your legislators. “County mental health services provide a critical piece to the public safety net for people in need,” notes Richard S. Edley, PhD, President and CEO of RCPA. “The system sustained cuts over a decade ago with little relief since then. It is time to restore those dollars and further enhance the system. Not only will it provide critical funding for the individuals receiving services, but there are positive benefits — both financially and clinically — to the entire community.”

The time to act is now for engaging with your representative, as local communities and providers have come together to sustain the safety net and serve those who need it most. The reality is that the demand for service far outweighs capacity and rate structures to serve this population. CCAP has created the following materials to assist in providing strategic talking points for our outreach:

If you have further thoughts or questions, please contact your RCPA Policy Director.

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The Office of Long-Term Living (OLTL) has updated its guidance about payments to strengthen the home and community-based services (HCBS) workforce and assist Adult Day Service (ADS) providers. The updated Frequently Asked Questions (FAQ) document is available under the “Strengthening the Workforce” heading on the DHS Long-Term Care Providers page.

To maximize the use of federal funding under Section 9817 of the American Rescue Plan Act (ARPA) of 2021, OLTL has moved the date by which providers must spend “Strengthening the Workforce” and “Adult Day Services” funds from March 31, 2024, to October 1, 2023. This change allows sufficient time for providers to file an expenditure report and return unspent funds as applicable. OLTL will offer additional details about ARPA expenditure reporting in coming months.

Providers that have questions about this information should contact the OLTL Provider Helpline at 800-932-0939.

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DDAP Modifies ASAM Transition Web Page, Archives Addendums That Outlined IOP Ratio and Daily Therapeutic Hour “Expectations”

The Pennsylvania Department of Drug and Alcohol Programs (DDAP) has overhauled its ASAM Transition web page, removing previous references to “expectations for contractual compliance” in areas of ASAM Criteria where DDAP originally went beyond the Criteria as explicitly written. Newly revised information, including an updated “Guidance for the Application of The American Society of Addiction Medicine, 3rd Edition, 2013 in the Pennsylvania Substance Use Disorder Treatment System for Adults” and “ASAM Frequently Asked Questions” document, references the 1:15 intensive outpatient (IOP) counselor-to-patient ratio and the six to eight daily therapeutic hours at residential level of care as a DDAP “recommendation.”

The change is significant because, according to the Pennsylvania Department of Human Services (DHS) Office of Mental Health and Substance Abuses Services (OMHSAS), per its HealthChoices Behavioral Health Program Standards and Requirements for Primary Contractors document, “the Primary Contractor and its BHMCO must ensure that the SUD providers in the network comply with program standards in the ASAM Criteria, included but not limited to admission criteria, discharge criteria, interventions/types of services, hours of clinical care, and credentials of staff as set forth in the ASAM transition requirements found at https://www.ddap.pa.gov/Professionals/Pages/ASAM-Transition.aspx.” In other words, providers were expected to be in compliance with any information published as an expectation on that page.

For months following DDAP’s testimony in Commonwealth Court that the IOP and daily therapeutic overreaches were simply “guidelines,” the provider community remained unclear on whether they would be required to comply with the “guidelines” as part of their contracts with the BHMCOs. Still, providers have not yet seen the evaluation tool that will be used to audit their compliance with ASAM Criteria despite DDAP’s expectation that they be “substantially aligned” with those Criteria by Jan. 1, 2022.

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ODP Announcement 22-010 announces that the Operational Guide for Appendix K has been updated to align with current guidance from the Centers for Disease Control and Prevention (CDC), the Centers for Medicare and Medicaid Services (CMS), and the Pennsylvania Department of Health (DOH).

Additionally, guidance has been added regarding regulatory compliance during the COVID-19 pandemic. The purpose of the Operational Guide is to provide guidance to Providers (including services rendered under a participant-directed services model), Supports Coordination Organizations, Administrative Entities, and the Office of Developmental Programs (ODP) to ensure adherence with current state and federal guidance.

The Operational Guide applies only to participants impacted by COVID-19. Examples of participants impacted by COVID-19 include participants impacted due to staffing shortages, a COVID-19 diagnosis for the participant or a participant’s housemate or caregiver, and closures of service locations (residential homes, Community Participation Support service locations, etc.). For any requirement not listed in the Operational Guide, refer to the current approved ODP waivers.

ODP is finalizing Version 3 of the Operational Guide for the Adult Autism Waiver and will publish it soon.

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The Department of Human Services (DHS) has issued updated guidance on COVID-19 for Personal Care Homes (PCHs) and Assisted Living Residences (ALRs). As the Commonwealth, along with the nation, has obtained additional data and expanded their knowledge and understanding of COVID-19, guidance continues to evolve and change. The revisions to the guidance are identified in red text.

Questions on these revisions should be sent electronically or to the regional office.

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A Message from Kevin Dressler:

Health Alert Updates

Please see the three Health Alert Network (HAN) updates from the Department of Health regarding treatment for COVID positive people, as well as work restrictions for exposure and return to work guidance. These HANs have been updated over the past two weeks, can be of assistance in updating your COVID response plans, and have components built into them to assist in mitigating staff shortages.

You can also find information at the DOH HAN website.

Department of Health Division of ICF

I would like to announce to the group and welcome Susan DiFuccia as Acting Chief of the Division of ICF. She replaces Orlando Hernandez, whom recently retired after an honorable career in the DOH Division of ICF. Susan has been the Supervisor for the Jackson Center and Pittsburgh DOH survey teams for many years as well as a respected member of the DOH Division of ICF, whom will thrive in her new role.

ICF Taskforce Meeting

The next ICF Taskforce Meeting will be held on February 24, 2022, from 1:00 pm–3:00 pm. A link to the meeting will be forthcoming. If you have any specific topics, please send them to me for possible inclusion in the meeting agenda.

6600 Regulations Update

The 6600 regulations update will be shared for public comment in the coming weeks. Please look for them and provided comments as designated in the announcement. There will also be an opportunity to discuss the regulations at the next ICF Taskforce Meeting.

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