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IRRC

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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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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the proposed Mental Health Procedures regulations, which are open for public comment. The posting on the Independent Regulatory Review Commission (IRRC) website can be found here.

The proposed regulations are to be in compliance with Act 32 of 2022. OMHSAS is choosing to go beyond the updates required by Act 32 and is doing a full alignment of the chapter with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to increase the clarity of the regulations for stakeholders.

Starting December 6, 2025, and closing January 5, 2026, 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 comment on the regulation. However, please ensure you are comfortable with the content of your comment being made public, with your name attached to it.

RCPA has conducted an internal review of the proposed regulations and is seeking member feedback and comments to be included in our submission. Members are encouraged to review and provide recommendation and guidance on the impacts of the proposed regulations on your organization.  Agencies may submit separately or in conjunction with RCPA.

Comments may also be submitted to RCPA COO and Mental Health Policy Director Jim Sharp by January 2, 2026, OR to the following address:

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

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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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As RCPA, the Office of Mental Health and Substance Abuse Services (OMHSAS), and the stakeholder community continue to partner on the Psychiatric Rehabilitation Treatment Facility (PRTF) regulation promulgation process, we have submitted to the PA Independent Regulatory Reform Commission (IRRC) a PRTF Cost Analysis. RCPA’s financial analysis focuses on the implementation costs in key target areas: staffing, accreditation, and non-allowable costs. The information represents a cross section of providers from diverse geographic and organizational perspectives.

We thank OMHSAS for the recent PRTF forum, which provided an overview of the changes the Department has made. The forum was informative, collaborative, and set a framework for ongoing regulatory development.

View the full RCPA PRTF Cost Analysis here.

If you have any questions, please contact RCPA Policy Associate Emma Sharp.

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On behalf of its opioid treatment program (OTP) provider members, RCPA submitted comments to the Independent Regulatory Review Commission (IRRC) in support of a final-omitted regulation that would allow an initial physical examination required for prescribing, administering, and dispensing controlled substances through an OTP to be conducted via telehealth under certain circumstances under Pa. 49 Code § 16.92.

This final-omitted regulation would enable the Pennsylvania Department of Drug and Alcohol Programs (DDAP) to grant a statewide exception to 28 Pa. Code § 715.9(a)(4), which today requires Pennsylvania OTPs (called narcotic treatment programs in DDAP regulations) to conduct a face-to-face determination of whether an individual is currently physiologically dependent on an opioid.

IRRC will consider the final-omitted regulation at a public meeting on December 5.

In its comments, RCPA wrote:

“Enabling OTPs to conduct the initial examination required as part of induction into methadone or buprenorphine treatment through telehealth significantly improves and expedites patient access to the gold standard treatment for OUD without sacrificing quality or safety. In a treatment environment where finding qualified physicians, physician assistants and certified registered nurse practitioners is challenging, telehealth bridges a significant gap. Physicians would no longer need to be physically on site at the OTP where treatment is to take place to examine a patient as part of the induction process. Rather, from anywhere in the commonwealth, a physician can examine more patients, who can then begin treatment with medication faster at a facility near their home. In fact, with this final-omitted regulation, OTPs will have the ability to accommodate same-day or walk-in admissions instead of scheduling intake appointments days later.”

The final-omitted regulation, submitted by the Department of State, Bureau of Professional and Occupational Affairs, State Board of Medicine, along with comments in support from the Department of Drug and Alcohol Programs and RCPA, can be viewed on the IRRC website.

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Image by Dirk Wouters from Pixabay

The Office of Mental Health and Substance Abuse Services (OMHSAS) has submitted to the Pennsylvania Independent Regulatory Review Commission (IRRC) IRRC No. 3417 — Psychiatric Residential Treatment Facilities (14-555) regulations for the first phase of the promulgation process.

At this time, the regulations will be open for the submission of public comments from November 2, 2024, to December 1, 2024. The IRRC will review these comments and work with OMHSAS on developing responses as well as any potential language changes.

This process for regulation development with stakeholders began in 2019, and RCPA and its members have been active partners with the OMHSAS Children’s Bureau in the ongoing process through forums and work group meetings. The RCPA Residential Services Work Group completed a cursory review of a PRFT regulation presentation by OMHSAS in July and will begin working on developing a full response to the regulations.

RCPA will be connecting with these members this week to schedule the PRTF Regulatory Review Team that will support our recommendations to the current draft. If any member is interested in participating in the review group, please contact RCPA COO and MH Director Jim Sharp.

The regulations can be view at the links below.

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The Pennsylvania Independent Regulatory Review Commission (IRRC) has completed their review of existing Intensive Behavioral Health Services (IBHS) regulations codified at 55PA. Code chapters 1155 and 5240, as requested by the RCPA IBHS Steering Committee.

The RCPA IBHS Regulatory Reform Recommendations, submitted on November 29, 2022, requested the commission to review the IBHS regulations under section 8.1 of the Regulatory Review Act, which provides that the commission may review any existing regulation which has been an effect for at least three years.

The commission has noted the burden placed on providers by the Department of Human Services regulation, but while they appreciated our concerns, the commission’s role is to determine whether existing regulations, as a whole, remain in the public interest. In the commission review letter, they determined that further action by the commission is not warranted in this matter.

We have been in contact with OMHSAS throughout this two-year period, and the commission provided the department with guidance as part of the review process. Despite the ruling from the IRRC, OMHSAS has agreed that they will reopen the IBHS for review as announced by OMHSAS Deputy Secretary Jennifer Smith at the RCPA Conference last week. RCPA will be reviewing the recommendations to calibrate those areas that continue to create barriers to access that have arisen since the recommendations created in the Fall of 2022.

If you have any questions, please contact RCPA COO and Policy Director Jim Sharp.

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