The Centers for Medicare and Medicaid Services (CMS) has released an informational bulletin, as well as a slide presentation, that are related to continuity of coverage for individuals receiving home and community-based services (HCBS). The purpose of the bulletin is to highlight the federal renewal requirements and available flexibilities to promote continuity of coverage.
The Department of Human Services (DHS) today announced applicants selected through a Request for Applications (RFA) process to administer Pennsylvania’s Community HealthChoices (CHC) program, the Medicaid managed care program that covers adults who are dually eligible for Medicare and Medicaid or who qualify to receive Medicaid long-term services and supports due to a need for the level of care provided in a nursing facility.
Selected applicants will now move to a readiness review period before the agreements are fully executed.
The five selected plans will be available statewide. They include the three current incumbents and two plans new to Community HealthChoices:
RCPA will be reaching out to the selected applicants to be at the upcoming PD&A meeting in September. If you have any questions, please contact Fady Sahhar or Melissa Dehoff.
The Office of Mental Health and Substance Abuse Services (OMHSAS) Deputy Secretary Jen Smith recently provided an update on the federal four walls rule. The Centers for Medicare and Medicaid Services (CMS) has issued a proposed rule, or Notice of Public Rulemaking, that could create exceptions to the existing four walls requirement for IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas.
The official language posted to the federal register can be found on page 15 of the Federal Register, which is scheduled to be published on July 22, and is copied below.
“This proposed rule includes a proposal to create exceptions to the Medicaid clinic services benefit four walls requirement, to authorize Medicaid payment for services provided outside the four walls of the clinic for IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas. Our current regulation at 42 CFR § 440.90(b) includes an exception to the four walls requirement under the Medicaid clinic services benefit only for certain clinic services furnished to individuals who are unhoused. We believe these proposed exceptions would help maintain and improve access for the populations served by IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas.”
As a reminder, this is a proposed rule intended to announce and explain CMS’s plan to address the problem. As such, all proposed rules must be published in the Federal Register to notify the public and give them an opportunity to submit comments. The proposed rule and the public comments received on it form the basis of a final rule. More information on the final rulemaking process is available here. Interested parties should provide public comments on this proposed rule to the addresses listed in the federal register by September 9, 2024.
While CMS works through this process, OMHSAS, RCPA, and the PA General Assembly continue efforts to address this through the recently released HCO 3450 legislation that will address the psychiatric outpatient in-office requirements and the Medicaid “4 walls” standards. RCPA will work with our members and the National Council for Mental Wellbeing on developing public comments for submission regarding this proposed rule. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.
RCPA recently signed two letters, one to Governor Shapiro and one to the PA Department of Human Services (DHS), alongside dozens of other organizations and the Pennsylvania Community Health Worker Collaborative (PACHW) regarding the state’s plan for an amendment to authorize payments for Community Health Worker services under Pennsylvania State Medicaid. The letters outlined several key features PACHW wished to highlight regarding these payments, including:
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