Message from the Office of Mental Health and Substance Abuse Services (OMHSAS):

The Pennsylvania Department of Human Services’ (DHS) Office of Mental Health and Substance Abuse Services (OMHSAS) is issuing the bulletin OMHSAS-25-05 “Behavioral Health Clinic Services Provided Outside of the Clinic,” effective November 12, 2025, following changes to Federal Regulation 42 CFR 440.90(d).

OMHSAS 25-05 announces an amendment to Pennsylvania’s Medicaid State Plan which allows all behavioral health clinics that are enrolled in the Medical Assistance (MA) Program, who deliver services through the fee-for-service and managed care systems, to provide clinically appropriate services outside of the clinic. Behavioral health clinics include psychiatric outpatient clinics, outpatient drug and alcohol clinics, and methadone maintenance clinics.

Furthermore, OMHSAS-25-05 also announces the abrogation of 55 Pa Code §§ 1153.14(6) (relating to noncovered services) and 55 Pa. Code 1223.14(11) (relating to noncovered services) by Act 46 of 2025.

The guidance in OMHSAS-25-05 is separate from any “telehealth only” licensure and guidance that may be in place. The changes discussed in this bulletin also do not apply to the existing Mobile Mental Health Telehealth (MMHT) services.

Questions and comments can be directed to OMHSAS via email. RCPA members can also contact RCPA COO and MH Policy Director Jim Sharp with any questions.