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OMHSAS

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.

The Office of Mental Health and Substance Abuse Services (OMHSAS) is working on developing Regulatory Compliance Guides (RCG) for each licensed level of care to support their commitment to quality in licensing. The RCG is a tool for providers, OMHSAS staff, and the public to better understand the regulations.

This Regulatory Compliance Guide is a companion piece to 55 Pa. Code Chapter 5200. 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 Chapter 5200.

OMHSAS issued the first version of the Psychiatric Outpatient Clinic RCG in November 2021. Today, they are reissuing an updated Psychiatric Outpatient Clinic RCG. The changes made were primarily to language and updates based on comments received on the original document.

Feedback or questions on the RCG can be sent electronically.

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

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has announced the 2025 quarterly meeting dates for next year’s OMHSAS Stakeholder Webinars and asks that you mark your calendars.

2025 OMHSAS STAKEHOLDER WEBINAR DATES:

  • January 30, 2025 — 3:00 pm – 4:00 pm
  • April 24, 2025 — 3:00 pm – 4:00 pm
  • July 17, 2025 — 3:00 pm – 4:00 pm
  • October 23, 2025 — 3:00 pm – 4:00 pm

In the meantime, if you have suggestions for agenda topics for January’s webinar, please submit them via email. We will monitor the account and will only reply to the sender if more information is needed. Responses will not be provided if additional information is not needed.

Please note that webinar links will be provided closer to each of the meeting dates as shown above.

Thank you for your review and please – SAVE THE DATE.

If members have any questions, please contact RCPA COO and Mental Health Director Jim Sharp.

Living the D.R.E.A.M! Creating a Culture of Health and Wellness for All
December 4, 2024
9:00 am – 12:00 pm

The Department of Human Services’ (DHS) Office of Developmental Programs (ODP) and the Office of Mental Health and Substance Abuse Services (OMHSAS) have announced the Dual Diagnosis Professional Conference “Living the D.R.E.A.M.” During this session, SPIN will provide an historical overview of how they created a culture of health and wellness by engaging all stakeholders in living a healthy lifestyle. Presenters will showcase SPIN’s mission of inclusive and holistic meaningful activities in the community and SPIN Community & Fitness, a gathering and welcoming place for the whole community. The D.R.E.A.M team model, including the vision and purpose, elements of “Living the D.R.E.A.M,” and lessons learned for successful incorporation into everyday lives, will be featured.

Registration is now open.

See the announcement for a full session description, presenter biographies, and how to register.

Email with any questions.

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:

The Office of Mental Health and Substance Abuse Services (OMHSAS) recently sent out information to County Mental Health Administrators to alert each of them to an upcoming funding opportunity. This funding supports OMHSAS’s efforts to equip the ICWCs for alignment with the Certified Community Behavioral Health Clinics (CCBHC) model, which includes providing robust crisis services. Additional information regarding the OMHSAS plan for the expansion of the ICWC model is forthcoming, but clinics should still take advantage of this potential opportunity. The ICWCs are encouraged to contact their county representatives to express interest in participating in the start-up project for walk-in crisis services.

An informational meeting for County Partners will be held on Wednesday, October 23, 2024. Please do not submit any applications to OMHSAS, as the application must come from the County Partner(s) in order to be considered.

If you have any further questions, please reach out to your County Partner. Please see below for the information that was shared.


Upcoming Funding Opportunity: Emergency Behavioral Health Crisis Walk-In Centers (EBHC Walk-In Centers)

OMHSAS is excited to announce a new funding opportunity for County Mental Health Administrators aimed at supporting the establishment of Emergency Behavioral Health Crisis Walk-In Centers (EBHC Walk-In Centers). This opportunity offers up to five grants, with a total funding request of up to $3 million per project. Each grant will consist of a blend of $1 million in state funds and $2 million from the federal Community Mental Health Services Block Grant (CMHSBG).

Funding Breakdown:

  • State Funding: Can be used for infrastructure, purchasing property, construction, and/or service provision.
  • Federal CMHSBG Funding: Limited to services for individuals with Serious Mental Illness (SMI)/Serious Emotional Disturbance (SED), provider training, and rent/utilities.

Key:

  • New Walk-In Centers in Rural Areas: Particularly those formed through multi-county partnerships, beyond joinder counties.
  • Applicants that have not previously received CMHSBG funding for crisis start-up projects will be prioritized.

If you have further questions, please contact RCPA COO and Mental Health Director Jim Sharp.

The Division of Licensing Administration has created tutorials to assist with the electronic payment of application, certificate, fines, and appeals fees. A different tutorial has been designed for each program office and payment type. The tutorials give step-by-step instructions for completing the payment of fees for each office.

A new applicant tutorial has also been created. This tutorial will give applicants step-by-step instructions to complete and submit the Application for a Certificate of Compliance (HS633) to become a licensed provider of a human services setting. The HS633 has been revised, and the updated version is available here.

The following tutorials can be accessed on the Application for Human Services License website as well as viewed below:

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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.

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.

The Office of Developmental Programs (ODP) and the Office of Mental Health and Substance Abuse Services (OMHSAS) are pleased to announce that the latest edition of the Positive Approaches Journal is now available!

Understanding Trauma: Expressive Therapies

In this issue of the Positive Approaches Journal, we see that there have been important strides in identifying the prevalence of trauma and the complex consequences of trauma from multiple sources, including social adversity, abuse, and neglect. The focus is on the importance of taking this into consideration on every level, from systems collaboration, to how we assess, diagnose, treat, and offer restorative environmental supports to individuals with intellectual disability and autism (ID/A).

This issue of Positive Approaches Journal is in digital form, available for viewing online or for downloading at MyODP. To print a copy of the PDF, online journal, or a specific article, you will find these options within your left navigation bar on any Positive Approaches Journal page. A new window will open with your selected document. In your browser, you may click the Print button in the top left corner of the page, or by using the Print capability within your browser.

Please submit feedback regarding your experience with the Positive Approaches Journal on MyODP.

The Positive Approaches Journal is published quarterly. For additional information, please contact ODP Training’s inbox.