RCPA has been advocating for years for significant changes to the Mental Health Outpatient regulations to help to protect and strengthen mental health outpatient services in Pennsylvania. In 2010, RCPA developed a position paper outlining the major problems in this area. In response to this crisis, the Office of Mental Health and Substance Abuse Services (OMHSAS) developed a task force to work on regulation changes. The task force was a broad range of stakeholders which included consumers, counties, providers, and behavioral health managed care organizations. The task force worked for several years to develop a new set of regulations intended to protect and strengthen mental health outpatient services. The job of the task force was complete in 2014 and OMHSAS submitted the revised regulations to internal sources for approval. From beginning to now, it has been six years since we requested help. OMHSAS responded with strong support but the regulations have been held up in various areas of the department and the administration.

We received the following email today from Jean Rush, who has been the lead at OMHSAS since the beginning of the project:

“I wanted to share the current status of the OP regulation package since we drafted the revisions. With the expansion of Medicaid, the department has made changes to our State Plan Amendments for compliance with ACA which have been approved by CMS. This will require some minimal changes to the OP regulation package which were not an issue during our work.

OMHSAS will be making the minimal changes to the regulation package in conjunction with the Office of Medical Assistance Programs (OMAP) as the Medicaid Authority for the Commonwealth, as well as our Office of Legal Counsel.

The changes will not impact your recommendations but are necessary for compliance and the ability to complete the IRRC review. We will share the changes with you via email and if there are any areas where input is needed, I will be contacting you to schedule a call to discuss.

We appreciate all of the time and dedication to this project and will continue to work on making the changes to move this regulation package to completion. It is still a priority for the department.”

RCPA is hopeful that a resolution is forthcoming and will keep you all posted.