The Pennsylvania Independent Regulatory Review Commission (IRRC) has approved RCPA’s request to review the RCPA IBHS Regulatory Review Recommendations within the context of the current IBHS regulations.

The premise of the recommendations addresses the challenges and barriers IBHS providers have faced in creating the staffing infrastructures and meeting the burdensome operational protocols for regulatory compliance. The overreaching nature of the regulations, coupled with the impact of the pandemic, has caused great strain on an already depleted behavioral health workforce. These system stressors limit the ability to provide vital, quality services to children and families. Due to the prohibition for the use of waiting lists, it is difficult to capture the true number of children and families going without these essential services. We contend there are thousands of children across the Commonwealth with unmet treatment needs and written orders for IBHS services who await care.

The current lack of access to care is a result of the workforce crisis and operational requirements of implementing the regulations. We feel these access issues and children waiting for services are compelling reasons, in the interest of the public, to merit a review of the regulations. We have also provided these recommendations to OMHSAS, the HealthChoices BHMCOs, and leadership in the Pennsylvania General Assembly.

RCPA extends its gratitude to our members and those who have supported this process as well as the IRRC for their review. There is no current timeframe for the review, as there are many other, similar regulatory review requests on the docket. With that said, we remain vigilant in our efforts and seek partnership and collaboration with all stakeholders to address the current crisis.

If you have any questions, please contact RCPA Mental Health Policy Director Jim Sharp.