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Public Comment

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The Independent Regulatory Review Commission (IRRC) has published their comments on the proposed Licensure of Crisis Intervention Services regulations, summarizing the comments submitted by the stakeholder community during the public comment period. As part of the IRRC’s regulatory process, OMHSAS will have to address and clarify any questions that have been submitted.

Similar to RCPA’s public comments, the IRRC response highlights concerns regarding the proposed rulemaking in the following areas:

  • Potential issues with “one-size-fits-all” approach to crisis intervention.
  • Lack of availability of qualified staff and how to pay for them.
  • Elimination of an “in-between” level of care by imposing hospital-like standards that do not align with current outpatient structures.
  • Possibility of inadequate government funding to cover providers’ implementation costs.
  • Lack of inclusion and integration with law enforcement, first responders, 911 operators, and 988 lifeline centers.

In support of RCPA’s recommendation, the IRRC comments also urge the Department to reconvene the stakeholder work group that had been assembled in 2021, especially given the drastic shift in the mental health landscape that has occurred since the group last met.

Please contact Emma Sharp with any questions.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the proposed Mental Health Procedures regulations, which are open for public comment. The posting on the Independent Regulatory Review Commission (IRRC) website can be found here.

The proposed regulations are to be in compliance with Act 32 of 2022. OMHSAS is choosing to go beyond the updates required by Act 32 and is doing a full alignment of the chapter with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to increase the clarity of the regulations for stakeholders.

Starting December 6, 2025, and closing January 5, 2026, the public may submit written comments regarding the proposed rulemaking to the Department via email. Please be aware that all public comments must be published verbatim on the IRRC website with the name of the commenter included. OMHSAS fully supports and encourages individuals with lived experience to comment on the regulation. However, please ensure you are comfortable with the content of your comment being made public, with your name attached to it.

RCPA has conducted an internal review of the proposed regulations and is seeking member feedback and comments to be included in our submission. Members are encouraged to review and provide recommendation and guidance on the impacts of the proposed regulations on your organization.  Agencies may submit separately or in conjunction with RCPA.

Comments may also be submitted to RCPA COO and Mental Health Policy Director Jim Sharp by January 2, 2026, OR to the following address:

Department of Human Services
OMHSAS – Bureau of Policy, Planning, and Program Development,
Attention: BPPPD
Commonwealth Tower, 11th Floor
303 Walnut Street
Harrisburg, Pennsylvania 17105

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has announced that the proposed Licensure of Crisis Intervention Services regulations will be published in the Pennsylvania Bulletin on October 18, 2025. The package is also posted on the Independent Regulatory Review Commission (IRRC) website and can be found here. OMHSAS’ proposed regulation seeks to codify minimum standards for the issuance of licenses to provide emergency behavioral health crisis intervention services (crisis intervention services) in the Commonwealth in alignment with national best practices for crisis services.

Starting October 18, 2025, and closing November 17, 2025, the public may submit written comments regarding the proposed rulemaking to the Department via email. Please be aware that all public comments must be published verbatim on the IRRC website with the name of the commenter included. OMHSAS fully supports and encourages individuals with lived experience to submit comments on the regulation, but please be sure you are comfortable with the content of your comment being made public with your name.

Comments may also be submitted to the following address:

Department of Human Services
OMHSAS – Bureau of Policy, Planning, and Program Development, Attention: Tara Pride
Commonwealth Tower, 11th Floor
303 Walnut Street
Harrisburg, Pennsylvania 17105

RCPA will be convening a Crisis Intervention Regulatory Review Team to evaluate the proposed regulations and submit comments. If any member is interested in participating in the review group, please contact Emma Sharp.

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The Pennsylvania Department of Drug and Alcohol Programs (DDAP) is providing the opportunity for public comment on the Pennsylvania Substance Use Prevention, Treatment, and Recovery Services (SUPTRS) Block Grant application. This application will occur in three parts:

  • Substance Abuse Prevention and Treatment Assessment and Plan
  • SUPTRS Report (available in November)
  • Annual Synar Report (available in December)

The application documents can be accessed through SAMHSA’s Web Block Grant Application System (WebBGAS) using the login “citizenpa” and password “citizen.”

Please submit your comments by Tuesday, September 30.

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The Pennsylvania Department of Drug and Alcohol Programs (DDAP) is providing the opportunity for public comment on the Pennsylvania Substance Use Prevention, Treatment, and Recovery Services (SUPTRS) Block Grant application.

This application will occur in three parts:

  • Substance Abuse Prevention and Treatment Assessment and Plan;
  • SUPTRS Report (available in November); and
  • Annual Synar Report (available in December).

The application documents can be accessed through SAMHSA’s Web Block Grant Application System (WebBGAS) using the login “citizenpa” and password “citizen.”

Comments must be submitted via email by Tuesday, September 30.

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Providers are invited to attend a virtual informational session regarding the proposed regulatory chapters for Residential Services for Children. This session will provide highlights of the key changes being proposed to regulations governing child residential settings (including parent/child settings and outdoor programs), secure detention, and secure residential facilities. These proposed regulatory chapters are identified as:

  • 55 Pa. Code Chapter 3900 Child and Youth Facility Requirements
  • 55 Pa. Code Chapter 3910 Child Residential Facilities
  • 55 Pa. Code Chapter 3920 Secure Residential and Secure Detention Facilities for Youth

These proposed regulatory chapters currently are under review within the Governor’s Office, and the Office of Children, Youth, Families (OCYF) is projecting publication in the last quarter of calendar year 2025. There will be a 60-day comment period following publication of the proposed regulations.

In advance of publication, however, OCYF is extending the opportunity to attend an informational session to highlight proposed key changes to existing practices.

DATE: There are two dates you can attend. The content will be the same at each session.

TIME: 1:00 pm – 3:00 pm (the same for both sessions)

RCPA, as part of the Children’s Residential Services and Children’s MH Division, will be assembling a regulatory review team as part of the regulatory promulgation and public comment process. RCPA has performed a similar review for the PRTF, Crisis, IBHS, and Outpatient Psychiatric processes, as well as a host of other DHS regulatory efforts.

If you are interested in being a part of this review, please contact RCPA Mental Health Policy Associate Emma Sharp. RCPA will convene a Chapter 3900 Work Group within a week of the OCYF presentation.

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The FFY 2026/27 Community Mental Health Services Block Grant (CMHSBG) Draft Pennsylvania Application is now available for public comment. The CMHSBG is federal block grant funding that assists states in providing community-based services to adults with Serious Mental Illness and children with Severe Emotional Disturbance. This application provides a review of the current strengths and needs in the Pennsylvania mental health system and plans priority areas for improvement. The priorities were developed in consultation with representatives from the Pennsylvania Mental Health Planning Council. The CMHSBG Application public comment period will remain open until August 25, 2025.

Please access the application using the Webbgas Citizen’s login using the below credentials.

  • Login: citizenpa
  • Password: citizen

Submit any comments on this application to the CMHSBG Resource inbox.

RCPA is open to submitting members’ comments and feedback via our organization’s response to the public feedback process. If you would like to have RCPA submit comments on behalf of your agency, please contact RCPA Policy Associate Emma Sharp with any questions.

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The Office of Developmental Programs (ODP) held the SCO Performance-Based Contracting (PBC) Introductory Session today.

ODP received approximately 140 people’s and organizations’ comments during the public comment period. Deputy Secretary Kristen Ahrens stated that comments were very helpful and specific in finalizing the proposed plan being submitted to CMS.

General recommendations received:

  • Implement one set of standards for all SCOs (no tiers);
  • Require more than 2 SCOs in each county;
  • More and clearer engagement and education for individuals and families; and
  • Develop resources for SCOs to use.

Timeline considerations:
Feedback on the performance measures:
Rates:15-minute units vs monthly units

  • Concerns of using both
  • Average hours in the assumptions

Handouts from today’s session are available here.

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Image by Werner Moser from Pixabay

The Office of Long-Term Living (OLTL) is sharing the message below from the Pennsylvania Department of Aging (PDA):

As part of Aging Our Way, PA, PDA is conducting an evaluation of the PA Link to inform the design of a strategic plan. The goal is to improve and redesign the program to better serve older adults, people with disabilities, and caregivers. The entire project was informed by extensive stakeholder engagement, including consultation of an advisory committee.

Please use the Public Comment Form to review the DRAFT Evaluation Report and DRAFT Recommendation report. You will then be able to upload your comments.

The public comment period will close on Monday, July 28, 2025, and all comments will be considered in the creation of the final strategic plan to refresh the PA Link.

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