';
Tags Posts tagged with "Public Comment"

Public Comment

The Office of Mental Health and Substance Abuse Services (OMHSAS) is pleased to announce that the draft application for the Fiscal Year 2025 Projects for Assistance in Transition from Homelessness (PATH) grant is now available for public comments. The draft application has been posted for public review on the Mental Health in PA website.

The PATH grant is a non-competitive formula grant available to all states and territories by the Stewart B. McKinney Homeless Assistance Amendments Act of 1990. PATH programs serve individuals with serious mental illness experiencing or at imminent risk of homelessness. The PATH grant application is submitted to the federal agency Substance Abuse and Mental Health Services Administration (SAMHSA) annually.

Please note that this is the Pennsylvania application to SAMHSA. This is not a request for new PATH project proposals.

The PATH Application public comment period will remain open until 10:00 am Friday, March 21, 2025. If you have any questions or comments, please send them to Lauren MacWithey, Pennsylvania PATH Grant Coordinator, via email.

Please contact RCPA Policy Associate Emma Sharp with any additional questions.

Earlier this month the Drug Enforcement Agency (DEA) issued a Notice of Proposed Rulemaking (NPRM) for Special Registrations for Telemedicine and Limited State Telemedicine Registrations. DEA is seeking public comment by March 18, 2025.

RCPA is considering whether it will submit comments. If you have comments about the proposed rule that you would like to make part of any RCPA response or if you would like to discuss the proposed rule, please contact RCPA SUD Treatment Services Policy Director Jason Snyder.

The NPRM introduces three types of Special Registrations for Telemedicine:

  1. A Telemedicine Prescribing Registration, authorizing qualified clinician practitioners to prescribe Schedule III-V controlled substances via telemedicine;
  2. An Advanced Telemedicine Prescribing Registration, authorizing qualified, specialized clinician practitioners (i.e., psychiatrists, hospice care physicians, physicians rendering treatment at long-term care facilities, and pediatricians for the prescribing of medications identified as the most addictive and prone to diversion to the illegal drug market) to prescribe Schedule II-V controlled substances via telemedicine; and
  3. A Telemedicine Platform Registration, authorizing covered online telemedicine platforms, in their capacity as platform practitioners, to dispense Schedule II-V controlled substances. To satisfy the statutory requirements, DEA would also require the special registrant to maintain a State Telemedicine Registration for every state in which a patient is treated by the special registrant, unless otherwise exempted. The State Telemedicine Registration would be issued by DEA, not the states, and operate as an ancillary credential, contingent on the Special Registration held by the special registrant.

Public comments are also requested on additional patient protections for the prescribing of Schedule II medications by telemedicine, including:

  • Whether the special registrant should be physically located in the same state as the patient being prescribed Schedule II medications;
  • Whether to limit Schedule II medications by telemedicine to medical practitioners whose practice is limited to less than 50 percent of prescriptions by telemedicine; and
  • The appropriate duration needed for the rules’ provisions to be enacted.

The special registration rule will also require the establishment of a national prescription drug monitoring program (PDMP) to help the health industry protect against abuse and the diversion of controlled substances into the illegal drug market. A national PDMP will provide pharmacists and medical practitioners with visibility of a patient’s prescribed medication history.

assistance, support, guidance - business concept words in color hexagons over blue background, flat design

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released updated National Behavioral Health Crisis Care Guidance aimed at enhancing the nation’s response to mental health and substance use crises. This effort is part of an ongoing initiative to address record-high rates of suicide and overdose, while also building on the transition to the 988 Suicide & Crisis Lifeline in 2022.

The updated National Behavioral Health Crisis Care Guidance is comprised of three key documents. These are the 2025 National Guidelines for a Behavioral Health Coordinated System of Crisis Care, Model Definitions for Behavioral Health Emergency, Crisis, and Crisis-Related Services, and a draft Mobile Crisis Team Services Implementation Toolkit, which is open for public comment until March 21, 2025. Together, these resources set forth a framework for reshaping community crisis care systems and ensuring timely access to care.

SAMHSA’s framework is built on three foundational pillars essential to an integrated crisis care system:

  1. Someone to Contact — The 988 Lifeline and other hotlines provide immediate, accessible support for individuals in crisis.
  2. Someone to Respond — Mobile crisis teams are a critical component, delivering rapid, on-site assistance to de-escalate crises and connect people with appropriate care.
  3. A Safe Place for Help — Stabilization services offer facilities where individuals in crisis can access care, resolve crises, and transition to ongoing treatment when necessary.

The new guidance emphasizes scalability and sustainability for these systems, equipping state, tribal, local, and territorial governments with the tools needed to design and improve crisis care services. It also provides practitioners with actionable steps for delivering quality care.

The 988 Suicide & Crisis Lifeline, launched nationwide in 2022, represents a significant shift in behavioral health crisis response. The easy to remember three digit number aims to provide individuals with immediate access to trained crisis counselors, significantly reducing reliance on law enforcement and emergency departments for mental health emergencies. The updated guidance builds on this progress while addressing the urgent need for comprehensive crisis care systems.

The guidance reflects substantial input collected through listening sessions, expert consultations, and public feedback. Crucially, it underscores the importance of a coordinated, flexible, and compassionate approach to behavioral health crises at a time when the nation continues to grapple with increasing demand for services.

With public comments being sought on the draft Mobile Crisis Team Services Implementation Toolkit, SAMHSA aims to refine and finalize tools that advance the capacity of crisis teams to stabilize situations and connect individuals with long-term support. Please forward your comments to RCPA COO and Mental Health Services Director Jim Sharp for inclusion in the RCPA response to SAMHSA. This will addressed in the February 18, 2025, RCPA 988/Crisis Services meeting. You can register for the meeting here.

The Substance Abuse and Mental Health Services Administration (SAMHSA) is welcoming public comments on the draft SAMHSA Now Accepting Public Comments on Draft Model Behavioral Health Crisis Services Definitions.

SAMHSA developed the draft Model Behavioral Health Crisis Services Definitions document for state, territory, Tribal, and local entities; crisis services providers; public and private payers; regulators; and help seekers and their supporters to clarify and distinguish the different types of crisis services for people across the nation.

Interested people are invited to submit written comments for these draft definitions from Thursday, November 21, 2024, through Thursday, December 5, 2024, at 11:59 pm ET.

For more information on the definitions and to submit comments, please visit the Model Behavioral Health Crisis Services Definitions web page on the Crisis Systems Response Training and Technical Assistance Center website at the link below.

Read More Here

On behalf of its opioid treatment program (OTP) provider members, RCPA submitted comments to the Independent Regulatory Review Commission (IRRC) in support of a final-omitted regulation that would allow an initial physical examination required for prescribing, administering, and dispensing controlled substances through an OTP to be conducted via telehealth under certain circumstances under Pa. 49 Code § 16.92.

This final-omitted regulation would enable the Pennsylvania Department of Drug and Alcohol Programs (DDAP) to grant a statewide exception to 28 Pa. Code § 715.9(a)(4), which today requires Pennsylvania OTPs (called narcotic treatment programs in DDAP regulations) to conduct a face-to-face determination of whether an individual is currently physiologically dependent on an opioid.

IRRC will consider the final-omitted regulation at a public meeting on December 5.

In its comments, RCPA wrote:

“Enabling OTPs to conduct the initial examination required as part of induction into methadone or buprenorphine treatment through telehealth significantly improves and expedites patient access to the gold standard treatment for OUD without sacrificing quality or safety. In a treatment environment where finding qualified physicians, physician assistants and certified registered nurse practitioners is challenging, telehealth bridges a significant gap. Physicians would no longer need to be physically on site at the OTP where treatment is to take place to examine a patient as part of the induction process. Rather, from anywhere in the commonwealth, a physician can examine more patients, who can then begin treatment with medication faster at a facility near their home. In fact, with this final-omitted regulation, OTPs will have the ability to accommodate same-day or walk-in admissions instead of scheduling intake appointments days later.”

The final-omitted regulation, submitted by the Department of State, Bureau of Professional and Occupational Affairs, State Board of Medicine, along with comments in support from the Department of Drug and Alcohol Programs and RCPA, can be viewed on the IRRC website.

The PA Department of Labor & Industry’s Office of Vocational Rehabilitation (OVR) has further developed the draft of the Financial Needs Test (FNT) policy after incorporating feedback received during the September 2024 public comment period. As a result, there will be a second, shorter public comment period on the draft. The draft will be posted on OVR’s website for public review beginning November 11, 2024.

Virtual meetings will be held via Zoom at 9:00 am and 2:30 pm on Monday, November 18, 2024, to provide an overview of the policy and accept comments (content will be the same in both meetings). The public is invited to comment on the draft policy through November 22, 2024. Comments may be directed to OVR’s Public Comment inbox.

Zoom Meeting Information:

CART and sign language interpreters will be available for these meetings via the Zoom link.

Additional auxiliary aids and services are available upon request to individuals with disabilities. Please send your request to OVR’s Public Comment inbox.