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Tags Posts tagged with "Public Comment"

Public Comment

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Image by Werner Moser from Pixabay

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 Block Grant application submission.

This submission will occur in three parts:

  • The Substance Abuse Prevention and Treatment Assessment and Plan;
  • The SUPTRS Report, which will be posted in November; and
  • The Annual Synar Report, which will be made available in December.

These documents can be accessed through the Substance Abuse and Mental Health Services Administration. Use “citizenpa” as the login and “citizen” as the password.

Submit all comments electronically by September 30.

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Image by Dirk Wouters from Pixabay

As part of the Independent Regulatory Reform Commission (IRRC) process for the promulgation of new regulations, the Final Form Regulations for the Psychiatric Rehabilitation Services (PRS) have been posted for review and public comment on the IRRC website. This public comment period runs for 30 days. The comments may be submitted by individuals, organizations, associations, etc. on the impacts of the regulations on the systems and individuals they serve.

The purpose of this final-form rulemaking is to amend Chapter 5230 to allow psychiatric rehabilitation services (PRS) to be provided to individuals who are diagnosed with posttraumatic stress disorder, bipolar disorder, major depressive disorder, or anxiety disorders without going through the exception process and to allow individuals who are 14 years of age or older but under 18 years of age who meet the admission requirements to access PRS. In addition, the final-form rulemaking clarifies the documentation that will be reviewed through the exception process to determine if an individual is eligible for PRS as well as revises outdated language.

The Department convened a work group that included stakeholders to review and provide input on the proposed rulemaking. The work group held face-to-face meetings on November 4, 2015; December 8, 2015; and January 28, 2016, to review the current regulation and provide recommendations for the proposed changes, which RCPA and its members took part in.

At this time, we are seeking any further public comment as it relates to these regulations. RCPA intends to submit comments on behalf of our members, though individuals and organizations may submit comments pertaining to the regulations directly to the IRRC website. Please submit your comments to RCPA COO and Mental Health Policy Director Jim Sharp.

The IRRC hearing on the Final Form Regulation Hearing will be held on September 19, 2024, at 10:00 am. RCPA intends to participate in the hearing to speak to our recommendations. If any member would like to attend and or testify, please contact Jim Sharp.

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The Bureau of Children’s Behavioral Health Services is pleased to invite stakeholders to an informational webinar. This webinar, scheduled for Thursday, July 25, 2024, at 1:00 pm, will highlight significant sections of the proposed Psychiatric Residential Treatment Facility (PRTF) regulations prior to the public comment period. Please note that comments and questions will not be addressed as part of this webinar but may be submitted during the public comment period.

The proposed PRTF regulations will codify the minimum licensing standards and Medical Assistance (MA) participation requirements and payment conditions for PRTFs that provide medically necessary behavioral health treatment to children, youth, or young adults under 21 years of age with a behavioral health diagnosis. Questions/comments about this webinar should be submitted electronically. If you have any additional questions, please contact RCPA CCO and MH Policy Director Jim Sharp.

View the details below to join the webinar:

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Phone conference ID: 363 691 933#

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Today, both the ISAC Performance Review Subcommittee and the Medical Assistance Advisory Committee (MAAC) meetings were held. During these meetings, the Office of Developmental Programs (ODP) announced that as a result of public comments received regarding Performance-Based Contracting, some adjustments are being made to the plans. Tomorrow, ODP will release an announcement with more details, but for now, we know the following:

  • Residential providers will be offered a choice of when they are assigned into a tier. This will be based on which data they chose for ODP to review and make a tier determination upon. The choices will be:
    • Calendar year 2023 data reviewed with notification of tier assignment occurring in November, to be effective January 1, 2025 – June 2026; or
    • Review of Calendar year 2024 data with notification of tier assignment occurring in May, to be effective July 2025 – July 2026.

ODP plans to submit the proposed waiver to CMS on July 19, 2024.

In addition, the presentation from the MAAC meeting can be found here.

Documents from the Performance Review Subcommittee can be found below:

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The Office of Long-Term Living (OLTL) has announced two waiver amendments that are open for public comment. The amendments detail the Community HealthChoices (CHC) waiver renewal and the OBRA waiver amendments. Information on the CHC waiver and OBRA waiver are available individually as well as in the June 15, 2024, PA Bulletin. Comments are due July 15, 2024.

Those interested in submitting comments can do so in the following ways:

  1. For the CHC waiver:
    1. Send a letter to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: Keeley Anglin—CHC Waiver Renewal, PO Box 8025, Harrisburg.
    2. Submit comments to the department via email. Use “CHC Waiver Renewal” in the subject line.
    3. Please use the CHC Waiver Comment Form.
  2. For the OBRA waiver:
    1. Send a letter to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: Keeley Anglin—OBRA Waiver Amendment, PO Box 8025, Harrisburg.
    2. Submit comments to the department via email. Use “OBRA Waiver Amendment” as the subject line.
    3. Please use the OBRA Waiver Comment Form.

Comments received by July 15, 2024, will be considered in subsequent revisions to the proposed renewal and amendment. For more information, please contact Fady Sahhar or Melissa Dehoff.

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Image by Werner Moser from Pixabay

ANCOR has shared that the first step to revise the Standard Occupational Classification process has begun. Today the Office of Management and Budget (OMB), on behalf of the Standard Occupational Classification Policy Committee (SOCPC) — which is the committee that makes recommendations to OMB for potential revisions — announced it is beginning the review of the 2018 Standard Occupational Classification (SOC) Manual for revisions to be made for 2028, and that it is soliciting public comment.

This is an opportunity to write comments in support of revisions to the SOC, in particular for the creation of a code for direct support professionals. In its notice for comments, OMB specifically notes that it “solicits and welcomes comments related to any aspect of occupational classification, especially comments concerning . . . whether to consider the addition of new detailed occupations or occupational groups, including specifically care workers.”

The public comment period is open until August 12, 2024. ANCOR will be submitting comments and providing additional guidance and tools to submit comments in the coming weeks.

For more information, the notice is available on the Federal Register website.

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RCPA has gathered feedback from our members in multiple forums and attended several listening sessions hosted by the Office of Developmental Programs (ODP) in order to hear and compile public comments on the proposed implementation of performance-based contracting (PBC) for Residential Services and waiver amendments to the Consolidated, Community Living, and Person/Family Directed Waivers. After reviewing all of the available information, we have submitted our comments to ODP.

Our members support the ideal of assuring quality services for individuals with ID/A that are integrated and person centered, enabling individuals to experience more independence and choices in their lives. Additionally, we are in favor of limiting the provider pool to only those providers that are able to demonstrate quality service provision.

RCPA wants to support this program for two reasons. First, any initiative by ODP that focuses on improving quality in the system is something we all should stand behind. Second, alternative reimbursement strategies with enhanced rates and additional funding based on quality and outcomes is certainly more innovative and progressive than traditional fee-for-service. It is time for the IDD system to move toward reimbursement policies that reward providers who are progressive in their service provision.

We are, however, concerned about the speed with which this incredibly complex systemic change is proposed to occur, and the amount of performance standards and measures proposed in this plan.

RCPA’s complete letter can be read here. For any questions, contact Carol Ferenz, Director, IDD Division.

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As a reminder, the public comment period ends next Tuesday, June 4, 2024, for the proposed implementation of Performance-Based Contracting for Residential Services, Waiver amendments, and proposed rates for services, which are effective July 1, 2024.

RCPA staff have participated in various listening sessions and met with members to hear your concerns regarding the proposed changes and rates. We will be sending our comments later this week and want to be sure that we are representing your interests. Please contact Carol Ferenz with any thoughts you have regarding these significant changes by close of business Wednesday, May 29, 2024.

Thank you for sharing your concerns. We strongly recommend that you take advantage of this opportunity to provide your own comments to ODP as well.

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