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Public Comment

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Last week, House Bill 2300 was referred to the House Professional Licensure Committee. HB 2300: Legislative Package to Join the National Counseling Compact & Changes to Behavioral Specialists (Former HB 2852), allows Pennsylvania to join the Counseling Compact, enabling Licensed Professional Counselors (LPC) to practice across state lines without needing additional licenses. This change aims to improve access to mental health services by supporting telehealth, allowing LPCs to provide remote counseling. The compact also mandates standardized licensure requirements, including a 60 semester-hour master’s degree, a nationally recognized exam, and supervised postgraduate experience. RCPA is seeking member input as we develop our position on the legislation.

The Compact establishes a data system for sharing licensure and disciplinary information among member states, enhancing oversight and public safety. It mentions granting authority to member states to take actions against LPCs who violate regulations and creates the Counseling Compact Commission to oversee the implementation and administration. These changes ensure consistent standards for mental and behavioral health providers, increasing mobility and the availability of BH services.

As RCPA reviewed the details of this piece of legislation, one item of interest was that the bill entails the creation of a commission in Pennsylvania that will need to be funded. In the past, portions of commission operating costs have been realized by an increase in licensing fees. It is important to note that RCPA has not yet seen any fiscal package associated with the bill.

We ask that members review the bill and provide commentary as well as an organizational position of support, neutrality, or non-support. Please contact RCPA COO and Policy Director Jim Sharp with any feedback or questions.

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The Information Sharing and Advisory (ISAC) Committee for the Office of Developmental Programs (ODP) met on Tuesday, April 23, 2024. Deputy Secretary Ahrens gave an update and reminded members that on Friday, April 19, 2024, ODP published two very important announcements:

  • ODP Announcement 24-038: Open for Public Comment: Proposed Waiver Amendments and Rates for Services Funded Through the Adult Autism Waiver (AAW); and
  • ODP Announcement 24-039: Open for Public Comment: Proposed Implementation of Performance-Based Contracting for Residential Services, Waiver Amendments to the Consolidated, Community Living, and Person/Family Directed Waivers, and Rates.

Public comments are due June 4, 2024, for both of these announcements.

The proposed rates will be dependent on the governor’s budget passing with the proposed increases for ODP services remaining intact. Deputy Secretary Ahrens urged all stakeholders to advocate with legislators to keep this funding in the budget. Governor Shapiro has been visiting programs and sharing publicity about the importance of these services.

The Deputy Secretary also reviewed the current plans for Performance-Based Contracting for Residential Services with ISAC members. ODP has shared provider preparedness tools with the Residential Strategic Thinking Group for their feedback before publishing the provider preparedness tools and holding provider forums to support providers as they get ready for PBC implementation.

Provider preparedness tools include a Residential Provider Performance-Based Contracting Preparedness Assessment, which comes with a template to support providers developing plans to improve performance on the standards ahead of implementation in January 2025.

Once comments are reviewed and analyzed and any revisions made, the waiver application and amendments will be submitted to the Centers for Medicare & Medicaid Services (CMS) for review, and negotiations implementation target date is January 1, 2025.

RCPA is holding a meeting with our members to develop comments for submission to ODP on Thursday, May 9, 2024, from 9:30 am – 12:00 pm. We ask that you register for this meeting here in order to share your thoughts and help us as we develop our response.

For any questions, please contact Carol Ferenz.

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The Department of Human Services (Department) is making available for public review and comment the Office of Developmental Programs’ (ODP) proposed application for a section 1915(b)(4) waiver for a selective contracting program as well as amendments to the Consolidated and Community Living waivers required to implement selective contracting for Residential Habilitation, Life Sharing, and Supported Living services. The selective contracting program will be referred to as Performance-Based Contracting.

The Department is also making available for public review and comment additional proposed amendments to the Consolidated, Community Living, Person/Family Directed Support (P/FDS), and Adult Autism Waivers that are not related to implementation of selective contracting. Changes are proposed to become effective on January 1, 2025.

When performance-based contracting is implemented, all currently enrolled residential providers will have the opportunity to enter into a performance-based contract with ODP. To help support providers with the new requirements and process, ODP will hold provider trainings so that providers have a clear understanding of the process and expectations. As part of this process, providers will submit documentation demonstrating compliance with the performance areas identified by ODP. Additionally, ODP will use data from participant experience surveys, claims, incident management, health risk screening, administrative entities, and a new Performance Analysis Services vendor to evaluate each provider’s performance against the established standards and determine the tier in which the provider will be placed.

Providers will be placed in one of the following tiers based on their performance:

  • Conditional for providers operating under provisional or revoked licenses;
  • Primary for providers that meet current standards and a few additional standards;
  • Select for providers that deliver at least two of the three residential services in the performance-based contracting model and meet enhanced measures; or
  • Clinically Enhanced for providers that offer clinically enhanced medical or behavioral supports and meet enhanced measures.

The Department proposes the following substantive amendments to the Consolidated and Community Living waivers that will support the implementation of performance-based contracting, effective January 1, 2025:

  • Allow for the Department to contract with a Performance Analysis Services vendor that will provide administrative support with data collection, analysis, and reporting functions;
  • Require residential service providers to sign a residential provider agreement, which requires providers to comply with performance standards and reporting requirements outlined in the agreement and ODP policy; and
  • Implement pay-for-performance supplemental payments for residential service providers that meet or exceed performance targets for staff credentialing, employment of individuals served, transition of individuals to Life Sharing or Supported Living services, and reporting on use of technology.

Supplemental payments will be calculated for residential providers meeting or exceeding performance standards as a one-time or combined payment up to 3% of ODP-eligible service revenue from the applicable review period or established payment amount per qualifying event. Providers that have been determined to be a Primary, Select, or Clinically Enhanced provider are eligible to receive the supplemental payments.

  • Pay Licensed Residential Habilitation, Unlicensed Residential Habilitation, Life Sharing, and Supported Living providers that meet the requirements to qualify as a select provider or a Clinically Enhanced residential provider a payment that is in addition to the Medical Assistance fee schedule rate. Select providers will receive a rate add-on of 5% per individual served, and Clinically Enhanced providers will receive a rate add-on of 8%.

Other proposed amendments unrelated to Performance-Based Contracting include:

  • Assuring effective communication for individuals who use American Sign Language through implementation of a new American Sign Language — English Interpreter service. Services will be reimbursed as a vendor service based on the cost that the provider charges to the general public.
  • Promoting health, wellness, and safety by clarifying that individuals who receive services in an acute care hospital will not be disenrolled from the waiver.
  • Supporting the quality of Assistive Technology provided by expanding the qualification requirements for a professional who can complete an evaluation of an individual’s need for Assistive Technology and clarifying that evaluations can be completed for technology costing less than $750 if the service plan team believes it will be beneficial.
  • Increasing community participation and employment by requiring providers of Community Participation Support and Day Habilitation services to annually complete an analysis of each individual’s interests, preferences, skills, and strengths that support the individual’s participation in employment or other community activities.
  • Including revisions to align waiver requirements with regulatory requirements, correct errors, and provide clarification requested by stakeholders.
  • Increasing employment of individuals by allowing indirect activities to be billed through the Benefits Counseling service and improving access to Benefits Counseling for individuals who are not eligible for the Federal Work Incentives Planning and Assistance program.

The Department proposes the following substantive amendments to the Adult Autism Waiver that are not related to implementation of performance-based contracting effective January 1, 2025:

  • Support the quality of Residential Habilitation, Community Home, and Life Sharing services, through alignment of provider qualifications with the qualifications included in the Consolidated and Community Living waivers.
  • Promote health, wellness, and safety by clarifying that Residential Habilitation providers must have a licensed nurse available if the provider serves individuals with needs that require care by a licensed nurse.
  • Promote self-direction, choice, and control by clarifying that Community Transition Services can be used to support individuals transitioning from settings such as Residential Habilitation to private residences in alignment with guidance in the CMS instructions, technical guide, and review criteria for 1915(c) waivers.

View Performance-Based Contracting Information:

View Proposed Changes to the Waivers, Including Changes Not Related to Performance-Based Contracting:

Comments received within 45 days of publication of this notice will be reviewed and considered for revisions to the proposed application for a section 1915(b)(4) waiver as well as proposed amendments to the waivers. Comments should be addressed to Julie Mochon, Department of Human Services, Office of Developmental Programs, 625 Forster Street, Room 510, Harrisburg, PA 17120. Comments may also be submitted to the Department via email using the subject header ”Waiver Comments.”

RCPA will be scheduling a meeting for members to develop comments in response to these proposed amendments. Please contact Carol Ferenz with any questions.

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The Office of Developmental Programs (ODP) has published the proposed Fee Schedule Rates for services funded through the Consolidated, Community Living, Person/Family Directed Support (P/FDS), and Adult Autism Waivers and Base-Funded Program, residential ineligible services, as well as the accompanying rate assumption logs. These rates are proposed to become effective July 1, 2024.

Comments received by 11:59 pm on June 4, 2024, will be reviewed and considered for revisions. Interested persons are invited to submit written comments regarding the proposed rates. Comments may be submitted to the Department via email, and RCPA will schedule a meeting with our members to develop our comments.

Proposed Fee Schedule Rates and Department-Established Fees for Community-Based Services in the Consolidated, Community Living, and P/FDS Waivers and Base-Funding:

Adult Autism Waiver: 

* The proposed AAW fee schedule rates have not been posted

Comments about rates for services in the Consolidated, Community Living, and P/FDS Waivers and base-funding should be addressed to Department of Human Services, Office of Developmental Programs, Division of Provider Assistance and Rate Setting, 4th Floor, Health and Welfare Building, 625 Forster Street, Harrisburg, PA 17120.

Comments about rates for services covered in the Adult Autism Waiver should be addressed to Jamie Bonser, Department of Human Services, Office of Developmental Programs, 625 Forster Street, Room 510, Harrisburg, PA 17120.

We understand that the waiver amendments, including the details regarding Performance-Based Contracting, are scheduled to be published in the PA Bulletin this weekend, and we will share those with members as soon as they are available.

We would like to thank business member Paul Stanalonis for sharing an impact analysis he developed today. Please note that this comparison is based upon the rates that have continued to be in effect throughout COVID, and were not adjusted as originally planned by ODP.

Please contact Carol Ferenz with any questions. A meeting announcement will be sent to members once a date and time is confirmed.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2025 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule. The proposed rule will be published in the March 29, 2024, Federal Register. A high-level overview of the proposed rule is provided below:

Payment Updates:

CMS estimates an overall increase in aggregate payments to IRFs by 2.5% or $255 million (compared to the 4% payment update in FY 2024).

Market basket update for IRF services is 3.2%. This will be reduced by a productivity adjustment of 0.4%, which would result in an overall 2.8% increase. These figures are likely to change due to updated forecasts.

CMS is proposing to update the outlier threshold amount from $10,423 (FY 2024) to $12,158 (FY 2025), which would account for an estimated 0.2 percent decrease to aggregate payments across the IRF PPS in FY 2025.

Quality Reporting Program (QRP) Updates:

CMS is proposing to make additions, modifications, and removals of some QRP measures. A proposal was included to collect four new Standardized Patient Assessment Data Elements (SPADE) in the IRF QRP to bolster the collection of information on social determinants of health (SDOH):

  • Living Situation: Requests regarding the current living situation;
  • 2 Food Items: Questions about food running out;
  • Utilities: Questions about threats to shutting off utilities; and
  • A modification to an existing SPADE on Transportation.

CMS is also proposing to remove the “Admission Class” from the IRF Patient Assessment Instrument (PAI).

Feedback is requested on future revisions to the IRF QRP, as well as feedback on the development of a five-star methodology for IRFs.

Additional information will be forthcoming. Comments on the proposed rule are due to CMS by the end of May.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) invites public review of the Fiscal Year 2024 Projects for Assistance in Transition from Homelessness (PATH) grant application on the Mental Health in PA website. The PATH grant, established under the Stewart B. McKinney Homeless Assistance Amendments Act of 1990, assists individuals with serious mental illness facing or at risk of homelessness. The application, submitted annually to the Substance Abuse and Mental Health Services Administration (SAMHSA), is open for public comment until 10:00 am Friday, March 22, 2024. For questions or comments, please contact Lauren MacWithey, Pennsylvania PATH Grant Coordinator.

Additional questions can be sent to RCPA Policy Director Jim Sharp.

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The Department of Aging has released the second draft of Aging Our Way, PA, the department’s name for Pennsylvania’s 10-year strategic plan to support improvement in infrastructure and services for older adults. This second draft is open for a 30-day comment period until March 20. Visit here for details and instructions on submitting comments, and please consider providing feedback on the plan.

If you have any questions, please contact RCPA Policy Director Fady Sahhar.

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The Independent Regulatory Review Commission (IRRC) recently posted a proposed regulation from the Pennsylvania Department of State on behalf of the State Board of Physical Therapy (PT) for consideration.

The State Board of Physical Therapy (Board) proposes to amend §§ 40.1, 40.14, 40.15, 40.61, 40.63, 40.67, 40.163, 40.164, and 40.192. The proposed rulemaking will allow physical therapist (PT) students and physical therapist assistant (PTA) students to sit for the requisite examinations up to 90 days prior to graduation from their respective programs, and it will allow PTs and PTAs to receive a limited amount of continuing education credit for providing clinical instruction to student PTs and student PTAs at clinical facilities affiliated with accredited programs. Additionally, the proposed rulemaking will allow applicants to directly register for the national examination with the examination provider, by removing the requirement that the applicant first seek the Board’s permission. Lastly, it will allow applicants to sit for a third or successive examination, after two failures, without first seeking the Board’s permission.

The amendments will be effective upon notice or publication of the final-form rulemaking in the Pennsylvania Bulletin scheduled for January 27, 2024. The proposed regulation will be open for public comment upon publication, and comments will be accepted through February 26, 2024. Written comments, recommendations, or objections regarding this proposed rulemaking should be sent to Thomas M. Davis, Board Counsel, at P.O. Box 69523, Harrisburg, PA 17106-9523 or by email within 30 days of publication of this proposed rulemaking in the Pennsylvania Bulletin. Please reference “Regulation No. 16A-6522 (Early Exam, CE for Clinical Instruction, and AAP)” when submitting comments. IRRC comments on the proposed regulation will be due by March 27, 2024.

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The PA Department of Labor & Industry’s Office of Vocational Rehabilitation (OVR) has developed a draft of the Audiological Services policy. The draft will be posted on OVR’s website for public review beginning January 15, 2024. Virtual meetings will also be held via Zoom at 10:00 am and 3:00 pm on Wednesday, February 7, 2024, to provide an overview of the policy and take questions and comments. Please note that content will be the same in both meetings.

The public is invited to comment on the draft policy for 30 days. Comments may be sent electronically through February 16, 2024.

Meeting information:
Wednesday, February 7, 2024
After registering, you will receive a confirmation email containing information about joining the meeting.

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 via email.

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