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Tags Posts tagged with "Regulatory Reform"

Regulatory Reform

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The Pennsylvania Independent Regulatory Review Commission (IRRC) has completed their review of existing Intensive Behavioral Health Services (IBHS) regulations codified at 55PA. Code chapters 1155 and 5240, as requested by the RCPA IBHS Steering Committee.

The RCPA IBHS Regulatory Reform Recommendations, submitted on November 29, 2022, requested the commission to review the IBHS regulations under section 8.1 of the Regulatory Review Act, which provides that the commission may review any existing regulation which has been an effect for at least three years.

The commission has noted the burden placed on providers by the Department of Human Services regulation, but while they appreciated our concerns, the commission’s role is to determine whether existing regulations, as a whole, remain in the public interest. In the commission review letter, they determined that further action by the commission is not warranted in this matter.

We have been in contact with OMHSAS throughout this two-year period, and the commission provided the department with guidance as part of the review process. Despite the ruling from the IRRC, OMHSAS has agreed that they will reopen the IBHS for review as announced by OMHSAS Deputy Secretary Jennifer Smith at the RCPA Conference last week. RCPA will be reviewing the recommendations to calibrate those areas that continue to create barriers to access that have arisen since the recommendations created in the Fall of 2022.

If you have any questions, please contact RCPA COO and Policy Director Jim Sharp.

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The Pennsylvania Department of Drug and Alcohol Programs (DDAP) is conducting a survey on regulatory reform that will help guide its work in this area. The survey is available online, and responses are due by close of business March 28, 2024. Regulations governing licensed addiction treatment providers under DDAP’s authority can be found in the Pennsylvania Code and Bulletin. If you have any questions, please contact Cynthia Beidler.

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On behalf of the RCPA Community Residential Rehabilitation (CRR) service providers and the individuals of Pennsylvania that they serve, RCPA submits our CRR Regulatory Reform Recommendations to the Office of Mental Health and Substance Abuse Services (OMHSAS). 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 individuals waiting for services are compelling reasons, in the interest of the public, to merit a review of the regulations based on section 8.1 of the Regulatory Review Act (71 P.S. § 745.8a).

The COVID-19 DHS regulatory flexibilities provided relief for providers, and OMHSAS continues to offer waivers to agencies experiencing critical staffing shortages. Providers are grateful for these temporary solutions; however, these waivers do not address the long-term impacts of the current regulatory requirements. Providers continue to struggle to hire qualified staff and contend with burdensome operational requirements, many of which negatively contribute to the efficiency of care delivery. Therefore, many of the guidelines that were allowed under the suspension of regulations and frequent waiver requests are incorporated into recommendations for permanent improvements to the regulations.

Our recommendations place focus on the care of the individuals and address the challenges and barriers CRR service 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 individuals. Under current regulations, programs are forced to focus on administrative details that do not have a meaningful effect on the actual care of the individual.

These CRR Regulatory Recommendations will also be directed to the Governor’s Policy Office, the Department of Human Services (DHS) Secretary Arkoosh, and members of the Pennsylvania General Assembly.

RCPA would like to thank the members of the CRR Regulatory Review team for their focused and diligent efforts to make this submission possible. If you have any questions, please contact RCPA Policy Director Jim Sharp.

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