ODP ISAC Meeting Information Released
Residential Services
IRRC Releases OMHSAS PRTF Regulations for Public Comment
The Office of Mental Health and Substance Abuse Services (OMHSAS) has submitted to the Pennsylvania Independent Regulatory Review Commission (IRRC) IRRC No. 3417 — Psychiatric Residential Treatment Facilities (14-555) regulations for the first phase of the promulgation process.
At this time, the regulations will be open for the submission of public comments from November 2, 2024, to December 1, 2024. The IRRC will review these comments and work with OMHSAS on developing responses as well as any potential language changes.
This process for regulation development with stakeholders began in 2019, and RCPA and its members have been active partners with the OMHSAS Children’s Bureau in the ongoing process through forums and work group meetings. The RCPA Residential Services Work Group completed a cursory review of a PRFT regulation presentation by OMHSAS in July and will begin working on developing a full response to the regulations.
RCPA will be connecting with these members this week to schedule the PRTF Regulatory Review Team that will support our recommendations to the current draft. If any member is interested in participating in the review group, please contact RCPA COO and MH Director Jim Sharp.
The regulations can be view at the links below.
Reminder: RCPA IDD Member Webinar on Provider Rights for Rate Appeals to Be Held Sept. 19
RCPA IDD Member Webinar on Provider Rights for Rate Appeals to Be Held Sept. 19
ODP Announces Adjusted Timeframes and Changes to Performance-Based Contracting Plans
After reviewing hundreds of comments from stakeholders, the Office of Developmental Programs (ODP) has made some initial adjustments to the proposed Performance-Based Contracting waiver for Residential Services. Areas with high volumes of comments included:
- Select/Clinically Enhanced Tiers being reserved for agencies serving 10 or more individuals;
- Competitive Integrated Employment standards;
- Populations served with average Needs Level 4.5+ and average Health Care Level 3.5+ (HCL is established using the Health Risk Screening Tool);
- Primary providers being limited to Needs Group 1-3;
- The number of measures; and
- The timeline for implementation.
ODP is now offering Residential providers 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 continue their review of public comments and intends to publish additional information. On July 19, ODP hopes to submit amended the 1915(c) waivers and 1915(b)4 waiver as well as publish the following supporting documents:
- Performance Standards;
- Implementation Plan;
- Attestation; and
- Provider Data Submission Tool.
On January 1, 2025, ODP intends to begin Performance-Based Contracting (pending CMS approval).
ODP will conduct a webinar for residential providers on Monday, July 22, 2024, from 3:00 pm – 4:00 pm, to review publications, changes made as a result of public comment, and instructions for tier determination and data submission. Register here. This webinar will be posted on the PBC Resource Page located on the MyODP website.
ODP Hosts First Provider Preparedness Summit
Today, June 3, the Office of Developmental Programs (ODP) held the first of four Provider Preparedness Summits for Residential Services providers. The purpose of the summits are to take a deeper dive into the specifics that are being proposed for implementation of performance-based contracting (PBC).
The PowerPoint is now available, and a recording of the session will be posted shortly on the MyODP website.
ODP staff in attendance answered many questions submitted by providers. One of the key takeaways from today’s summit is that ODP will be postponing the due date for residential provider agreements to be signed and submitted to ODP. Originally, they were projected to be due by June 30, 2024; however, ODP has now stated that the due date will be July 31, 2024. The agreement has not yet been published, but it is expected to be released tomorrow, June 4, 2024.
There are three additional summits planned, and ODP will be recording each summit. Providers are encouraged to attend all four sessions as well as watch a pre-recorded webinar. All of these resources can be found on the MyODP website.
Contact Carol Ferenz for further information.
Recording of Residential ISP Training for Program Specialists Now Available
ODP Announcement 24-049 announces that the recording of the live virtual training sessions held in February and March 2024 regarding implementation of the Residential ISP Staffing approach for Program Specialists is now available on MyODP.
The recorded training session is provided for Residential Provider Program Specialists who contribute to ISP development but were unable to attend the live, virtual training. The training focuses on Program Specialist expectations in ISP development and ensuring consistent, statewide implementation of the Residential ISP Staffing approach.
Program Specialists are responsible for providing critical and up-to-date information to the ISP team so that the ISP is person-centered and mitigates risks to health and safety.
All participants must complete the current prerequisite online training (Residential ISP Staffing: It’s About the Person, Not the Numbers) before being able to view the recordings.
One Week Left to Submit Comments on ODP’s Proposed Implementation of Performance-Based Contracting
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.
ODP Issues Clarification on New Residential Qualification Requirements in Waiver Amendments
The Office of Developmental Programs (ODP) has shared ODPANN 24-008. The purpose of this communication is to provide clarification regarding new residential qualification requirements in waiver amendments, effective November 1, 2023, including the release of a Frequently Asked Questions (FAQ) document. This clarification includes the requirement to have prior experience providing non-residential waiver services. Please view the announcement and FAQ document for information and details.
Clarification on IDD Providers’ Role in Medicaid Renewal Process
Deputy Secretary Ahrens has shared information regarding avoidable Medicaid non-renewals for individuals. If an individual is receiving waiver services and loses their MA, this has the unfortunate outcome of the individual being dis-enrolled in the waiver. In turn, services rendered during a time when the individual is ineligible will not be paid through waiver funds.
If your agency serves as a representative payee or provides waiver services, especially residential services, this can have a serious impact on both your agency and the individual receiving services. Of note:
- As of 10/17/2023, the Office of Developmental Programs (ODP) has a record of 444 enrolled individuals (223 of whom are waiver participants) whose MA was not renewed procedurally. These participants’ renewal dates span April through September 2023.
- 176 individuals (45 of whom are waiver participants) were registered and had their MA closed due to ineligibility.
The primary reasons appear to be that asset limits were exceeded and determination paperwork had not been returned (procedural closure). There are individuals who receive residential services in these groups. Please note that sometimes paperwork may go to a guardian or representative payee. In those situations, it’s important that there is communication between the provider and the responsible person. In particular, providers should be aware of the following:
- Individuals receive MA renewal paperwork in the mail at their home address. Providers/SCOs should ensure that the CAO always has up-to-date contact information for individuals receiving MA.
- Renewal dates differ. Individuals should receive renewal info about 90 days prior to the due date.
- If a provider has questions about renewal dates for individuals, AEs and SCOs are provided data on all individual MA renewal dates.
Please ensure that your agency is aware of the renewal dates and is prepared to respond quickly and/or assist the guardian or family member who may be receiving the paperwork. Additionally, please be cognizant of the asset limits and consider opening an ABLE account if all the individual’s needs are met.
For any questions, contact Carol Ferenz.
