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Telehealth

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the OMHSAS-24-05 Peer Support Services (PSS) Bulletin and PSS Provider Handbook, updating the requirements for Peer Support Services. OMHSAS significantly reorganized the existing language in the Handbook to better clarify which requirements apply to OMHSAS licensure and which apply to Medical Assistance payment. Along with these formatting changes, OMHSAS-24-05 includes the following updates:

  • Staff Qualifications and Requirements for Certified Peer Specialists (CPS)
    • The requirement for a CPS to have a high school diploma or GED has been removed.
    • The requirement for a Serious Mental Illness (SMI) or Serious Emotional Disturbance (SED) has been replaced with a requirement to have a mental health diagnosis. Please note, to be eligible to receive PSS services, there is still a requirement for “the presence or history of an SMI or SED.”
    • The clause requiring CPSs “to attain certification through the PCB within six months of hire” has been removed, as the certification examination is now available on-demand, eliminating the need for a grace period for testing to be completed.
  • Staff Qualifications and Requirements for CPS Supervisors
    • Adding a new qualification category for individuals with an associate degree.
    • Supervisory meetings held in an audio-only format shall not be considered supervision.
    • Supervisory meetings shall be provided at a minimum of one hour each week.
  • Telehealth
    • The prior requirement that only 25% of total services provided per beneficiary per calendar year can be delivered by telephone has been removed.
    • PSS may be provided via telehealth technology, including audio-only service delivery, when it is clinically appropriate to do so.
    • PSS providers must ensure that the preference of individuals receiving services (or their legal guardian) is given a high priority when determining the appropriate service delivery modality.

Please review all other revisions to OMHSAS-24-05 here.

Comments and questions regarding this bulletin should be directed to:
Office of Mental Health and Substance Abuse Services, Bureau of Policy, Planning and Program Development,
P.O. Box 2675,
Harrisburg, PA 17105
General Office Number: 717-772-7900
Email

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

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Capitol hill building in the morning with colorful cloud , Washington DC.

On December 21, President Biden signed into law the 2025 American Relief Act, a stopgap funding bill passed by Congress on December 20 that funds the federal government through March 14, 2025, and includes over $110 billion for disaster relief.

The bill extends certain Medicare telehealth flexibilities through March 31, 2025, under Section 3207, including the six-month in-person requirement for mental health services, the expanded originating sites, and coverage of audio-only services.

The bill also extends funding for several expiring health care programs through March 31, 2025, including the National Health Service Corps at $85 million and the Teaching Health Center Graduate Medical Education Program at $43 million, both under Section 3101.

In addition, the stopgap bill delays scheduled reductions to the Medicaid Disproportionate Share Hospitals allotments, which are currently set to result in a total reduction of $32 billion between 2025 and 2027. Under Section 3401, the bill delays these cuts through April 1, 2025.

You can read the bill text and a summary of the health care provisions.

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The Pennsylvania Department of Drug and Alcohol Programs (DDAP) today issued Licensing Alert 08-2024 to detail the steps for SUD treatment providers to obtain a telehealth-only license from the department.

These DDAP-licensed telehealth-only providers may provide intake, evaluation, and referral, as well as outpatient or partial hospitalization services, via telehealth only without a physical plant location in Pennsylvania to individuals who are located in the commonwealth as long as the provider complies with all applicable federal, state, and local laws. Any DDAP-licensed provider can also provide some telehealth services as an option to in-person treatment. However, only a telehealth-only provider may provide 100 percent of its treatment services via telehealth.

DDAP will not require the provider to maintain a physical location in Pennsylvania. DDAP also will grant all telehealth-only providers an exception to § 709.11(b) regarding the requirement to conduct an onsite inspection for the renewal of a license as part of licensure.

Licensing Alert 08-2024 applies only to DDAP licensure. Providers that are considering applying for a telehealth-only license should consult their public and private insurance payers to confirm whether they will meet conditions for network enrollment and payment, as DDAP cannot guarantee a DDAP-licensed telehealth-only provider funding or a contract.

The full licensing alert provides additional information, including how to apply for the license.

Contact RCPA SUD Treatment Services Policy Director Jason Snyder with any questions.

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Despite opposition and concerns from substance use disorder (SUD) treatment providers, single county authorities, primary contractors, and behavioral health managed care organizations, the Pennsylvania Department of Drug and Alcohol Programs (DDAP) will begin licensing telehealth-only SUD treatment providers.

DDAP will issue a licensing alert on Wednesday, December 4, detailing the new licensure category.

Organizations newly licensed under this tele-only category will be able to provide intake, evaluation, and referral services, as well as outpatient treatment, including partial hospitalization services, via telehealth only, without a physical plant location in Pennsylvania.

DDAP’s intention in licensing telehealth-only providers is to hold them to the same standards as facility-based providers as a way to ensure equity and maintain operational standards. DDAP will continue to monitor complaints and unusual incidents for all licensed providers, as well as the number of telehealth-only license applications that are made over time, looking for any trends that could require additional action.

RCPA and its provider members opposed creation of the new license, citing patient safety and quality concerns, as well as potential erosion of the community-based provider system. RCPA hosted DDAP for a discussion about its concerns, met one-on-one with the department, and provided written feedback to DDAP. In addition, RCPA met with the governor’s Policy Office, to discuss provider concerns.

DDAP will attend RCPA’s next SUD Committee meeting at 11:00 am on Tuesday, December 10. RCPA has asked DDAP to discuss the new license category. RCPA members wanting to attend this meeting can register here.

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As RCPA previously communicated, the Drug Enforcement Administration (DEA), jointly with the U.S. Department of Health and Human Services (HHS), has extended the temporary COVID-19 telemedicine flexibilities through December 31, 2025. These flexibilities enable prescribing of controlled medications via telemedicine. As such, the Pennsylvania Department of Drug and Alcohol Programs’ (DDAP) suspension of 28 Pa. Code § 715.9(a)(4), which allows an initial evaluation for a person who will be treated by an opioid treatment program (OTP) with buprenorphine to be completed via telehealth, is also extended.

DDAP’s complete Information Bulletin 03-2024 is available here.

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The Office of Long-Term Living (OLTL) has announced new services that will be available as a result of the Community HealthChoices (CHC) Waiver renewal and OBRA Waiver renewal. Effective January 1, 2025, the following services will be available:

Chore Services – CHC Only

  • Provider Type: 59
  • Specialty Code: 431
  • Procedure Code: S5131

Teleservice Cognitive Rehabilitation Therapy – CHC and OBRA

  • Provider Type: 59
  • Specialty Code: 207
  • Procedure Code: W0176

Teleservice Counseling Services – CHC and OBRA

  • Provider Type: 59
  • Specialty Code: 231
  • Procedure Code: W0175

Teleservice Nutritional Consultation – CHC and OBRA

  • Provider Type: 59
  • Specialty Code: 230
  • Procedure Code: W0170

The rates for the OLTL Home and Community-Based Services (HCBS) rates, effective January 1, 2025, are available here.

Additional information on the licensure and certification requirements can be found in the Service Definitions under Appendix C of the waivers. Please note that these documents have not received final approval from the Centers for Medicare & Medicaid Services (CMS). Once approval is received, a ListServ message will be sent with links to the final approved waiver applications.

The Fee for Service rates for Teleservice Cognitive Rehabilitation Therapy, Teleservice Counseling Services, and Teleservice Nutritional Consultation have been added to the fee schedule attached to the ListServ.

For existing OLTL providers to enroll in the services listed above a request must be submitted to the enrollment and certification resource account. The required documentation should include an updated Provider Enrollment Information Form (PEIF), a copy of the required license or certification, and a copy of the job description for the service you are requesting to add to your provider profile. If you have any questions related to the new services you can reach out to the enrollment and certification unit at 1-800-932-0939, option 1, or via email.

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On Friday, November 1, the Centers for Medicare & Medicaid Services (CMS) released an anticipated Final Rule titled “CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS 1809-FC),” which includes three new exceptions for the federal “four walls” rule. At present, the “four walls” rule prohibits Medicaid payment for clinic services when both the practitioner and individual receiving service are outside of the “four walls” of the clinic unless the services are being provided to unhoused individuals (such as through street medicine). The new exception for Indian Health Services and Tribal Facilities is required nationally. The exceptions for Behavioral Health Clinics and Rural clinics are optional. States who determine that their Behavioral Health Clinic and/or Rural Health Clinic populations served meet the four criteria established by CMS (see page 1323 of the final rule) must submit a Medicaid State Plan Amendment (SPA) and receive approval from CMS for these exceptions to be in place for their state.

The Office of Mental Health and Substance Abuse Services (OMHSAS) had been working toward a short-term state level solution to the four walls issue for both Outpatient Psychiatric Clinics and Drug and Alcohol Clinics. However, now that a long-term federal option has been made available, the team in OMHSAS will be pivoting to pursue this newly available federal exception for Behavioral Health Clinics. While OMHSAS is still in the process of developing a timeline for the new State Plan Amendment, their team will be working on this as a top priority, with the goal of having a SPA in place in early 2025.

It has been confirmed that OMHSAS will not be shifting their current enforcement policy around the four walls while they work through getting this waiver in place. RCPA will continue its collaboration with OMHSAS on the process as this move forwards. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

For additional information, please see the following:

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