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Tags Posts tagged with "Telehealth"

Telehealth

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Photo by Markus Winkler on Unsplash

The Office of Mental Health and Substance Abuse Services (OMHSAS) Deputy Secretary Jen Smith recently provided an update on the federal four walls rule. The Centers for Medicare and Medicaid Services (CMS) has issued a proposed rule, or Notice of Public Rulemaking, that could create exceptions to the existing four walls requirement for IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas.

The official language posted to the federal register can be found on page 15 of the Federal Register, which is scheduled to be published on July 22, and is copied below.

“This proposed rule includes a proposal to create exceptions to the Medicaid clinic services benefit four walls requirement, to authorize Medicaid payment for services provided outside the four walls of the clinic for IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas. Our current regulation at 42 CFR § 440.90(b) includes an exception to the four walls requirement under the Medicaid clinic services benefit only for certain clinic services furnished to individuals who are unhoused. We believe these proposed exceptions would help maintain and improve access for the populations served by IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas.”

As a reminder, this is a proposed rule intended to announce and explain CMS’s plan to address the problem. As such, all proposed rules must be published in the Federal Register to notify the public and give them an opportunity to submit comments. The proposed rule and the public comments received on it form the basis of a final rule. More information on the final rulemaking process is available here. Interested parties should provide public comments on this proposed rule to the addresses listed in the federal register by September 9, 2024.

While CMS works through this process, OMHSAS, RCPA, and the PA General Assembly continue efforts to address this through the recently released HCO 3450 legislation that will address the psychiatric outpatient in-office requirements and the Medicaid “4 walls” standards. RCPA will work with our members and the National Council for Mental Wellbeing on developing public comments for submission regarding this proposed rule. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

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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 Office of Developmental Programs (ODP) is pleased to offer a webinar regarding the Specialty Telehealth and Assessment Team (STAT) waiver service. STAT is a new waiver service available to individuals in the Person/Family Directed Support (P/FDS), Community Living, and Consolidated Waiver programs. STAT is a telehealth service that is consultative and provides disability-specific advice on when best to seek additional or in-person medical treatment for the participant. It provides 24/7 access to physicians with extensive education and experience within the IDA population 365 days a year, who triage and evaluate medical conditions as needed. This webinar will provide an in-depth look at the STAT waiver service, how it works, and the benefit to participants.

ODP Will be holding two sessions. The information will be the same at both. Pre-registration is required. Select the preferred session date to register.

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Photo by Markus Winkler on Unsplash

The Medical Assistance Bulletin 08-24-04, issued by the Department of Human Services (DHS) Office of Medical Assistance Programs (OMAP), provides updates to the PROMISe (Provider Reimbursement and Operations Management Information System) Provider Handbook 837, Professional/CMS-1500 Claim Form, specifically focusing on Appendix E – FQHC/RHC (Federally Qualified Health Center/Rural Health Center) Handbook. Released on March 1, 2024, the bulletin outlines revisions to Federal and State requirements for FQHCs and RHCs in Pennsylvania participating in the Medical Assistance (MA) Program.

Notable changes include the addition of pharmacists and licensed dietician-nutritionists as eligible practitioners for billable encounters starting March 1, 2024. The revision addresses group therapy encounters and introduces guidelines for telehealth, telemedicine, and teledentistry in FQHC and RHC services. A new section on alternative payment methodologies is included, along with updates to the MA Cost Reporting and Wraparound Reporting sections. The Centers for Medicare & Medicaid Services’ clarification designates “hospital” as an allowable place of service for FQHC and RHC services. Providers are encouraged to review the revised handbook for detailed information on these changes.

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

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RCPA is pleased to report several successful collaborative efforts this week, including a meeting with DHS, OMHSAS, and a delegation of House and Senate Representatives. We reviewed proposed language for a new bill that would address the 4 walls standard for ongoing telehealth with practitioners not within the 4 walls of a clinic. The bill will also include language previously introduced on the Psychiatric Outpatient Regulatory requirements for the 50% in-office time for clinics and the use of advanced practice professionals to meet those time requirements.

The language for both target areas was approved by all parties and will now move on to the House Human Services Committee. RCPA has a meeting scheduled for early next week to review the finalized version prior to its introduction. We have also met with Senate counterparts to support the measure.

Lastly, RCPA continues its dialogue with OMHSAS for guidance and clarification, including sharing members’ and stakeholders’ feedback. We have had the opportunity to speak with our BH-MCO members and understand OMHSAS Deputy Secretary Jen Smith will be meeting with that group and the county contractors on the processes moving forward.

We are hopeful for an expedited legislative solution that will aid OMHSAS in making any resulting policy, practice, or program changes that will support the initiative. We are extremely encouraged by the system’s efforts and focus this week and will continue to provide key updates to members and stakeholders.

If you have any questions, please contact RCP Policy Director Jim Sharp.

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