PCPA Addresses FBMHS Draft Regulations
August 2, 2001
PCPA responded to the Office of Mental Health and Substance Abuse Services request for stakeholder input on Family Based Menth Health Services (FBMHS) and whether program standards should be developed. The letter from PCPA, reprinted below, outlines current issues providers have with the draft 1993 regulations for FBMHS. The letter also supports the initiation of a work group to support the potential standards. For more information contact the Association.
July 31, 2001
Beechmont Building, 2nd Floor
P.O. Box 2675
Harrisburg, PA 17105
On behalf of the Pennsylvania Community Providers Association, I would like to provide comments to you on the current draft Family Based Mental Health Services Regulations (May 1, 1993) and the potential of revising the draft regulations as well as creating standards for a variety of family based interventions. More specifically, I will provide you with feedback from PCPA's Family Based Mental Health Services (FBMHS) Subcommittee.
During our last FBMHS Subcommittee we held a discussion as to how, as providers, under the draft regulations we are held to standards that have made the FBMHS what they are today. Providers are very proud of the fact that they have been able to maintain the integrity of the program. However, there is the need to branch out and create specialized family based services in response to the changing needs of children and their families.
In the early 1990s when we began to provide services, we saw children with Medicaid and Non Medicaid resources. The children generally had a mental health issue and may have had another system involved. But as the years continue we are seeing children with more needs than we previous saw. More children have Medicaid resources. The complexity of the children's need and their family dynamics are more challenging. And more often than not, FBMHS are the last service (or the last resort) accessed by the child and the family. This is often after Behavioral Health Rehabilitation Services have failed. We are proposing that FBMHS be given a "face lift," be reenergized, and be given program standards. The program standards should allow us as providers the flexibility to work within other systems.
In order to sell our services to other systems we need to generate a set of standards for working with different systems and different situations. Here are some of our ideas for specialized program standards:
- Program Standards for Working with Children in the Juvenile Justice System
- Program Standards for Working with Children with Drug and Alcohol Issues
- Program Standards for Working with Children with Mental Retardation
- Program Standards for Working with Children that are dependent
- Program Standards for working with Adults with Mental Illness and their Children
- Program Standards for Working with Pregnant Women
Many of the rules that were proposed in 1993 may not be in the best interest of family based programs or the children and families served. One such rule, that we continue to challenge, is the rule that "the members of the treatment team and the program director may not be employed in another mental health program with the exception of the program director who may provide supervision to the Family Preservation Program" [See section 5260.21(7)]. We again feel that this rule needs updated to meet the challenges programs face such as staff shortages and program cutbacks.
Clarification is needed on the Family Support Services (FSS). There is confusion around the state, at the county level, and within managed care organizations as to what the budget implications are for family support dollars. Programs are constantly fighting for the monies they believe are a part of their budget. The monies are to support families as they strive to become independent, yet we are constantly at odds with others who feel the dollars should not be accessed for tangible items. There need to be specific guidelines for FSS dollars.
We believe in the training programs and believe the requirements fill the needs of programs. Providers should have the opportunity to have a choice of more than two training programs. We request that OMHSAS expand the training options. As we move into the age of technology, video conferencing and web-based training should be options for providers. The certification process has been beneficial in many cases. Not only does it make staff feel a sense of accomplishment, it has allowed providers to retain staff based on capabilities rather than on degree.
Further direction is needed on the 60/40 split. There are various methods of billing based on the interpretation of the split. We ask that this issue be addressed.
We also request that OMHSAS reevaluate the rate in which providers are reimbursed for services. Programs cannot maintain they if they are not cost reimbursed or given adjustments based on the cost of living increases.
FBMHS providers have proven that FBMHS work. We ask that the OMHSAS help us increase our visibility and capabilities by addressing standards of service.
Thank you for considering the programs standard revisions and addition of new standards. We look forward to your response.
If you have any questions please contact me at 717-657-7078 or via e-mail firstname.lastname@example.org.
Lisa M. Lowrie, LSW
Children's Policy Specialist