Office of Mental Health and Substance Abuse Services (OMHSAS) representatives addressed questions about the transformation of long term structured residences (LTSR) to adult outpatient programs (AOP) in an alternative setting at the June Mental Health Committee meeting. Issues related to documentation requirements, expectations of individuals’ participation for billable services, staff qualifications, and coding issues were discussed. OMHSAS has prepared a draft question and answer document to assist with policy interpretations. A recommended documentation form was made available to AOPs, but is not mandatory. Although documentation is needed to record service delivery, individual responses, and other activities, strict adherence to recording start and stop time, for example, is not required. Billing will be done using an alternative payment strategy such as a daily, weekly, or monthly rate. Billing will be completed based upon average levels of participation in programs during the payment period. Providers had serious concerns about having sufficient qualified staff to meet requirements for billing services. For example, the AOP does not meet psychiatric rehabilitation requirements for 25 percent of staff to be certified and cannot expect to consistently train, certify, and maintain staff with the level of turnover in most residential programs. Certified staff is not always available to provide psychiatric rehabilitative service and the AOP does not qualify as a psychiatric rehabilitation provider. Waivers of psychiatric rehabilitation requirements have not been entertained by OMHSAS. They remain opposed, but concede that some waivers may be considered in the future if providers are unable to maintain qualified staff.
Existing LTSRs are very different from each another. Each is to submit a service description (using the OMHSAS provided template) that describes services they provide. The template should be tailored to address individual provider practices. Providers are encouraged to submit service descriptions in draft form for review and feedback from OMHSAS before submitting the final document. Providers are encouraged to discuss questions and concerns about LTSR/AOP with county and OMHSAS regional office contacts. PCPA members should contact Betty Simmonds (717-364-3280) to discuss LTSR/AOP concerns.
