The Office of Mental Health and Substance Abuse Services (OMHSAS) issued a second set of questions and answers related to peer support services on June 15. The information is included below as presented by OMHSAS. More clarifications will be issued as questions are posed. Participants in the upcoming technical assistance sessions are asked to review information prior to the sessions. Please contact Betty Simmonds with further questions.
Question
1: Are co-payments required for Peer Support Services?
Answer: Since HealthChoices is now available in all counties and
since Peer Support Services are a required in-plan service in HealthChoices,
co payments are now under the jurisdiction of the Behavioral Health Managed
Care Organizations (BHMCO) in most cases. Deputy Secretary Joan Erney is instructing
the BHMCOs not to assess a co-payment for Peer Support Services in HealthChoices.
Although co-payments are required for this service in the Medical Assistance
Fee For Service (FFS) program, OMHSAS anticipates this will be a very infrequent
occurrence since the numbers of individuals served in FFS will be nominal.
Question
2: The Peer Support Services bulletin indicates that social, recreational,
or leisure activities are not appropriate Medicaid Peer Support services.
Does this mean that socialization will no longer be an appropriate goal?
Answer: No. If an individual identifies that one of the things they
want the Peer Specialist to help them with is to socialize and become more
integrated into the community, the Peer Specialist can include this in the
person’s individualized service plan as a goal. In order to bill for
Medicaid, all services provided by the Peer Specialist need to be identified
within the person’s plan and activity directed towards any goal must
be documented within the record. If an individual, however, merely wants to
participate in a leisure or recreational activity, this would not be reimbursable
through Medicaid and should be paid for out of funding sources. For example,
social rehabilitation programs, drop-in centers, and clubhouses organize group
activities for their members such as movies, ballgames, etc. which the Peer
Specialist can help connect people to.
Question
3: Why does a Mental Health professional have to sign off on the individual
service plan? We only have limited access to a mental health professional
within our program.
Answer: The Centers for Medicare and Medicaid services have set forth
in a white paper their requirements for approval of Peer Services under Medicaid.
One of those requirements is that a Mental Health Professional must supervise
the service. Therefore, in order for Pennsylvania to receive Medicaid funding
for this service, we must be in compliance with this requirement.
We are allowing providers to meet this requirement through a variety of options.
They can utilize a MH professional that is on staff or a MH professional that
is within the umbrella agency that holds the license for the program, or,
if necessary, an agency can subcontract with a licensed agency that can fulfill
this function.
Question
4: Why do Peer Support Services need to be deemed “medically necessary?”
Answer: Peer Support Services are now being funded by Medicaid. Medicaid
only provides payment for medical services and therefore requires that the
services are “medically necessary” in order for providers to receive
federal reimbursement. Please keep in mind that Peer Support Services funded
through Medicaid are only one piece of funding and there are many kinds of
services that can and should be provided by Peers outside of Medicaid. OMHSAS
expects that the helpful services provided by drop-in centers, consumer-staffed
programs, or other informal peer-to-peer activities will continue to be funded
with state, county, and other dollars.
Question
5: If I have to travel 30-50 miles to meet with my peers and I can’t
bill for phone calls and research time, I don’t see how I will get enough
billable hours in to compensate for my time. Can you explain?
Answer: The Department has been diligent in its efforts to research
and evaluate the development of Peer Support Services, including the establishment
of a rate. Pennsylvania’s rate is commensurate with what is currently
being paid by other states that have had a state plan amendment approved by
the Centers for Medicare and Medicaid Service. It is also in proportion with
other reimbursement rates that are on the Medicaid fee schedule. When we developed
the rate for Peer Support Services we took into consideration the “down
time” when a peer cannot bill for direct services. Much like the method
we used for developing the rate for case management services, the Peer Support
Services rate factors in a certain level of “productivity.” That
is, we subtracted time spent in training, on holidays, vacation, sick time,
and time spent in non-direct service and determined the average number of
hours per week or year that a Peer Specialist would be able to bill for direct
services.
The Department acknowledges that, just as with the provision of other services, it may not be feasible for all interested parties to provide Medicaid funded Peer Support Services without additional fiscal support. The submission of a State Plan Amendment for this service was not intended to meet all of the needs for peer support in Pennsylvania, but rather to offer one option for the payment of these services. Since Peer Support Services are now a required service in HealthChoices, the BHMCOs have the authority to establish their own rates and activities (including travel time, phone time, etc) that they will pay for. Providers should be in discussion with their BHMCO around these issues.
Question
6: Why is there a limit of 16 units a day on Peer Support Services? People
will not be able to get the help they need with this limit.
Answer: Sixteen (16) units a day or four hours of Peer Support Services
is a per person limit in Medicaid Fee For Service only. In HealthChoices,
which is where the vast majority of individuals will receive the service,
the BHMCO has the authority to set or remove any limits to payment, limits,
etc. This limit was established based upon the belief that the maximum amount
of time a Peer Specialist would likely spend in one day with any one individual
they are working with was four hours.
Question
7: Please clarify if the goals developed by the Peer Specialist for the Individual
Service Plan are part of the overall treatment plan/service plan developed
by the treatment team that is working with an individual, or whether the Peer
goals are included in a separate plan.
Answer: All service providers should be working with each individual
they serve to develop an individualized recovery-oriented plan. The plans
developed by each agency may vary in focus depending upon the type of service
that provider offers. In all cases, including Peer Support Services, goals
that are developed by a provider agency should be integrated into and consistent
with the person’s overall treatment plan. In a recovery-oriented system,
goals identified in all agency plans should be goals that the individual has
identified and is working towards.
Question
8: Providers are concerned about the availability and cost of training for
peer specialists and supervisors. Only one program has been available and
the requirements for holding training sessions have been costly. There have
been insufficient numbers of training slots available to meet the initial
and ongoing need.
Answer: OMHSAS is about to enter into an agreement with a second
training vendor – Recovery Innovations (formerly known as META). OMHSAS
has also issued a request for proposals to counties that want to apply for
free training slots within their communities. This round of free training
will insure that another 120+ individuals will be trained statewide. Counties
and providers are encouraged to contact either of the training vendors to
establish a training class in their area. OMHSAS should be contacted if there
are concerns about the availability of training so that we can resolve problems
when and where they arise. Per question 10 in the May 1, 2007 FAQ, Pennsylvania
will be contracting with two or three vendors with proven track records for
the first two years of implementation and then will assess the consistency,
quality, and availability of training. Any issues regarding these three areas
should be directed to OMHSAS.
We are encouraging counties to use reinvestment or other funds to pay for the initial training. We are also making available a sample contract of an agreement that was established between the Mental Health Association of SE Pennsylvnia and the Philadelphia District Office of Vocational Rehabilitation. We encourage other counties to establish similar agreements with their district OVR offices to pay for the Peer level training.
Question
9: We have concerns that the supervisory requirements in the Peer Support
Services bulletin are not sufficient to develop the necessary supervisory
skills.
Answer: The supervisory requirements in the Peer Support services
bulletin are: a high school diploma or equivalency, four years of mental health
direct care experience, and completion of the Peer Specialist supervisory
training. These baseline standards were recommended and agreed to by a broad-based
advisory group that helped to develop the overall standards for Peer Support
Services. These requirements are a minimum expectation and providers/BHMCOs
are free to establish higher qualifications to insure that supervisors are
qualified for the position.
Question
10: What are the documentation requirements for Peer Support Services?
Answer: The documentation requirements for Peer Support Services
are contained on page VII-8 section D of the provider handbook pages of the
Peer Support Services bulletin. Also cross-referenced in the bulletin, is
Title 55 PA Code 1101.51 (d) that contains the medical record requirements
for all Medicaid enrolled providers.
