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Managing “BHRS Redesign”
November 8, 2012

Community providers of Behavioral Health Rehabilitative Services (BHRS) across the commonwealth are reporting that new or new interpretations of standards for “billable” activities and services, prescription changes, reductions, and denials and restrictive credentialing criteria are resulting in the curtailment of many medically necessary rehabilitative services. These are services developed by the state under Medicaid Early Periodic Screening, Diagnosis and Treatment (EPSDT) criteria. PCPA is offering 10 action steps that providers should consider in response to what the Office of Mental Health and Substance Abuse Services and its managed care contractors refer to as “BHRS Redesign.” 

  1. Promote the fact that BHRS, especially Therapeutic Staff Support and Summer Therapeutic Activity Programs, are EPSDT “rehabilitative services” supporting standard treatment interventions.
  2. Promote the fact that most child consumers in need of BHRS have a persistent and chronic behavioral health care condition.
  3. Promote the fact that many clinical conditions and symptomatic behaviors targeted will not change in a short period and frequently require progress maintenance services.
  4. Provide the clinical rational for prescribing services and activities that the behavioral health managed care organizations (BH-MCO) should recognize as rehabilitative.
  5. Quantify the projected reduction in services to clients and families as soon as possible.
  6. Inform schools and families that providers, not just your agency, are under extreme pressure to reduce the prescribed quantity of home, community. and school services and will not be able to bill for many activities (meetings and letters).
  7. Inform families that they may want to press for reduced, denied, and discontinued services in schools be replaced by their child’s schools through changes in their child’s Individualized Education Plan (IEP).
  8. Encourage schools to quantify the costs of the shift of service from a community Medical Assitance provider to the IEP and special education budgets.
  9. Quantify the reduction in employment (reductions in staffing and layoffs) caused by new BH-MCO authorization and billing standards.
  10. Track the life impact (school attendance, law enforcement contact, exclusion from community activity, emergency room services, hospitalizations, domestic violence, etc.) of service reductions.

As is always the case, BHRS interventions must be medically necessary, prescribed by a licensed psychologist or physician, and properly delivered and documented. Prescribers have the ethical and professional obligation to request authorization and provision of the quantity and type of services they deem to be clinically needed. Families should be encouraged to appeal reductions or denials of services prescribed.

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