RCPA - Rehabilitation and Community Providers Association


BHRS Redesign: Action and Recommendations
Decembr 3, 2012

The Children’s Committee met with consumer advocates and state practitioner organizations to discuss what the Office of Mental Health and Substance Abuse Services and its managed care contractors refer to as “BHRS redesign.” Providers of Behavioral Health Rehabilitative Services (BHRS) are reporting that prescription changes, service reductions and denials, and new or new interpretations of standards for billable activities are resulting in the curtailment of medically necessary rehabilitative services. PCPA and the Disability Rights Network of Pennsylvania (DRN) are collaborating to gauge, track, and respond to the impact of changes on consumers, families, and providers. 

Questions for Providers

  • Are you seeing an increase in denials?
  • Is there a pattern to changes in service authorization (Diagnostic group, home vs. school vs. community denials, service type)?
  • What reasons are you seeing for denials?
  • Are you appealing the denials?
  • If so, what are the outcomes of the appeals?
  • Are the rules affecting prescriptions? How?
  • Are you seeing and can you document adverse impacts on individual children as a result of denials?

Requests From DRN and PCPA

  • DRN wants to hear directly from families whose children have been denied services through its intake system, through an online survey, or both.
  • DRN would like providers to obtain permission to send them redacted denial notices (with some way for you to later identify the child if needed).
  • DRN would like to receive data about the effectiveness of BHRS.
  • DRN would like to receive data about changes in service authorization patterns for BHRS at your agency.
  • Encourage families to take a survey on this issue at https://www.surveymonkey.com/s/DRNSurvey-ChildrensBHRSinPennsylvania. The DRN Alert regarding this survey that can be disseminated to families is attached.
  • Providers and Families can contact DRN’s Intake Team at 800-692-7443, x400 or intake@drnpa.org.

Recommendations From PCPA and DRN

  • Continue to prescribe what children need.
  • Support families wishing to file appeals of denials.
  • When prescribing a service or writing a treatment plan that involves cuing or prompting, use those words but be specific about the behaviors (which can include appropriate communication) you are prompting (as opposed to helping with academic or recreational skills).
  • When prescribing Therapeutic Support Staff (TSS) for a child with Attention Deficit Hyperactivity Disorder, discuss the option of seeing a psychiatrist for medication evaluation with the family and state in the evaluation that you discussed that option with the family. Document family input and reasoning for prescribing TSS with or without medication.
  • When prescribing community-based activities, identify the skills that are to be addressed in the context of developmentally appropriate integrated activities. State whether the skills are to be transferred to the caretaker or to the child and, if to the child, whether the caregiver’s presence is necessary and age or setting appropriate.

Families and Providers may contact the DRN Intake Team as noted above. Providers and families may contact Children’s Policy Specialist Connell O’Brien (717-364-3280 or connell@paproviders.org).


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