RCPA - Rehabilitation and Community Providers Association


DPW Proposes Changes to Welfare Code
June 21, 2013

The Department of Public Welfare (DPW) is circulating language reflecting proposed changes in the welfare code. The draft legislative amendment document is available. The document states:

Amending the act of June 13, 1967 (P.L.31, No.21), entitled "An act to consolidate, editorially revise, and codify the public welfare laws of the Commonwealth," further providing for county human services consolidated planning and reporting; in medical assistance benefit packages, providing for a premium schedule for disabled children; in children services, providing for payments to counties for services to children, further providing for provider submissions; and in human services block grant pilot program, providing for the expansion of the Human Services Block Grant Program.

While awaiting sponsorship of this potential legislation, it appears that the intent of the department and some members of the legislature is to make significant changes in the welfare code that may have a significant and substantial impact on recipients of children’s mental health, health care, and child welfare services, along with families and organizations serving these children and youth. PCPA is awaiting proposed language as it relates to changes in medical assistance benefit packages providing for a premium schedule for disabled children. The association’s opposition the expansion of the Human Services Block Grant is well established.

PCPA has grave concerns about the department’s intentions and goals with regard to language reflected in the draft document regarding payments to counties for services to children. Current concerns include the following issues.

  • Delay in payments by counties to service providers that are contingent on submission of an invoice that “satisfies the county's requirements for a complete and accurate invoice” and receipt by the county of payments from DPW.
  • Payments to providers within 45 days of invoice rather than a more reasonable 30-day payment process that supports provider cost management, payroll and vendor payment, and credit costs routinely incurred by organizations.
  • Proposed language that would call for a provider to “submit information to the Department, in a form and manner prescribed by the Department, for the purposes of determining which costs of services are eligible for reimbursement with federal and state funds.”  Provider and county experiences with the past “form and manner” for reporting real operational costs, allowable costs, and related delays in contracting and payments have been unreasonably complex, expensive, intrusive, and problematic.
  • While PCPA appreciates that “the Department will be charged to convene a Task Force which shall develop recommendations for a reimbursement methodology for the purchase of services from providers,” the experiences of several years call for the work of the task force and a consensus-based report to be completed prior to any legislative amendment.

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