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Information Sought Regarding Psych Time in RTFs
December 14, 1999

Steve Jewell of Pressley Ridge Schools has been serving as a PCPA representative to a state committee discussing interim program standards for RTFs. As part of that group, he is requesting your input and information, as noted below. You can respond to Steve by FAX (412-321-5313) or e-mail. Thank you for your assistance!

Over the past two months I have been part of a workgroup convened by the Pennsylvania Office of Mental Health and Substance Abuse Services (OMHSAS) focused on updating/upgrading the state's program standards for RTFs. Our goal is to take the new Chapter 3800 regulations for children's residential facilities (which address only health & safety), and decide what needs to be added to those standards to ensure some minimum level of quality within such programs. As such we are going through the Chapter 3800 regulations almost line-by-line, talking about what needs to be added. As you might imagine, the discussion is lively given the many stakeholder groups represented. Some of the issues can be resolved in the meeting, but some need to be given consideration outside of the meeting and have proposals brought back to the group for their review.

In that context, I have been given a task by the group that I am asking your help with. I have been asked to come to the next meeting (1/6/00) with a proposal for the minimum number of hours of on-site psychiatric time that should be available for children & adolescents placed in an RTF in PA. Neither the existing federal (HCFA) or state regulations address this issue at all. The work group feels that this is a serious oversight, and wants it addressed.

As an initial point of discussion, the group reviewed the current state licensing requirements for children's partial hospital programs (PHPs), noting that to be licensed as a child PHP in PA there needs to be a minimum of 2 hours of on-site psychiatric time per week for every 5 children enrolled in the program. There seemed to be a sense that this standard would be inadequate if applied to RTFs. It was decided, however, that more input was needed from stakeholders outside the group before a decision was made.

While it is clear that defining a minimum number of hours is a positive step forward in assuring some minimum standard for quality of care in a level of care that serves kids with serious problems, choosing a specific formula for this is difficult. On the one hand, setting a standard that is too low may lower the quality of services provided to these needy kids. On the other hand, an excessive requirement could be very costly (and difficult to provide in some rural parts of the state), thus potentially reducing access to this important level of care.

I am therefore asking for your help in three ways:

  1. Please let me know your sense of the current standard of practice with regard to the number of psychiatric hours/resident/week provided in RTFs you are currently involved with, or have been involved with in the past.
  2. Please let me know what your suggestion would be for a proposed standard for psychiatric hours that would be reasonable to present to the group.
  3. Please share with me any existing regulations or standards for psychiatric time in RTFs that you might be aware of in other states or in the guidelines/criteria of managed care organizations, etc.

I will keep your individual responses confidential if you like, but will collate the overall responses to see if there is a consensus that emerges from those who do respond. (If you are interested, I would be happy to share this consensus with you after I have gotten all the responses.)

Again: the next meting of this group is on 1/6/00, so any response that I can receive from you before that date would be greatly appreciated. Thank you. Steve Jewell

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