RCPA - Rehabilitation and Community Providers Association


Coalition for Responsible Wraparound
AIM . Children, Youth & Families Education Consortium . Delaware County Autism Taskforce . Pennsylvania Community Providers Association . Pennsylvania Association of Rehabilitation Facilities . Pennsylvania Council of Children's Services . Pennsylvania Psychological Association . Springfield-Hopes . Sharing and Caring of Bucks County . The Greater Philadelphia Autism Society of America United Cerebral Palsy of Pennsylvania

December 15, 1998

Feather O. Houstoun, Secretary
Department of Public Welfare
Health and Welfare Building
PO Box 2675
Harrisburg, PA 17105-2675

Dear Secretary Houstoun:

We write to you on behalf of the Coalition for Responsible Wraparound, a newly formed coalition comprised of parents, advocates and providers to address our concerns regarding the draft bulletin on the Provision of Mobile Therapy, Therapeutic Staff Support and Behavioral Specialist Consultant Services to Children and Adolescents.

The bulletin will affect children who are currently being served and children who in the future may need the specialized and flexible services that ESPDT funding allows. Although member groups have sent in individual comments on the language contained in the bulletin, we have come together to express our concerns about more than just specific language.

Our first issue is the process by which the draft bulletin was developed. The bulletin was developed without the necessary input from parents and their children who are receiving services. We are concerned that the design of this bulletin was done in isolation and does not address the broad nature of the services to children and adolescents. Children with serious emotional disturbance, as well as children with head injury, mental retardation, substance abuse, and autism, will be impacted by the draft document. The ramifications of this bulletin will also affect parents and providers of service. We would like to work with you in an effort to address the issues that we as parents and providers live with every day in the treatment and care of our children.

Our second issue is the use of the bulletin as a substitute for regulation. A document of such influence over the direct provision and accessibility to services should never be promulgated without all of the safeguards that the regulatory process ensures. We were given a public comment period that was less than the IRRC would have allowed had this document gone through the regulatory process. Additionally, how can families and providers be assured that a bulletin is not subject to arbitrary change?

We urge you to begin this process again.

This time representative parents, providers, and advocates of all children who will be affected should be included. The Department must ensure that parents and providers are given the opportunity to voice constructive concerns and input on regulations for EPSDT Wraparound and that they are allowed to assist in the development of recommendations on a quality standard.

We thank you for your concern for children and quality services. We respectfully request a meeting with you to address the issues above.

We would greatly appreciate your response to our request by January 4, 1998, as we would like to address these issues as soon as possible. Please feel free to contact Evelyn Clark at (215) 953-1923 or Kathy Weaver at (610) 328-3995.

On behalf of the coalition,


Evy Clark, Parent
Sharing and Caring of Bucks County


Kathy Weaver, Parent

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