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PCPA Responds to OMHSAS Accreditation Plan
April 21, 1999

Carol Ward-Colasante
Office of Mental Health and Substance Abuse Services
P.O. Box 2675
Room 201, Beechmont Building
Harrisburg, PA 17105

Dear Ms. Ward-Colasante,

The Pennsylvania Community Providers Association represents over 230 community agencies serving persons with mental illness, mental retardation, and/or drug and alcohol addiction. Our mission is to promote quality community services for persons using these services. We appreciate the efforts of the Office of Mental Health and Substance Abuse Services in addressing the inconsistent application of regulations, duplication and overlap of departmental licensing survey visits, and the rigidity of the inspection process. Providers often find themselves in the middle of a sometimes contradictory process. With OMHSAS working toward less cumbersome regulations and licensing processes, the quality of services community providers offer can be greatly improved. We look forward to being involved in the process.

As was mentioned in the OMHSAS Workplan, there is much duplication and overlap of departmental licensing survey visits. The Workplan only hints at the benefits OMHSAS believes the provider will realize in this plan. Accreditation must not be one more layer of accountability and cost. PCPA recommends that providers be given "deemed status" to continue to reduce this duplication. Deemed status would result in the acceptance of accreditation as the equivalent of licensure/certification, and allow accreditation to result in licensure approval.

The licensing agencies within the Departments of Public Welfare, Health, and Aging must all accept this deemed status in order to reduce duplication. Therefore, accreditation would waive all regulations for providers that are "deemed" acceptable. We ask that OMHSAS provide a clear plan about how the presumed reduction in oversight and regulation will occur once agencies gain accreditation.

There were several possible accrediting bodies mentioned in the Workplan. The final selection of accrediting bodies by OMHSAS must allow providers to determine the appropriate accrediting body to their services. This is a crucial part of the accreditation process, as it will provide the best "fit" between the accrediting body and the provider.

In providing a choice of accrediting bodies however, the possibility arises for multiple accreditation of a single provider. For example, if an accrediting agency will accredit five services, but an agency provides ten services, will that provider be required to find a second or third accrediting body to accredit the other five services? The possibility of providers needing multiple accreditation must be thoroughly reviewed and ultimately avoided.

The cost of accreditation is of great concern to community providers who are already working on a tight budget. While continuous quality improvement is extremely important, it is equally important that providers remain financially viable in order to provide services. Various options for defraying the cost of accreditation need to be considered and must not be left the sole responsibility of providers.

The Pennsylvania Community Providers Association is willing to survey its members currently accredited by the bodies listed in the Workplan. This will provide OMHSAS the opportunity to determine the true cost of accreditation, including application fees, on-site review fees, annual maintenance fees, as well as additional costs of meeting accreditation requirements, such as hiring more staff to fulfill more stringent staffing ratios.

While we support agencies having choice in which accrediting body they will use, we also want to provide the choice to not seek accreditation. Agencies request the option to either opt for accreditation or continue with licensure as it is presently carried out. Accreditation for agencies must be considered within the scope, size and reach of their programs, including an option to be accredited for specific services at the same cost that they are incurring currently for licensing.

We have received numerous comments about the inclusion of drug & alcohol (D&A) licensure and regulations into the Cross System Licensing Project (CSLP). The Association is unclear about the ramifications of D&A being included, and want to assure that any decision made in that direction would protect and not diminish the quality of D&A services and the integrity of the D&A programs. At this time, the Association does not have an official position on whether or not D&A regulations should be included in the CSLP and are awaiting further information on how this would be carried out. We recommend careful consideration of this matter and ask that PCPA be a significant partner in any discussions OMHSAS has.

Two other questions require clarification:

  • There appears to be some confusion surrounding network accreditation vs. provider accreditation and under what circumstances either accreditation is acceptable. Will the Office of Mental Health and Substance Abuse Services accept network accreditation in addition to or in place of provider accreditation? How will this decision be made and carried out?

  • The state's role as gatekeeper will require a clear directive on how licensure, credentialling, accreditation, and contractual relationships will be viewed. We must not create yet another system wherein these four very important elements are contradictory. What plans does OMHSAS have for preparing the environment to accept and work toward unification of these four aspects?

Again, we thank you for the opportunity to provide comments on the OMHSAS Accreditation Workplan. We eagerly await participation in further actions OMHSAS will be taking to address these matters.

Respectfully,
Raymond R. Webb, Jr., LSW
Executive Director

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