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Authors Posts by Jim Sharp

Jim Sharp

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has issued clarification on policy regarding encounter signatures for crisis services. The updated policy outlines that OMHSAS considers mobile mental health crisis services to be emergency services. While every effort should be made to obtain a signature from the beneficiary or a parent, legal guardian, relative, or friend, when such a signature cannot be obtained due to the nature of the situation, crisis intervention service providers are permitted to insert “Signature Exception” on the signature line of the encounter form.

RCPA has inquired if the encounter verification under these circumstances can be considered for similar applications to other programs under other OMHSAS licensed services. If you have any questions, please contact RCPA COO and Policy Director Jim Sharp.

Lack of BH Providers in Medicare and Medicaid Impedes Enrollees’ Access to Care

The Office of the Inspector General (OIG) has released a report citing there are not enough behavioral health providers participating in Medicare and Medicaid networks.

In an analysis published April 2, the government watchdog studied one urban and one rural county in 10 states across the country. The analysis found relatively few behavioral health providers are participating in Medicaid, Medicare, and Medicare Advantage programs, leading to difficulties in access for enrollees.

Notable Findings:

  1. On average, there were fewer than five active behavioral health providers accepting Medicare and Medicaid patients per 1,000 enrollees. Traditional Medicare had the lowest rates of providers, at 2.9 per 1,000 on average, and Medicare Advantage had the highest rate at 4.7 per 1,000 enrollees.
  2. Rural counties had fewer providers accepting Medicare and Medicaid than urban counties. In rural counties, there were 1.5 providers accepting traditional Medicare per 1,000 patients, compared to 4.4 in urban counties.
  3. Across Medicaid, traditional Medicare, and Medicare Advantage, there were fewer than two providers per 1,000 enrollees that could prescribe medication for mental health issues, such as psychiatrists and psychiatric nurse practitioners.
  4. Active providers accepting public insurance make up around one-third of the behavioral health workforce, according to the report.
  5. Fewer than 10% of public insurance beneficiaries received mental health treatment in 2023.
  6. CMS could also tighten network adequacy standards in Medicare Advantage and Medicaid to increase the size of insurers’ networks, the OIG said in its report.
  7. The OIG recommended CMS up its oversight of Medicaid and Medicare enrollees’ use of behavioral health services, and recommended CMS examine allowing more types of behavioral health providers to participate in Medicare and Medicaid.
  8. CMS said it concurred with the OIG’s recommendations and said it has already taken several steps to improve access to behavioral health providers for Medicare and Medicaid beneficiaries.

If you have questions please contact RCPA COO and Director of Mental Health Jim Sharp.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the OMHSAS-24-01 Restraint Seclusion and Exclusion Bulletin, updating policies on restraint, seclusion, and exclusion in state mental hospitals to reduce these practices. This bulletin supersedes OMHSAS-09-06, necessitating adjustments in local hospital policies. Changes include shifting from “manual hold” to “physical restraint” terminology and clarifications in definitions. It strictly prohibits mechanical and chemical restraints, allowing physical restraint only as a last-resort emergency measure with detailed guidelines on application, documentation, and debriefing protocols. The emphasis is on individualized care, de-escalation techniques, and personnel training to ensure the humane and judicious use of physical restraint.

If you have any questions, please contact RCPA COO and Policy Director Jim Sharp.

The Office of Mental Health and Substance Abuse Services (OMHSAS) April 2024 Stakeholder Webinar is scheduled for Thursday, April 18, 2024, from 3:00 pm 4:00 pm. You can now register for the meeting here. After registering, you will receive a confirmation email containing information about joining the webinar.

If you have any questions, please contact RCPA Policy Director Jim Sharp.

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The Office of Children, Youth & Family has compiled a list of the top 10 frequently asked questions (FAQ) regarding the renewal process for existing Certificates of Compliance/Licenses. These FAQs cover essential information for providers operating under office regulations, including document requirements, submission procedures, and anticipated timelines. Providers can access the Licensing Administration Top 10 FAQs and are able to share these FAQs with relevant personnel. Providers are also encouraged to include their Certificate of Compliance or License number and agency/facility name in all communications with Licensing Administration staff.

If you have any questions, please contact RCPA Policy Director Jim Sharp.