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Substance Use Disorder

On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that announces and solicits public comments on proposed policy changes for Medicare payments under the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) and other Medicare Part B issues, effective on or after January 1, 2024.

The calendar year (CY) 2024 PFS proposed rule is one of several proposed rules that reflect a broader Administration-wide strategy to create a more equitable health care system that results in better access to care, quality, affordability, and innovation.

The proposed modifications include several pertaining to telehealth policy in the Medicare program for 2024. One of the major takeaways from the proposed 2024 PFS is the clarification that certain telehealth flexibilities that were previously extended until 151 days after the end of the public health emergency (PHE) have now been extended until December 31, 2024, in accordance with amendments made by the Consolidated Appropriations Act, 2023. These extensions have been known since the CAA’s passage in December last year and has also been addressed in a series of fact sheets and FAQ documents.

However, there were also some new changes addressed in the 2024 PFS. For example, every year CMS will consider adding new services to their list of codes that are reimbursable via telehealth. While they did not decide to add any new codes on a permanent basis to the list (though many remain on the list temporarily through the end of 2024), they did propose to add a number of codes to Category 3 (CMS’ current temporary list), including certain codes for health and well-being coaching services. Additionally, CMS announced a proposed revision to their telehealth code classification process, moving from a Category 1, 2 and 3 classification system to a binary ‘permanent’ or ‘provisional’ classification in an attempt to simplify the process beginning in CY 2025. In order to make the steps for getting a code accepted for inclusion in either the permanent or provisional telehealth lists transparent, CMS proposes a five-step process that is detailed in the proposed 2024 PFS, which includes consideration of the evidence of clinical benefits.

A few additional changes proposed in the document are listed below:

  • The list of telehealth practitioners is amended to recognize marriage and family therapists and mental health counselors as telehealth practitioners, effective Jan. 1, 2024.
  • CMS will pay for place of service (POS) 10 at the non-facility PFS rate, while 02 will be paid at the facility rate beginning Jan. 1, 2024.
  • Frequency limitation would be removed for subsequent inpatient visits through the duration of CY 2024.
  • Multiple clarifications are provided for billing both remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) codes.
  • Direct supervision is allowed to include real-time audio video interactive telecommunication through Dec. 31, 2024 (including for FQHCs and RHCs). Direct supervision requirements are also addressed for occupational therapists in private practice (OTPP) and physical therapists in private practice (PTPP) for unenrolled physical and occupational therapists when providing remote RTM.

CMS will be accepting comments on their proposals until 5:00 pm EST on September 11, 2023, and RCPA will review the document and work with the National Council for Mental Wellbeing in drafting recommendations. We welcome provider feedback and comments to be included and ask that you contact and share these with your RCPA Policy Director.

Join us at the 2023 RCPA Annual Conference A Decade of Unity for the latest in strategies and innovations within the health and human services sector. Held at the Hershey Lodge October 10 – 13, participants can earn CEs through workshops that will cover a wide variety of topics. Our full brochure is available, and we’ll be rounding out our first day at the lodge with:

  • Driving Pennsylvania’s Health Care Transformation: Integrating Perspectives for Advanced Patient-Centered Care
    • Discuss strategies and methods of health care system integration, including designing a roadmap for practical applications.
  • Purpose and Growth: Engaging and Retaining Your Teams in Challenging Times
    • Learn to retain employees in the face of generational gaps, the effects of the pandemic, and the economy by focusing on what they most want: purpose and growth.
  • Why Your Agency Needs A Specialized Telehealth Solution: Improving Health, Provider Cost Saving, Increased Satisfaction
    • Hear about StationMD and Mainstay Life Services’ telehealth partnership and how having a specialized telehealth solution can improve outcomes while lowering costs.
  • Data Strategies for Impact and System Transformation
    • Do more with your data by learning the stages of organizational development for data-informed decision-making.
  • Value-Based Purchasing: A Survival Guide
    • Review value-based purchasing and how it is a tool to be used to improve quality health care. This discussion will include best practices for utilizing data in real time.
  • Current Steps in Implementing Trauma-informed Care in Children’s MH RTFs
    • Learn about OMHSAS’s TIC Initiative for children’s mental health residential treatment facilities, which serves as part of PA’s commitment to becoming a trauma-informed state.
  • Individual Operations: Owning Your Own Influence
    • Understand what it means to be a leader and implement strategies that will strengthen your team, including utilizing and recognizing scheduling patterns, planning ahead, and knowing when to set and break boundaries.
  • Condition Support: Addressing Escalated Situations in the Health Care Setting
    • Analyze an overview of UPMC’s Conditional Support Process, which addresses patients or visitors who exhibit aggressive or hostile behaviors in order to protect medical professionals.
Register today!

In addition to an impressive roster of speakers, our 2023 Conference will have an exciting array of sponsors and exhibitors. We thank those who have signed on thus far! If you are interested in sponsoring or exhibiting, visit here for more details or contact Carol Ferenz, Conference Coordinator, with any questions you may have. Keep up-to-date and register today for #rcpaconf!

The Department of Human Services (DHS) recognizes that the corrective action process is a cornerstone of human services licensing. In 2019, the Department released a webinar, Developing a Plan of Correction, to assist providers with the successful development and implementation of acceptable Plans of Correction. Likewise, the Plan of Correction Quick Reference Guide was issued as a tool to assist our providers with this process.

The Department is seeking your feedback on these resources. Please complete this survey by July 26, 2023, in order to assist DHS in determining what additional steps are needed to ensure that our providers are sufficiently educated and supported in the Plan of Correction process.

If you have further questions, please contact your respective RCPA Policy Director for guidance.

Image by photosforyou from Pixabay

Life Unites Us is hosting a webinar at 12:00 pm on Tuesday, July 25, titled “Uniting Provider Communities: Improving Access to Behavioral Health and Substance Use Disorder Services for Older Pennsylvanians.” The webinar will cover Pennsylvania aging programs and services, the integration of behavioral health and addiction services, their delivery methods, and available resources within the aging network. Registration is available.

Life Unites Us is a collaboration between the Pennsylvania Department of Drug and Alcohol Programs, the Douglas W. Pollock Center for Addiction Outreach and Research at Penn State Harrisburg, and the nonprofits Shatterproof and The Public Good Projects. It aims to end stigma and improve access to addiction treatment and recovery by bringing together organizations fighting the opioid epidemic.

RCPA invites members to participate in the Coalition for the Mental Health Safety Net meeting on Wednesday, August 9, 2023, from 1:00 pm – 2:00 pm. You can register for the meeting here. Please note that if you previously registered for the July 12 meeting, you will need to register again. If you have any questions regarding registration, please contact Allison Brognia.

The Coalition is open to all stakeholder groups, and we encourage members to participate in these efforts of joint advocacy in protecting and preserving our mental health service delivery system. If you would like to join the coalition or have any questions, please contact Jim Sharp.

The Pennsylvania Department of Drug & Alcohol Programs (DDAP) is offering an online training module “Anxiety Disorders & Substance Use Disorder (SUD): Research-Based Strategies & Treatments.” The training covers effective treatments for individuals with co-occurring anxiety and substance use disorders, including cognitive-behavioral therapy, acceptance and commitment therapy, and mindfulness meditation. It includes interactive elements and takes approximately 4 hours to complete. To access the training, create or log in to your account on the TrainPA website and search for “PA-DDAP: Anxiety Disorders & SUDs” under courses. You can email DDAP’s training inbox or call 717-736-7452 for inquiries.