Policy Areas

ODP Announcement 19-066 serves as notice of the opportunity for public comment on proposed changes to the Consolidated, P/FDS, and Community Living Waivers. These changes (referred to as waiver amendments) are anticipated to be effective on October 1, 2019. As part of this process, ODP is seeking your valuable feedback and comments on the proposed waiver amendments. There is a 30-day public comment period that began on June 8, 2019 and ends on July 8, 2019.

Whenever substantive changes are made to an approved waiver, ODP must submit an amendment to the Centers for Medicare and Medicaid Services (CMS) for approval. ODP proposes to amend the Consolidated, P/FDS, and Community Living Waivers as follows:

  • Increase the number of individuals served in the Consolidated and Community Living waivers as provided for in the Governor’s proposed budget to support more people in the community.
  • Add planning requirements for Administrative Entities to address access to needed waiver services upon graduation to individuals who will graduate from special education and who are not eligible to continue their education through the next year.
  • Provide for support of children with medical needs who transition from a facility that does not meet waiver home and community-based settings requirements to live with their families or, if living with their family is not possible, in the home of another nurturing caregiver.
  • Increase community participation of waiver participants through changes in service definitions, such as the addition of an on-call and remote support component to the Community Participation Support service and clarification as to where newly enrolled licensed facilities can be located.
  • Increase competitive integrated employment of waiver participants by allowing Supported Employment services to be provided when a waiver participant has received an offer of competitive integrated employment and the Office of Vocational Rehabilitation (OVR) has not made an eligibility determination at that time and by clarifying where Advanced Supported Employment services can be provided.
  • Develop and support qualified staff by extending the timeframe by which requirements for employment credentials or certificates must be obtained to July 1, 2019 for Supported Employment, Small Group Employment, and the prevocational component of the Community Participation Support service.
  • Promote health, wellness, and safety by clarifying that Supports Coordinators should review information in health risk screening tools when applicable and determine whether there have been any changes in orders, plans, or medical interventions prescribed or recommended by medical or behavioral professionals when Supports Coordinators monitor a waiver participant’s health and safety, and develop Individual Support Plans (ISPs).
  • Clarify the role direct service professionals perform through Communication Specialist services.

The proposed amendments to the Consolidated, P/FDS, and Community Living Waivers effective October 1, 2019 are available here.

Information regarding the proposed waiver amendment changes, including how to provide comments, can be found in the Pennsylvania Bulletin, Volume 49, Number 23, published on Saturday, June 8, 2019.

Comments received by 11:59 pm on July 8, 2019 will be reviewed and considered for revisions to the waiver amendments submitted to CMS.

Comments should be addressed to Julie Mochon, Department of Human Services, Office of Developmental Programs, 625 Forster Street, Room 510, Harrisburg, PA 17120. Comments may also be submitted to ODP at this email.

ODP will also hold two webinars to receive comments on the proposed waiver amendments. Dates, times, and links for registration to attend these webinars are as follows:

  • Thursday, June 20, 2019, 1:00 pm to 3:00 pm
  • Monday, June 24, 2019, 10:00 am to 12:00 pm

Register for webinars using this link. Questions about this communication should be submitted via email.

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The Centers for Medicare and Medicaid Services (CMS) has issued a press release with a Request for Information (RFI) seeking new ideas from the public on how to continue progress of the Patients Over Paperwork Initiative to be published in the June 11, 2019 Federal Register. The initiative was originally launched in the fall of 2017. Since that time, CMS estimates that through regulatory reform alone, the health care system will save an estimated 40 million hours and $5.7 billion through 2021. These estimated savings come from both final and proposed rules.

This RFI invites patients and their families, the medical community, and other health care stakeholders to recommend further changes to rules, policies, and procedures that would shift more of clinicians’ time — and our health care system’s resources — from needless paperwork to high quality care that improves patient health. CMS is especially seeking innovative ideas that broaden perspectives on potential solutions to relieve burden and ways to improve:

  • Reporting and documentation requirements;
  • Coding and documentation requirements for Medicare or Medicaid payment;
  • Prior authorization procedures;
  • Policies and requirements for rural providers, clinicians, and beneficiaries;
  • Policies and requirements for dually enrolled (i.e., Medicare and Medicaid) beneficiaries;
  • Beneficiary enrollment and eligibility determination; and
  • CMS processes for issuing regulations and policies.

Comments on this initiative must be submitted by August 12, 2019. For additional information, visit the Patients over Paperwork page on the CMS website.

On Friday, June 14, the Pennsylvania Association for Infant Mental Health (PA-AIMH) will offer their third breakfast network opportunity and a presentation entitled “Infant Mental Health: So what? Who cares?”

The breakfast and presentation run from 8:30 am to 10:30 am at the Pittsburgh PaTTAN office. Visit their Eventbrite site for registration information.

Infant Mental Health: So what? Who cares?
Robert Gallen, PhD, IMH-E®
Associate Professor of Practice, Applied Developmental Psychology
University of Pittsburgh

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RCPA is pleased to report that the long-awaited Outpatient Regulations have been submitted to the Pennsylvania’s Independent Regulatory Review Commission (IRRC). A copy is available of the final-form annex of the Outpatient Regulations, 55 Pa. Code Chapter 1153, Outpatient Psychiatric Services and 55 Pa. Code Chapter 5200, Psychiatric Outpatient Clinics. Also available is the regulatory summary, which indicates that the final regulations will be published in September 2019.

A few of the highlights include the new requirements for psychiatric time, staffing patterns, and time frame for the development, review, and sign-off of treatment plans. Below is an excerpt from the regulatory summary:

“Previously, a psychiatric outpatient clinic was required to have a psychiatrist at the clinic for at least 16 hours each week and employ four full-time equivalent (FTE) mental health professionals regardless of the number of individuals being served. The regulation amends the requirements for staffing patterns and psychiatric time by allowing 50% of the treatment staff who provide psychotherapy to be mental health professionals and requiring 2 hours of psychiatric time for each FTE mental health professional and mental health worker per week. Additionally, although 50% of the psychiatric time must be provided by the psychiatrist at the psychiatric outpatient clinic, the final-form rulemaking allows the other 50% to be provided by an advanced practice professional or by a psychiatrist offsite through the use of tele-behavioral health, or by a combination of advanced practice professionals and tele-behavioral health, consistent with the OPOA.

The final-form rulemaking allows 30 days for the development, review, and sign-off of the initial treatment plan, and extends the time frame for treatment plan updates to 180 days. In addition to changes to the time frame for the treatment planning process, the rulemaking allows a psychiatrist or an advanced practice professional to review and sign the initial treatment plan. Previously, only a psychiatrist could review and sign an initial treatment plan or update. The final-form rulemaking also allows the treatment plan updates to be reviewed and signed by the primary professional providing services to the individual at the psychiatric outpatient clinic. The primary professional may be the mental health worker under the supervision of a mental health professional or a mental health professional. For individuals receiving medication management services, the primary professional may be a physician, an advanced practice professional, a certified registered nurse practitioner (CRNP), or a physician assistant (PA) prescribing medication within the practitioner’s scope of practice. The rulemaking will improve access to medically necessary behavioral health services, including medication management services, and allow licensed professionals such as advanced practice professionals, CRNPs, PAs, or mental health professionals to provide services within their scope of practice when employed by a psychiatric outpatient clinic.”

RCPA looks forward to attending the IRRC meeting when these regulations are presented for approval. Further updates will be provided. If you have any questions in the meantime, contact Sarah Eyster.

a memo is on the keyboard of a computer as a reminder: meeting

On June 3, 2019 the Office of Children, Youth and Families (OCYF) hosted the monthly Child Welfare Council meeting at the Child Welfare Resource Center in Mechanicsburg. The day-long session provided interactive overviews and discussion on new Title IV E funding for legal representation, a Family First Update, an OCYF update, and a review of the PA Council Charter. View/download the meeting highlights. If you have any questions, please contact RCPA Children’s Division Director Jim Sharp.

The Washington Post hosted an event recently, focused on the mental health and addiction crisis in America, where Senators Debbie Stabenow (D-MI) and Roy Blunt (R-MO) joined actress and mental health advocate Glenn Close to speak about the importance of expanding Certified Community Behavioral Health Clinics (CCHBCs). See video excerpts below:

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Attention:  In preparation for the end of the grandparenting period in August, OMHSAS and the PCB will hold a CPS Certification update webinar on Tuesday, June 25, 2019 at 10:00 AM. Certified Peer Specialists, CPS Supervisors, provider agencies, BH-MCOs, County MH/ID offices, and all other stakeholders are invited to participate in this webinar.  Please register using this link.  After registering, you will receive a confirmation email containing information about joining the webinar.

Certified Peer Specialists Recognized with Full Certification Process

To more formally recognize the value of peers in the workforce, Pennsylvania is moving to a new full peer certification offered by the Pennsylvania Certification Board (PCB). This new formal certification will be necessary to provide Medicaid billable peer support services.

To make this transition as easy as possible for current Pennsylvania Peer Specialists, there will be a time-limited grandparenting process for those who wish to obtain the new full certification during the grandparenting period.

The grandparenting period ends August 31, 2019.

The requirements for the grandparenting process must be met but no additional exam will be required.

The requirements to become grandparented are:

  • You must have completed the two-week peer specialist training from one of the recognized training vendors. Those two vendors are the Institute for Recovery and Community Integration and RI Consulting.
  • Complete the CPS Grandparenting Application and sign and date a Peer-specific code of ethical conduct.
  • Signed and notarized release form.

There is no initial cost to peers for obtaining the credential as the grandparenting fee is being underwritten by the Commonwealth of Pennsylvania, Department of Human Services, Office of Mental Health and Substance Abuse Services (OMHSAS).

The new CPS certification will be valid for two years. To avoid a lapse in certification, recertification should occur before the end of the two-year certification period. Recertification requires obtaining 36 hours of CEUs every two years and a $50 two-year recertification fee.

This new formal certification through the PCB is designed to help strengthen the profession and give CPSs a stronger voice, while maintaining the essence of peer support in delivering recovery oriented services. We urge you to complete the process now, during the grandparenting period, to ensure you can continue to do the great work that you do.

REMEMBER: This new formal certification will be necessary to provide Medicaid billable peer support services.

The CPS Grandparenting Application can be found at this link.

Requests for paper applications and/or questions should be addressed to:
Mail: PCB, 298 S Progress Ave, Harrisburg, PA 17109
Phone: 717-540-4455
Email: info@pacertboard.org

The following organizations participated in the development of the new certification process:
Pennsylvania Peer Specialist Workgroup
Pennsylvania Department of Human Services, Office of Mental Health and Substance Abuse Services (OMHSAS)
Pennsylvania Mental Health Consumers’ Association (PMHCA)
Pennsylvania Peer Support Coalition (PaPSC)
Pennsylvania Certification Board (PCB)