OMHSAS Pa. Telehealth Bulletin Approved
Jim Sharp
RCPA Telehealth Position Statement
After 18 months of telehealth service implementation, the Rehabilitation and Community Providers Association (RCPA) has conducted provider telehealth satisfaction surveys, created a provider telehealth task force, and developed policy positions regarding the future of telehealth services. As the Wolf Administration, the Pennsylvania General Assembly, and the Department of Human Services seek to make telehealth services permanent, RCPA sets forth our telehealth service recommendations for implementation across the Commonwealth of Pennsylvania. RCPA has compiled the provider comments from these efforts and we believe the following recommendations represent a viable and successful pathway for practitioners and those in need of services.
We offer these recommendations to the provider community to share with stakeholders and legislators as we move forward with the expansion of telehealth services.
RCPA Strongly Recommends and Endorses the Following Telehealth Standards:
- The delivery of virtual services through telephone use only, absent video, should be permitted when the individual served lacks video capability or during an urgent medical situation.
- Payment for services delivered through telehealth should be paid at the same rate as a comparable, in-person encounter.
- Use of telehealth should be expanded to cover services provided by non-clinician mental health practitioners, including unlicensed master’s level therapists, mental health targeted case managers, and mental health certified peer support specialists.
- Use of telehealth should be expanded to include services provided in non-clinical settings.
- Documented verbal consent in the medical record should be acceptable for consent for treatment, verification and acknowledgement of treatment/service plans, release of information, and privacy (HIPAA) notices, in the event that a signature cannot be obtained from the individual served or their legal guardian.
- Given that telehealth use is deemed clinically appropriate, the preferences of the individual served and their caregivers should be given the highest priority when making determinations regarding service delivery method.
- Telehealth service delivery should be expanded to include drug and alcohol providers licensed by the Pennsylvania Department of Drug and Alcohol Programs, including but not limited to counselors, certified recovery specialists, case managers, physicians, physician assistants, nurse practitioners, and nurses for services reimbursed through the MA program.
- Translation services, including sign language interpretation, should be available for all telehealth encounters to ensure equitable access for all individuals.
- Dedicated funding for the expansion of broadband accessibility should be allocated to ensure access to critical services for all Pennsylvanians.
Contact RCPA Children’s Division Director Jim Sharp or your RCPA policy director with questions.
MHA Releases Student Mental Health Toolkit
CCBH Continues Provider APAs Through 12-31-21
The following is a notice provided by Community Care Behavioral Health (CCBH) regarding the future status of provider Alternative Pay Agreements/Arrangements (APA):
“Community Care, in collaboration with our Primary Contractors/county partners, has been closely monitoring service delivery volumes in order to assess the level of need to continue with the current Ambulatory Alternative Payment Arrangement (APA). In order to continue to support providers to ensure member access to essential behavioral health services, we collectively have determined the need to continue the current terms of the Ambulatory APA and are committed to doing so through December 31, 2021. Community Care and our Primary Contractors will continue to work with our contracted providers to prepare for the future and the eventual discontinuation of our APAs.
Please review your previous contract amendment. In lieu of an extension for additional one (1) month periods, this email serves as formal notification to extend the APA through December 31, 2021. The criterion for eligibility and the methodology for APA calculations will remain unchanged from the contract language. Please add this document to your previous contract exhibit listed below.
| APA | Exhibit |
| Ambulatory Services Advance Payment Arrangement | Exhibit P |
As noted in the contract amendment, Community Care will perform a reconciliation process for the payments providers receive under this agreement. The reconciliation process for 2021 will begin 90 days after the APA ends.
Providers have the option to opt-out of the APA payments by submitting notice to the following email address. Please use the subject line Opt Out – your organization’s name.
Continue to check our website (COVID-19 Information: HealthChoices Providers – Community Care (ccbh.com)) for other important COVID updates. If you have any questions, please contact your Community Care Provider Relations representative. A list of Provider Relations representatives and contact information may be found at Provider Representatives: HealthChoices Providers – Community Care (ccbh.com).”
RCPA is grateful for these efforts by CCBH for their continued support of providers during this time. If you have any questions, please contact your RCPA Policy Director.
The 29th Virtual Forensic Rights & Treatment Conference — Call for Presentations
The 29th Virtual Forensic Rights and Treatment Conference is scheduled for December 1–2, 2021.
At this time, Drexel University’s Behavioral Healthcare Education is now seeking presentation proposals for the conference. Applicants are invited to submit an abstract for a 60-minute workshop consisting of 50 minutes of presentation and 10 minutes for Q&A.
Presentation proposals are encouraged to illustrate this year’s theme: The Power of Opportunity – Creating Growth Through Effective Mental Health Supports.
To submit a proposal, please download this call for presentations document and fill in all information. Please note, the deadline to submit proposals is August 31, 2021. All proposals will be considered, but only a limited number can be selected. Notifications of proposal acceptance will be emailed September 27, 2021.
Please visit here for more details on the call for presentations. If you have further questions, please contact RCPA Policy Director Jim Sharp.
PCCD Announcement: Mental Health Initiative Funds, Crisis Intervention, and Pretrial Diversion
The Pennsylvania Commission on Crime and Delinquency (PCCD) and the Office of Justice Programs (OJP), in a collaboration with the Department of Human Services and Office of Mental Health and Substance Abuse Services (DHS/OMHSAS), announces the availability of $1,000,000 in funds for the implementation of crisis response or pretrial diversion strategies for justice-involved individuals with Mental Illness/Co-Occurring Substance Use Disorders (MI/COD), Intellectual Disorders (ID), and/or autism spectrum disorders.
RCPA is recommending that members connect with their county courts and agencies to gauge interest and potential service provision opportunities. View the memorandum for further details, and please contact your respective Mental Health/Drug & Alcohol/IDD RCPA Policy Director with any questions.
PA Telehealth Status Update
As announced last week, the COVID-19 pandemic-related Department of Human Services (DHS) Regulatory Suspensions are set to expire on September 30, 2021. RCPA has fielded numerous inquiries as to the ongoing status of telehealth and the implications to the pending end of the regulatory suspensions. The following is a review of this status.
PA Perspective
In February 2020, DHS and the Office of Mental Health and Substance Abuse Services (OMHSAS) released an updated Telehealth Bulletin in advance of the pandemic and updated it again in March 2020 with additional flexibilities and guidelines for the use of telehealth. That bulletin is separate and apart from the regulatory suspension standards with the exception of the following:
- The signatory responsibility for telehealth encounters;
- Audio/telephonic only telehealth for Outpatient Behavioral Health services; and
- Audio/telephonic only telehealth for Drug and Alcohol services.
There currently is no Pennsylvania State statute prohibiting the use of telehealth/telemedicine. However, the ending of the regulatory suspensions would specifically affect those three service operations mentioned above.
PA Telehealth Bulletin
Since June of 2020, a statewide Group of Stakeholders, including RCPA, has been engaged in the development of an updated PA DHS/OMHSAS Telehealth Bulletin. This group developed a set of recommendations for operating standards and practices for telehealth in PA.
In our ongoing work and partnership with OMHSAS, we expect the PA Telehealth Bulletin to be released in advance of the Regulatory Suspension end date of September 30, 2021. It is our further expectation that the bulletin will reflect the recommendations of the PA Telehealth Steering Committee and the many operating efficiencies and practices that have been implemented during the last 18 months, including a pathway for audio only communication allowances. This referenced bulletin will only be for OMHSAS-licensed agencies, and we have been informed that other DHS divisions will subsequently release their own telehealth guidelines.
PA Telehealth Legislation
Currently in the PA State House and Senate, there are also two compatible telehealth bills that have been drafted. RCPA has been working with the legislators on the impacts of House Bill 1573 and Senate Bill 705. The bills essentially address many of the current practices of telehealth, including audio-only, but many of the current flexibilities have not been adequately addressed. RCPA continues its work in both the House and Senate on language and practices that ensure parity, equity, and access should this legislation continue through its process.
Federal Telehealth
There are more than 100 telehealth-related bills that have been introduced in this 117th Congress, and many capture the needed flexibilities that ensure best practices and access to services for practitioners and consumers. The Center for Medicaid and Medicare Services (CMS) as well as the Office of Civil Rights and Compliance are reviewing these standards, including the use of audio/telephonic only telehealth delivery. RCPA continues to advocate through our State and Federal Legislators and the National Council of Wellbeing on any pending telehealth legislation.
If you have questions of feedback, please contact RCPA Children’s Director Jim Sharp or your RCPA Policy Director.
Pennsylvania Care Partnership & York County System of Care Forum Presentation — August 17
Black and Brown Mental Health vs. Criminal Justice & Policing
Tuesday, August 17, 2021, 6:00 pm–8:00 pm
Subject: Criminal Justice and Policing
Learning Objectives:
• Discuss the impact of Mental Health within the Criminal Justice System and Policing
• Discuss the current data as it relates to communities of color and these systems
• Learn what a community should know about how mental health needs are addressed within Criminal Justice and Policing
Handout: Black and Brown Mental Health vs Criminal Justice & Policing
Registration Link
For more information, contact System of Care Family Peer Support Specialist Lisa Kennedy. If you have further questions, please contact RCPA Policy Director Jim Sharp.
OMHSAS Adolescent Trauma Informed Care Survey
The Pennsylvania Department of Human Services’ Office of Mental Health and Substance Abuse Services (OMHSAS) invites individuals to participate in the Attitudes Towards Trauma-Informed Care (ARTIC) Survey.
Prospective participants are individuals who provide clinical direction or clinical supervision to staff who occasionally provide behavioral or mental health services to children ages 0 through 8 and their families. See the memorandum for details.
To register as a participant and/or to learn more about the benefits of participating in the ARTIC Survey Study and about the Cross-Sector Infant and Early Childhood Mental Health Services Collaborative, please review the memorandum, which contains 2 registration links: one for a brief online Question & Answer Webinar, which will be held on August 17, 2021, from 1:00 pm–2:00 pm, and the other for enrolling as a survey participant. Questions regarding the Webinar can be directed here.
Thank you in advance for your interest. We hope you can participate, and we look forward to hearing from you. If you have any further questions, please contact RCPA Children’s Director Jim Sharp.
OMHSAS Releases Updated IBHS FAQ/Guidance
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