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Authors Posts by Jim Sharp

Jim Sharp

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RCPA is pleased to report several successful collaborative efforts this week, including a meeting with DHS, OMHSAS, and a delegation of House and Senate Representatives. We reviewed proposed language for a new bill that would address the 4 walls standard for ongoing telehealth with practitioners not within the 4 walls of a clinic. The bill will also include language previously introduced on the Psychiatric Outpatient Regulatory requirements for the 50% in-office time for clinics and the use of advanced practice professionals to meet those time requirements.

The language for both target areas was approved by all parties and will now move on to the House Human Services Committee. RCPA has a meeting scheduled for early next week to review the finalized version prior to its introduction. We have also met with Senate counterparts to support the measure.

Lastly, RCPA continues its dialogue with OMHSAS for guidance and clarification, including sharing members’ and stakeholders’ feedback. We have had the opportunity to speak with our BH-MCO members and understand OMHSAS Deputy Secretary Jen Smith will be meeting with that group and the county contractors on the processes moving forward.

We are hopeful for an expedited legislative solution that will aid OMHSAS in making any resulting policy, practice, or program changes that will support the initiative. We are extremely encouraged by the system’s efforts and focus this week and will continue to provide key updates to members and stakeholders.

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

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During this week’s budget presentation by Governor Shapiro, funding for mental health services was addressed as a priority for vulnerable Pennsylvanians. RCPA is working to review the preliminary funding recommendations listed below, and we hope to have greater line-item insight from DHS Secretary Arkoosh’s address this Friday.

Please note that registration is now open for the DHS 2024/25 Budget Briefing. You can register to view the briefing here. Additionally, the DHS House and Senate Budget Hearings will be March 5 and 6, 2024, respectively, and RCPA has been asked to provide questions for the testimony. The DHS budget book is available here.

Lastly, as part of our RCPA Mental Health Steering Committees and Work Groups, we will review recommendations as we develop our strategic budget advocacy campaign over the next several months in our meetings with stakeholders and legislators.

We offer the following as the initial review of yesterday’s budget presentation:

2024/25 Budget: Mental Health Program Recommendations:
This budget recommends the following changes: (Dollar Amounts in Thousands) for Mental Health Services

  • $20,000 — To replace nonrecurring prior-year carryover funding.
  • $5,750 — Initiative to expand diversion and discharge for individuals with mental illness currently in the criminal justice system.
  • $18,259 — To continue current programs.
  • $20,000 — To restore one-third of base funding to counties.
  • $3,443 — To replace federal funding received in 2023/24.
  • $5,000 — Initiative to maintain walk-in mental health crisis for COVID-19 response stabilization centers serving multiple counties.
  • $1,250 — To annualize prior-year expansion of home and community-based services.
  • $1,600 — Initiative to provide home and community-based services for 20 individuals currently residing in state hospitals.
  • $305 — To annualize prior-year expansion of diversion state hospitals and discharge programs.
  • $10,000 — Initiative to provide support to the 988 network for mental health services.
  • $85,607 — To increase appropriations.

School-Based Mental Health
This year, the Shapiro Administration looks once more to address the needs of student mental health with a $100 million investment. This new set of funds comes on the heels of $90 million recently allocated to schools, with monies originally set aside for adult mental health services targeted through the now defunct 2022 Behavioral Health Commission.

The funding mechanism for the distribution of these funds has yet to be determined if it is approved by the General Assembly. The last two rounds of school-based mental health funding have been allocated to individual districts through noncompetitive grants. The concerns have been that the funds, if not earmarked for the development of service delivery pathways, will go to building staff infrastructure in the form of social workers. While there are advantages to having these professionals in the buildings, they alone cannot address the student needs for assessment and treatment services

RCPA supports the funding being designated through the schools but will work with legislators to encourage developing a coordinated system of care coupled with a longer-term financial strategy with the schools, community-based providers, Student Assistant Programs (SAP), and county involvement in SAP coordination.

Early Intervention Services
As part of our initial budget discussions with OCDEL, we were concerned that there would not be an interim rate increase for 2024/25 as we work through the new Early Intervention rate methodology. We see in the budget that there is an increase of $16 million, nearly 9% over last year’s number. It is also projected that more children and families will be served in this coming year, and we will work with the administration to, at a minimum, continue to fund the ARPA-supported 3% increase from over the last three years.

County Child Welfare
It is projected that the County Child Welfare budget will essentially be flat, with less than a 1% increase. As the child welfare systems await the DHS Blueprint recommendations on addressing the extensive number of services for youth with complex care, especially those in congregate care, it was surprising there was not a designated funding allocation to support this initiative. This remains a priority to fund these programs.

County-Based Mental Health Funding
It was disappointing that the Shapiro Administration failed to deliver on last year’s “down payment” of the 2022/23 allocation of $20 million towards the county base. Up until last year, the county-based mental health system has gone more than a decade without a base rate increase. Last year’s $20 million represented only a 3% increase over the 2022/23 base funding. This year’s $20 million will equate to less.

We will continue, as part of our advocacy strategy, to support an allocation that is projected to be in the neighborhood of $1.2 billion to create a sustainable platform for county-based mental health service delivery.

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RCPA is pleased to report that there has been significant progress as stakeholders work together in developing solutions for expanded telehealth flexibility. RCPA has met with members of the General Assembly, OMHSAS, the Governor’s office, the National Council on Mental Wellbeing; as well as other member associations and providers; all committed to a collaborative effort to address the continuation of the telehealth service deliverables as outlined in our PA tele-behavioral health bulletin.

Next week, the principals will meet to review the legislative pathways and bill specifics in addressing the current 4 walls requirements. It has been determined the vehicle to this will be to amend our current draft legislation that initially was created to address the psychiatrist in office time requirement.

We have spoken at length with our partners at the National Council for Mental Wellbeing, and they have provided an insightful overview of this from a federal lens; including the fact that Pennsylvania is only one of more than 15 states working with CMS and their legislature to meet the systems needs of their Medicaid population. The National Council also reported that the legislative process is the pathway most supported at the federal level to address the matter.

We are hopeful for an expedited legislative solution that will support OMHSAS in making any resulting policy, practice, or programmatic changes that will support the initiative. We are extremely encouraged by the system’s efforts and focus this week, and the developing short-term plan. RCPA continues, as recommended earlier in the week, for providers to be patient, review your contingency plans, and focus your primary efforts on servicing those entrusted to your care.

RCPA will continue to partner with all members and stakeholders and provide updates as we proceed.

If you have questions, please contact RCPA Policy Director Jim Sharp. The next RCPA Telehealth Operations Committee meeting will be rescheduled for earlier in February and we will be sending that information out early next week. Please share this information with your stakeholder networks.

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Photo by Glenn Carstens-Peters on Unsplash

The Office of Child Development and Early Learning (OCDEL) has announced the successful migration of data from the old registry site to the new Infant/Toddler Early Intervention Provider Registry website. All users can now log in to the new site and access all of their information. Users will still be able to log into the old site for any Early Childhood Education related activities but will now use the new site for all Early Intervention related tasks.

Please update your bookmarks with the new link. If you encounter any issues or have questions, please utilize the “Contact Us” button on the site or email directly. For all other Early Intervention related questions, please contact RCPA Policy Director Jim Sharp.

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Photo by Markus Winkler on Unsplash

In response to the recent developments on the delivery of telehealth services and its intersection with Federal Medicaid payment standards outlined in the “4 walls” requirements, RCPA has widened its efforts in addressing the barriers currently in place. It has been determined that the most effective route to address this would be through legislation. The necessary changes cannot be achieved through a revised Tele-Behavioral Health Bulletin.

RCPA has been working with a bipartisan team of legislators on an updated version of Act 76 to address our limited access to psychiatric services through utilization of our advanced practice professionals. We are working with the Office of Mental Health and Substance Abuse Services (OMHSAS), our stakeholders, and the legislative committees to introduce a bill that would address both the psychiatric office time and the “4 walls” service delivery barriers.

Our members’ feedback over the last few days and during the OMHSAS telehealth forum on Monday has provided an invaluable backdrop to our efforts. RCPA is focused on working with our legislators and stakeholders to introduce this bill, and we will look to our members for support with these efforts. Additionally, we continue our daily efforts with our partners at OMHSAS, who are jointly committed to creating this viable and sustainable effort to preserve Medicaid service access to those most vulnerable in our Commonwealth.

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

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RCPA attended the Office of Mental Health and Substance Abuse Services (OMHSAS) telehealth webinar on Monday, January 29, alongside many provider members, regarding the Federal payment conditions related to the delivery of telehealth services and the requirement that the physicians or clinicians must present in the office, or that the client must be in the office during the telehealth session, to meet the guideline. It was explained that despite the standards outlined in the current OMHSAS Telebehavioral Health Bulletin, under the Federal “4 walls” statute, this is a required Federal Medicaid payment condition. These requirements cannot be waived.

The purpose of today’s call was twofold: explaining the “4 walls” requirements, and for providers to give vital feedback to OMHSAS on the impacts, challenges, and barriers to accessing services that this may create for consumers and families. This Medicaid standard remains in effect, and RCPA recommends provider members review their operating practices to ensure compliance.

During this time, RCPA will continue its efforts and work with OMHSAS, the HealthChoices partners, and stakeholders to ensure access to services via telehealth. You can review today’s OMHSAS telehealth webinar slide deck. We are also looking to obtain a recording of the webinar to share with our members.

If you have questions, please contact RCPA Policy Director Jim Sharp. The next RCPA Telehealth Operations Committee meeting is scheduled for Tuesday, February 27; however, we will be reviewing if we need to meet sooner based on current information.

Please share this information with your stakeholder networks.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) is holding a series of virtual conversations on Monday, January 29, to discuss opportunities in modernizing tele-behavioral health services within the Commonwealth. These meetings will be held using Microsoft Teams, and time will be allotted for discussion. To facilitate discussions most efficiently, OMHSAS will hold three meetings based on stakeholder type: BH-MCO/Primary Contractor/County Mental Health Administrators, licensed service providers, and individuals who access services and their families. Please choose the most appropriate webinar for you. The licensed service providers forum will be at 11:00 am. Attendance will be taken so that feedback can be cataloged accordingly.

These conversations will drive OMHSAS closer to finding solutions to the complicated work of increasing access to behavioral health services that are utilizing tele-behavioral health platforms and ensuring service recipients have a choice. This first conversation will focus on psychiatric outpatient clinic services and telehealth.

Join on your computer, mobile app or room device
Visit here to join the meeting
Meeting ID: 290 432 891 13
Passcode: 6nz9cp
Download Teams | Join on the web
Or call in (audio only)
+1 267-332-8737,,985858579#   United States, Philadelphia
Phone Conference ID: 985 858 579#

OMHSAS looks forward to you joining this critical conversation. If you have questions, please contact RCPA Policy Director Jim Sharp.

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