Children's Services

A recent edition of the Pittsburgh Post-Gazette focused on the planning efforts by Highmark Insurance to assure health care parity and the economic and health care value of integrated health care.

The Post-Gazette article notes that “behavioral health care is still provided under a “separate and unequal” system, eight years after enactment of a federal law that meant to curb such disparity,” noted Patrick Kennedy in a meeting with a group of Pittsburgh-area health insurance caseworkers. “But that may start to change by fall when employer compliance monitoring is expected to begin for the Mental Health Parity and Addiction Equity Act,” the 49-year-old former Rhode Island congressman told about 20 case managers at Highmark Health. Mr. Kennedy was upbeat, saying a renaissance was at hand as employers and insurers learn about the cost-saving value of behavioral health coverage. “The business model isn’t there yet. This is going to take time,” he said. “Let’s find the value so it makes sense for insurance companies.”

In a related effort, the Pennsylvania Parity Coalition will be meeting this week with the Pennsylvania Insurance Department, to discuss the implementation and monitoring of commercial insurance plans as part of the federal parity requirements in the move toward integrated health care. RCPA, along with leading provider and consumer advocacy groups and representatives of ParityTrack, supported by the Kennedy Forum, make up the core leadership of the Pennsylvania Parity Coalition.

Research position or fellowship in suicide prevention research in schools

Leaders in mental health and suicide prevention research are working to implement a grant to study an evidence-based approach to youth suicide prevention. They are now looking for a project coordinator (masters or doctoral level preferred) and a research assistant (BA level) to run a large, school-based suicide prevention study with teachers in urban and suburban middle and high schools in Pennsylvania. This project will study a promising prevention model by recruiting 30 schools and training over 1,000 teachers.

The work of the research team will involve identifying schools, working with school personnel to plan the training, implementation of the assessment system, coordinating the training, and collecting pre-, post-, and follow-up quantitative and qualitative data. Both the project coordinator and research assistant are 18-month positions starting September 1. Interested individuals should send their resumes with cover letters to Guy Diamond, PhD and Matthew Wintersteen, PhD.

RCPA has played a long-standing role in the Pennsylvania Youth Suicide Prevention Initiative and works in collaboration with state and local organizations to reduce the risk and rate of youth suicide in communities across the Commonwealth.

Expands Medicaid funding for stays in private or state mental health and for addiction treatment facilities: loosens the “IMD exclusion” to allow states with 1115 Waivers to authorize Medicaid managed care (only) funds to pay for hospital stays in state or private psychiatric and addiction treatment facilities for up to 15 days per stay. States will have to apply to use this option and CMS will have to approve on a state-by-state basis. The bill originally authorized all Medicaid to pay for unlimited stays in those facilities, provided they didn’t show an average of 30-day stays.

HIPAA privacy protections: essentially makes no changes in the current statute. It allocates $10 million through 2022 to educate health care providers and families about the level of flexibility to disclose patient information within the current law. It does direct the federal Health and Human Services Agency in conjunction with the Office of Civil Rights to consider new regulations next year.

Court mandated outpatient treatment (termed AOT): allocates funding to pay for a provision that was approved last year by Congress to establish AOT pilots. It increases the amount and the years of those pilots. The original bill penalized states that didn’t use or expand AOT programs by reducing their federal block grant totals by 2%.

Protection and Advocacy Agencies: no essential changes here; the bill does repeat previously stated prohibitions against P&A groups to use their federal funds to lobby and establishes a grievance procedure for complaints. The original bill would have all but gutted these programs.

Federal Agency Changes: creates an assistant secretary for Mental Health and Substance Use Disorders within the Health and Human Services Department to oversee and coordinate federal behavioral health policy. It is “preferred” but not required that the assistant secretary be a psychiatrist, osteopath, or psychologist. This position will oversee SAMHSA and the Center for Mental Health Services (CMHS) activities, establish priorities, performance metrics, and standards for grant programs.

SAMHSA Block Grants: re-authorizes all existing programs and includes an emphasis that these existing and new programs should address the needs of those with the most advanced conditions.

Assertive Community Treatment: provides $5 million a year for 2018–2022 ($25 million total) to expand Assertive Community Treatment teams.

Peer Services Study and Education: the Comptroller General will study peer support in 10 states to identify possible ‘best-practices.’ It also authorizes grants to colleges of $10 million a year for 5 years ($50 million) to increase the behavioral health paraprofessional workforce, including peers.

Psychologist Education: there is $12 million a year for five years ($60 million) to train psychologists to work with those with more advanced conditions.

Crisis Intervention Training for Police: authorizes $9 million for 2018–2020 ($27 million) for CIT Training.

Same Day Treatment: allows Medicaid to reimburse for physical health and mental health services received within the same day.

Suicide Prevention: there is an adult suicide prevention allocation of $30 million a year ($150 million total) and another grant of $9 million a year for 2017–2021 ($45 million total) for suicide prevention for any age group. There is also $35 million a year ($175 million) allocated to youth suicide. Rep. Murphy disclosed yesterday about his own father’s suicide attempt.

Interdepartmental Serious Mental Illness Coordinating Committee: establishes a high-level cross-government committee to issue a report and recommendations to improve care.

Innovation Grants: provides two separate grants of $7 million each over three years ($21 million total); one for evaluating promising models that enhance prevention, diagnosis, treatment and recovery or to integrate health and mental health; and one to scale up evidence-based programs.

Bed Registry or Community Crisis Response Plan: allocates $5 million a year ($25 million total) for 2018–2022 for grants communities can apply for to create a crisis response plan (agreements between providers and criminal justice, etc.) or to create a registry of existing empty beds.

Parity: The bill calls for a GAO study on parity compliance.

The Office of Vocational Rehabilitation (OVR) is conducting a comprehensive statewide needs assessment designed to meet and satisfy the state plan requirements in the Rehabilitation Act of 1973, as amended, and the Workforce Innovation and Opportunity Act. As part of this assessment, the Institute on Disabilities at Temple University is asking Pennsylvania employers and workforce professionals to complete a brief survey to identify how OVR can better support employers and employees across Pennsylvania.

This project is being conducted in cooperation with the Pennsylvania Rehabilitation Council and with the assistance of the Institute on Disabilities. If you are an employer or a workforce professional you are encouraged to complete this brief survey by Monday, August 1. Once you’ve completed the survey, you can enter in a drawing to win a $20 Target gift card.

The Institute on Disabilities is also seeking employer stakeholders to participate in brief phone interviews and share their expertise with the Institute. Interested employers can email or call 215-204-9544.

Integration is a hot topic and buzzword in health care. And, integrated primary and behavioral health care is the best approach to care for people with complex health care needs. But do you have an elevator speech when someone asks you about integrated care? What do you tell new staff during orientation and how do you communicate the value to potential partners and your board of directors? Join this webinar to go back to the basics of primary and behavioral health care integration and learn how to effectively communicate the importance of integrated care and the benefits to the people you serve.

Last week Insurance Commissioner Teresa Miller reiterated to consumers that enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA) is a priority for her department. Miller also encouraged consumers to understand what benefits they are entitled to under the law and to file complaints with the Insurance Department if they believe they are not getting proper insurance coverage. “The Pennsylvania Insurance Department takes this law very seriously, and we will us our statutory authority to enforce parity requirements on plans over which we have jurisdiction,” said Commissioner Miller.

The MHPAEA of 2008 requires health insurance plans to contain the same level of coverage for mental health and substance use disorders as for medical or surgical care. This coverage includes quantitative limitations (copays, deductibles, and limits on inpatient or outpatient visits that are covered) and non-quantitative limitations (pre-authorizations, providers available through a plan’s network, and what a plan deems “medically necessary”).

One important step toward a well-integrated system of health care, both physical and behavioral, is full implementation of the letter and spirit of MHPAEA. RCPA is actively working with health care advocates as part of the state’s Parity Coalition to assure consumers and providers/practitioners that Medicaid, CHIP, and private health plan coverage include quantitative and non-quantitative parity.

For more information on the MHPAEA or to file a complaint or ask a question, visit the insurance department website or call 877-881-6388.

The Office of Mental Health and Substance Abuse Services (OMHSAS) has released a draft bulletin and related documents for review and comment. The purpose of the draft bulletin and related forms is to inform behavioral health managed care organizations and providers of the procedures for requesting Applied Behavioral Analysis (ABA) using Behavioral Specialist Consultant-Autism Spectrum Disorder (BSC-ASD) and Therapeutic Staff Support (TSS) services. The draft documents describe the minimum qualifications needed to provide ABA using BSC-ASD and TSS services, and the procedure code and modifier combinations that can be used to bill for services when such services are used by appropriately qualified individuals to provide ABA.

Confirmation of Knowledge and Skills to Provide Applied Behavioral Analysis

Attestation for BHRS Providers That Provide ABA Using BSC-ASD and TSS Services

This draft bulletin is being shared at this time for public comment.  Comments should be sent to OMHSAS by Friday, July 8.

RCPA has been contacted by providers having difficulty with the revalidation process. After contacting the Office of Medical Assistance Programs (OMAP), the following tips and pointers were offered to ease and speed up the revalidation process. After mailing 80,000 reminder letters, the 800 number for assistance was unable to be manned properly; this has been corrected and providers are urged to contact the state next week.

You must ensure that the provider has reviewed and included the items in the application that are on the provider checklist at the end of the application (such as social security card, provider license, corporation papers, etc.). Most of the applications are sent back because the provider did not send a copy of a license, social security card, or corporation’s papers, or they send W-9s when the instructions say not to.

Providers often do not send the additional requirements for that provider type or specialty. Each provider type has additional requirements to what is on the checklist at the end of the application. Many providers fill out the application and submit it – then OMAP must send it back because the provider did not review, understand, or submit the additional requirements. For example:

Additional Required Documents for Provider Type 08 (CLINIC):
The following documents and supporting information are required by the Bureau of Fee-For-Service Programs to enroll your facility as a provider:

  • Completed provider enrollment application;
  • Signed outpatient provider agreement;
  • Copy of document generated by the Federal IRS that shows both name and tax ID of entity applying for enrollment;
  • A copy of the corporation papers issued by the Department of State Corporation Bureau;
  • Completed “Ownership or Control Interest” form;
  • Peer support services addendum (for Specialty 076 only);
  • Out-of-state providers – proof of home state Medicaid participation;
  • A statement signed by the medical director (licensed physician enrolled with PA Medicaid) indicating their affiliation with the clinic;
  • A copy of the medical director’s license; and
  • The medical director’s 13-digit PROMISe provider number.

For Specialties 558 and 808 through 811, include the service description denoting approval by the Bureau of Children’s Behavioral Health Services, Office of Mental Health & Substance Abuse Services (OMHSAS). Contact the Bureau at 717-705-8289 for additional information or requirements.

Often applications are received where the address of the facility license does not match the address on the provider application for enrollment or revalidation.

Make sure that the ownership and disclosure forms disclose at least one managing agent or person in charge. Many come in with no information and are returned to the provider.

Here is a link to a Q and A document regarding the ownership and control section of the application that may be helpful.

Anything related to the Behavioral Health HealthChoices counties – Managed Care Organizations should be directed to OMHSAS. Likewise, they continue to remind the BH-MCOs, if the provider is a state plan provider, they should be instructed to contact the appropriate program office for clarification/assistance to assure providers are being given the correct information.

RCPA wants to know about your experience with revalidation in Pennsylvania. Members may email Sarah Eyster with information. RCPA will continue to work closely with the licensing bodies to ensure timely review of programs in need of revalidation.