Drug & Alcohol

RCPA recently sent a letter to the Senate Banking and Insurance Committee supporting SB 1305. Sponsored by Senator Yaw, the bill would require insurance coverage for abuse deterrent opioids that is equal to coverage of other opioids, while prohibiting higher copays for pills that cannot be crushed or diluted.

Gov. Tom Wolf also supports similar requirements contained in SB 1305. The governor has called for a requirement that all of the state’s physicians check patients’ drug histories in a new database every time they prescribe controlled substances, including opioids. Several important pieces of legislation have passed the Senate, and await action in the House. Currently, there are a number of bills in both the House and Senate dealing with the opioid crisis.

RCPA has been working with various groups and supports SB 1305, because it reflects the collective expertise and resultant recommendations of the Joint State Government Commission Task Force and Advisory Committee on Opioid Prescription Drug Proliferation. RCPA encourages its members to contact your state senator and ask for their support of SB 1305.

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 Department of Human Services (DHS) is now implementing a new simplified process called the Elderly/Disabled Simplified Application Process (ESAP) for the Supplemental Nutrition Assistance Program (SNAP), commonly referred to as the food stamp program. The federally approved process simplifies the SNAP application and recertification process for older Pennsylvanians and individuals with a disability who have no earned income.

“The new simplified process will help ensure that some of the most vulnerable Pennsylvanians have easier access to the SNAP benefits that are critical to their health and well-being,” said DHS Secretary Ted Dallas. “Through enhanced data matches and other steps, the ESAP process helps these Pennsylvanians overcome barriers such as limited mobility and lack of access to the internet and helps realize the governor’s vision of a government that works.”

ESAP is available to households that meet all of the following criteria:

  • Every member in the household is at least 60 years old, has a disability, or both;
  • No member of the household has earned income; and
  • For SNAP eligibility, a household includes only individuals who live under one roof and who purchase and prepare meals together.

Through the use of data verification, DHS will be able to reduce the current application from 24 pages to a simplified two-page application. In addition to the simplified application process, ESAP households will now have a 36-month certification period, as opposed to the current 12-month recertification period.

“This initiative, part of Governor Wolf’s larger forthcoming statewide hunger plan, will increase SNAP participation by reducing barriers to participation and providing people with easier access to nutrition,” said Dallas.

“Hunger among seniors is a growing concern, and SNAP is a critical piece of the social safety net enabling older Pennsylvanians to access healthy and nutritious foods,” said Department of Aging Secretary Teresa Osborne. “DHS’ successful pursuit of a streamlined and simplified SNAP eligibility process will benefit seniors throughout the commonwealth, and highlights the positive results that occur when agencies work together to provide people with easier access to services and programs that have the capacity to improve their quality of life.”

On September 29, 2015, Governor Wolf brought together leaders from nonprofit anti-hunger organizations, the food industry, and government to discuss food security in Pennsylvania and signed Executive Order 2015-12, which created the Governor’s Food Security Partnership. To apply for SNAP using the ESAP form, visit the COMPASS web page. For more information on SNAP benefits visit the DHS website.

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.

Your feedback is greatly needed. The US Department of Labor (DOL) has issued its final overtime rule which increases the threshold related to the overtime exemption. This has caused great concern among RCPA members as there is no additional funding being proposed to cover the cost of this change. RCPA will be submitting testimony and testifying in front of the Senate Labor and Industry and Senate Appropriations Committees on Tuesday, June 21 regarding this issue. In preparation for this important Senate hearing, we are asking members to complete this SURVEY no later than Wednesday, June 15, so that we have data to present in addition to our concerns.

If you have already taken the survey, you do not need to provide feedback again. We appreciate your attention and input regarding this very important issue. Thank you.

Please contact RCPA Director of Government Affairs Jack Phillips with any questions.

The commencement of Certified Community Behavioral Health Clinics through Pennsylvania’s Department of Human Services, and the growing movement of individual providers to create medical homes to provide clients with co-located mental health and primary care providers in one facility, holds tremendous promise and opportunity for the coordination and enhancement of delivery of care to clients. These new provider relationships in shared office and facility spaces create new legal issues for providers under the federal Stark law and Anti-kickback statute. Providers must ensure that they do not inadvertently run afoul of these important federal fraud and abuse laws.

RCPA will offer a webinar presented by Renee H. Martin, JD, RN, MSN, a partner in the firm of Dilworth Paxson, LLP. This webinar will describe the legal requirements providers must be aware of under these federal laws and help to apply that knowledge in structuring financial relationships for use of these shared spaces. The webinar is intended for provider organizations’ executive staff, project planners, and legal counsel.

Stark Law and Integrated Health Care Webinar
Wednesday, June 29
12:00 – 1:00 pm
Register today

  • RCPA member registration is $25
  • Non-member registration is $40

Presenter: Ms. Martin exclusively practices health care law and advises both individual and institutional health care providers on regulatory and transactional matters. A significant portion of her practice centers on mental health and substance abuse law, including HIPAA, informational privacy, and fraud and abuse compliance. Ms. Martin has assisted in the formation of regional health information centers and mental health medical homes, working closely with federally qualified health centers and mental health providers.

RCPA will now distribute INFOS and ALERTS covering research, delivery and training models, policy issues, and other topics that will inform our members about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.