In early 2017, the Pennsylvania Department of Drug and Alcohol Programs (DDAP) announced the beginning of a major transition to the ASAM Criteria, a comprehensive set of guidelines governing the level of care most appropriate for patients and the services provided at those levels. Improved quality of care through outcome-oriented and results-based treatment was among the many changes this transition promised.
DDAP cited several reasons for the change, from ensuring the necessary federal Medicaid funding through an 1115 waiver to support the continuation of residential services, to the consistency that the most widely used system would bring to the Pennsylvania provider and payer world.
Today, the commonwealth’s addiction treatment system is little more than four months away from DDAP’s July 1 deadline for implementation, yet providers still have questions about the specifics of many of the changes taking place. Some of these changes go beyond ASAM Criteria, creating additional questions and confusion.
And as providers analyze the cost implications of the change, driven by increases in required treatment services, decreases in counselor-to-patient ratios, and requirements for more highly trained counselors, therapists, and doctors, it is becoming clear to them how significant those costs will be. With no plan from the commonwealth to increase reimbursement rates to cover these mandates and a funding environment in which reimbursement is already often inadequate in comparison to costs, providers are frustrated. Some have lamented the possible closure of facilities because of the exorbitant cost increases. Yet perhaps most troubling, at a time when the Covid pandemic is helping to drive overdose deaths to a level not seen since the peak of the opioid overdose death epidemic in 2017, these costs could limit patient access to care.
Despite these issues, RCPA drug and alcohol treatment provider members support efforts to increase quality in Pennsylvania’s addiction treatment system. They recognize the strength of the ASAM Criteria. But to put their full support behind ASAM, they need reimbursement increases to cover the costs and favorable resolution of the mandates that go beyond the ASAM Criteria in a way that seriously considers provider input.
RCPA enjoys and appreciates strong working relationships with DDAP, the Department of Human Services and its Office of Mental Health and Substance Abuse Services, county drug and alcohol administrators, and the commonwealth’s Medicaid managed care organizations. In the spirit of avoiding any unintended consequences and ensuring a quality system is available to continue to treat all Pennsylvanians in need of addiction treatment services at all levels of care, RCPA will continue to collaborate with these groups to highlight the issues and identify and work toward solutions, all the while bringing to bear its resources to effect these changes on behalf of its members.
The Intensive Behavioral Health Services (IBHS) regulations went into effect on January 17, 2021 after a one-year implementation period. Recently, the regulations have gone through some adaptations to address the clinical needs of children and families. One such change was the release of a bulletin outlining the approval to deliver 1:1 services for both ABA and Individual IBHS Services in a community or site-based setting, as well as the compatible billing codes.
These bulletins are both retroactive to January 17, 2021; the full bulletins can be found below.
As part of the ongoing IBHS implementation, the Office of Mental Health and Substance Abuse Services (OMHSAS) also released an updated IBHS Frequently Asked Questions (FAQ) Guide. This guide represents a composite of updated inquiries regarding the standards and will be updated as a companion piece to the implementation.
RCPA continues its efforts to support our members in the IBHS implementation through its IBHS Work Group, including work to create an equal billing platform for the delivery of individual services like its ABA counterpart. For more information on IBHS, please contact RCPA Children’s Policy Director Jim Sharp.
RCPA has teamed with Woods Services to further its strategic message and support of telehealth expansion and the building of a sustainable service platform. The project goal is to utilize information on the intersects of service delivery and payor dynamics, as well as the practitioner and client engagement data to support our efforts on the federal and state levels.
We are requesting that our members complete this brief telehealth survey to provide our first cut of the data that will go through analysis. Your agency’s individual responses will be confidential, and only aggregated information will be shared as part of the report. The survey will remain open for responses until February 22, 2021.
This survey has been expanded across the continuum of RCPA policy and human services, and we respectfully request that one survey be completed for each of those program areas in which you are providing telehealth. The data we collect will be instrumental in our efforts with the Department of Human Services (DHS), managed care organizations, and other critical decision makers to ensure that telehealth has a place in your continuum of care.
If you have questions regarding the survey, please call the principal investigator, Dr. Scott Spreat, at 215-801-2401. All other inquiries can be directed to RCPA Children’s Division Director Jim Sharp.
At the December RCPA Children’s Committee meeting, members were afforded the opportunity to participate in a guest presentation: Surviving Teletherapy and Adapting. The presentation was developed and delivered by Susan Brookman, MA, NCC, Assistant Director of Family Based Mental Health for the Allegheny Children’s Initiative. This training is designed to help front line staff and supervisors adapt their thinking and shift their skill set to this new normal of virtual interaction. The training will help participants to restructure, reconceptualize, and facilitate virtual sessions effectively.
Over the past year, both RCPA and OMHSAS have created surveys for practitioners and consumers to gauge the implementation pathways, challenges, and success for the use of telehealth. In June of 2020, RCPA released the RCPA Telehealth Survey Overview from more than 300 respondents. Likewise, OMHSAS performed a survey of more than 5,000 practitioners and consumers that focused on delivery demographics and satisfaction metrics as well; view the OMHSAS Telehealth Survey Report on the OMHSAS Telehealth web page. Each survey provided a springboard to the deeper dive into the impacts and benefits of telehealth and its expansion across our service communities.
As the Covid-19 pandemic persists, organizations continue to deliver services through a matrix of delivery options, including telehealth.
In a letter to United States governors, Acting Secretary of the Department of Health and Human Services (HHS) Norris Cochran announced their intention to keep the public health emergency (PHE) declaration throughout 2021. States will be provided with a 60-day notice before the declaration is terminated or expires, to allow stakeholders time to transition. Additionally, HHS has indicated that renewals will be announced every 90 days.
This action supports the Centers for Medicare and Medicaid Services (CMS) announcement that the current telehealth flexibilities currently in place would remain in effect for the calendar year in which the PHE ends. It is many of these flexibilities that have become the cornerstone of RCPA and Pennsylvania’s recommendation for creating a permanent platform for telehealth in the Commonwealth.
DHS created the Pennsylvania Telehealth Steering Committee in the Fall of 2020 to develop a set of recommendations by which this platform could be developed for implementation. The Steering Committee, led by OMHSAS and the Mercer Group, brought together stakeholders for the provider community, BH-MCOs, practitioners, families, and consumers as well as representatives from other DHS agencies. The recommendations were cast into five major telehealth areas:
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