OMHSAS Responds to RCPA Inquiry on IBHS Training

Last week, the Office of Mental Health and Substance Abuse Services (OMHSAS) provided updated behavioral health technician/behavioral health technician-applied behavior analysis (BHT/BHT-ABA) training information based on changes to the Behavior Analyst Certification Board (BACB) implemented on January 1, 2026.

RCPA, on behalf of its members, expressed concerns to the Department that the bulletin implied that all current RBT’s would have to retake the 40 hours of training under the new 3rd edition. OMHSAS’s Children’s Bureau responded that this would not be the case and provided the following clarification below for RCPA members.

Dear RCPA,

Thank you for your outreach regarding the April 2nd letter OMHSAS issued to share information on the updated BACB training changes.

The purpose of this training clarification is to inform providers about the language changes between the BACB’s training curriculum and the Pennsylvania IBHS regulations, as well as to raise awareness of updates to current training standards.

Current BHTs and BHT‑ABA staff are not required to repeat the 40‑hour RBT course sequence due to these changes. Instead, annual staff training plans should incorporate the new content areas to ensure that all individuals delivering ABA services receive consistent training across the same domains of skill and service provision.

Staff whose qualifications rely primarily on training and coursework based on the RBT Task List — now the Test Content Outline — are the most affected by these updates. These individuals should work to obtain the additional content areas identified in the Test Content Outline, as described in the training letter.

RBTs certified by the BACB will continue to follow the Board’s established recertification and continuing education requirements.

These updates are not intended to create a financial burden for providers. Rather, they serve as guidance to ensure staff competencies remain current and aligned with best practices in Applied Behavior Analysis, supporting high‑quality service delivery across IBHS programs.

Finally, practitioners have an ethical obligation to maintain updated training that is aligned with their scope of practice so they remain knowledgeable about new developments in the field and continue to provide services that are current and relevant in the field.

If staff meet the regulatory requirements, they are in compliance, and their training plan should reflect any work needed to obtain new training.

We thank our IBHS Steering Committee for their leadership and guidance in the process. If you have any questions, please contact RCPA Policy Associate Emma Sharp.

< Previous Post

Next Post >

ODP Updates the MAAC on Paid Relative Caregiving & Travel Limitations

By Tim Sohosky • May 29, 2026

On Thursday, May 28, the Office of Developmental Programs (ODP) provided an update to the Medical Assistance Advisory Committee (MAAC) regarding current policies and upcoming regulatory changes following a recent Commonwealth Court decision. On February 17, 2026, the PA Commonwealth Court issued a decision in Dunkelberger v. Department of Human Services that determined that ODP’s limitations on provider model services (specifically the 40/60-hour caps and 90-day travel maximums) were null and void. The decision was based on process rather than policy validity; the Court found that these limitations were not properly promulgated as regulations in accordance with the Commonwealth Documents Law and Regulatory Review Act. To maintain a balanced approach between flexibility and oversight, ODP is moving forward with the following actions: Regulatory Amendments: ODP will amend regulations to establish formal authority for setting service delivery limits that support individual welfare and program integrity. Self-Directed Model Agreements: ODP has already modified agreements for self-directed models to clarify limits on overtime, combined relative service provision, and travel restrictions. Travel Restrictions: Due to the inability to monitor services effectively over long distances, service provision will now be limited to Pennsylvania and contiguous states. Waiver Changes: ODP will seek modifications through the amendment process to the Consolidated, P/FDS, Community Living, and Adult Autism Waivers to include: New requirements for agencies providing IHCS and Companion services to disclose a DSP's relationship to participants; and Strengthened programmatic oversight and integrity measures. Life Sharing Alternative: For participants requiring more than 60 hours of paid care from a relative, the Life Sharing (24/7) service model remains the recommended alternative. ODP anticipates a public comment period for these proposed waiver changes beginning in January 2027.

Two men with intellectual disabilities working happily on a tablet.

Shapiro Administration's Strategic Investments in ID/A Community Lead to Highest Number of Pennsylvanians Ever Served in HCBS

By Tim Sohosky • May 28, 2026

Press Release from DHS : Published May 27, 2026

ODP Provides Updates to PBC 2026/27 Residential Pay-for-Performance

By Cathy Barrick • May 28, 2026

The Office of Developmental Programs (ODP) has shared ODPANN 26-039 . The purpose of this communication is to provide updated details about the Residential Performance-Based Contracting (PBC) Pay-for-Performance (P4P) initiatives for Fiscal Year 2026/27. Updates are provided in red . Please review the announcement for more details. Visit here to access the Pay for Performance (P4P): Residential Rural Capacity Expansion Plan template .