The legislation addressed the outlying PA Medicaid payment requirements for delivering and receiving mental health or substance abuse treatment services outside the four physical walls of a clinic. The legislative pathway was paved with the passing of HB1590 in the spring and its movement over to the Senate Health & Human Services Committee, where it eventually made its way to the Human Services Code Bill.
This summer, the Centers for Medicare and Medicaid Services (CMS) approved the Office of Mental Health and Substance Abuse Services (OMHSAS) State Plan Amendment, which addresses the operational practice considerations for the “4 Walls” requirements. The abrogation of the following completes all required federal compliance requirements:
Section 443.16. Abrogation of Regulatory Requirements for Payment for Outpatient Behavioral Health Facilities abrogates sections 1153.14(6) and 1223.14(11) from 55 Pa. Code to the extent that they limit medical assistance payments only for behavioral health services provided within the physical confines of a behavioral health clinic facility.
As reported earlier by OMHSAS, the next step in the process will be the distribution of a “Telehealth 4 Walls Bulletin” that will address the specifics, though there is no current timeframe for its release.
RCPA would like to thank OMHSAS for its partnership in this two-year process as well as our members and legislators for their advocacy and support. If you have any questions, please contact RCPA COO and Mental Health Policy Director
Jim Sharp.
