Jim Sharp • November 13, 2025

PA Passes Legislation for Telehealth “4 Walls” Compliance

Author

Jim Sharp

Date

November 13, 2025

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With the signing of the Human Services Code Bill by Governor Shapiro, the final hurdle in meeting the compliance requirements of the Federal “4 Walls” Telehealth Standards has been cleared.

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.

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

By Cathy Barrick • May 28, 2026
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