Shapiro Administration Releases Behavioral Health Council Action Plan

The Shapiro administration has released its Behavioral Health Council Action Plan.

Nearly three years in the making since Governor Shapiro created the council by Executive Order in October 2023, the plan is wide-ranging and ambitious. It includes six overarching goals, supported by a total of more than 40 recommendations and more than 200 high-level action steps. Those six goals are:

1. Develop an Integrated Care System;
2. Expand Access to Services;
3. Strengthen the Workforce and Provider Support;
4. Enhance Accountability and Transparency;
5. Advance Equity in Behavioral Health; and
6. Improve Criminal Justice and Behavioral Health Integration.

The plan reflects recommendations developed through a series of meetings held by the Behavioral Health Council and its Advisory Committee. RCPA President and CEO Richard Edley is a member of the Advisory Committee.

According to the Action Plan, the Behavioral Health Council’s mission was to examine innovative care delivery models, assess workforce needs and funding sources, improve regulations and payment systems, and integrate mental health and SUD care with primary care while addressing health-related social needs.

Several of RCPA’s and its behavioral health provider members’ longstanding priorities are found in the plan, either as recommendations or high-level action items. In particular, Goal No. 3, “Strengthening the Workforce and Provider Support,” includes several action items aimed at streamlining audits, reducing administrative burden, and increasing Medicaid rates as a path to increasing workforce compensation. Some of those items include:

• Review all mental health and SUD treatment facility licensing regulations across DHS, DDAP, DOH, and DOS to identify duplicative or conflicting rules;
• Update statutes and regulations so that providers offering integrated services meet one coordinated set of standards (for example, allow a single survey or audit in place of separate audits for each program);
• Pursue specific statutory and regulatory and process improvements: create a single license for cooccurring disorder programs, align license renewal and inspection schedules across agencies;
• Coordinate with BH-MCOs to adopt standardized audit protocols so that providers are not audited separately by each MCO for similar quality measures;
• Evaluate the feasibility of establishing deemed status for providers that maintain current licensure in good standing and hold nationally recognized accreditation (such as CARF or Joint Commission), whereby accreditation satisfies quality audit requirements;
• Standardize core documentation requirements, including intake forms, treatment plan formats, authorization procedures, and billing protocols across all BH-MCOs and SCAs so that providers use one set of processes regardless of payer. Prohibit BH-MCOs and SCAs from unilaterally imposing new documentation requirements without a cost-impact assessment and adequate implementation lead time; and
• Increase workforce compensation: conduct a market analysis of behavioral health salaries in Pennsylvania relative to comparable health care roles and neighboring states and use that data to advocate for Medicaid rate increases targeted at services with the largest staffing shortfalls.

In addition, the plan also calls for expanded SUD and mental health service availability for people who are incarcerated, ensuring adequate behavioral health treatment during incarceration that supports successful re-entry and community-based recovery. It also includes appendices that visually represent current and conceptual systems of care (Appendix A) and a Pennsylvania Behavioral Health Funding Map (Appendix B).

Although the plan acknowledges funding, legislative action, and interagency coordination as three primary levers to implementation, it offers no specifics on those levers, nor does it provide a timeline or detail on how it gets accomplished.

Read the governor’s full press release on the Behavioral Health Action Plan.