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Tags Posts tagged with "Guidance"

Guidance

The purpose of this bulletin is to provide guidance on documentation needed to substantiate a claim as well as provide guidance on the service documentation processes. This information is applicable to providers and Supports Coordination Organizations (SCO) that render services through the Consolidated, Community Living, P/FDS, and Adult Autism Waivers as well as Targeted Support Management (TSM) and base-funded services.

Documentation to provide a record of services delivered to an individual must be prepared and kept by the provider, SCO, or common-law employer for the purposes of substantiating a claim and documenting service delivery. The Office of Developmental Programs (ODP) has developed Technical Guidance for Claim and Service Documentation for providers of services in the Adult Autism Waiver and providers of services for all other waivers and base-funded services, which provide specific information for providers and SCOs on the documentation that must be kept for each service in order to support a claim and to document service delivery. These apply to services rendered by providers and SCOs that have enrolled directly with ODP, organized health care delivery systems, and services delivered through both self-directed services models, Agency with Choice, and Vendor Fiscal/Employer Agent.

Providers are encouraged to review and consider using the Medical Assistance Provider Self Review Protocol to proactively identify and address any claim documentation-related problems. The protocol can be found here.

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The Department of Human Services (DHS) is pleased to announce new provider enrollment portal enhancements designed to improve a provider’s enrollment experience. Providers will enter the enrollment portal from PROMISe™ using their existing registered login criteria. Upon successful login, providers will have access to these new enhancements:

  1. Applications for adding additional service locations, revalidations, and reactivations will prepopulate parts of your application;
  2. After logging into the portal, existing providers will be able to submit change requests to update their provider file without the need to complete a full application; and
  3. Proof of provider enrollment status with PA Medicaid is available to view and print.

See the PROMISe Quick Tips update for more information. If you do not have an existing login, please select “Register Now” in the Provider Login box and complete the process options. Additional enhancements are planned and will be communicated through future banner alerts and quick tips.

If you have further questions, please contact RCPA Policy Director Jim Sharp.

The memorandum “Guidance Regarding Maintaining Confidentiality When Sharing Information With Schools” is being issued to advise County Children and Youth Agencies (CCYAs) about information sharing with Local Education Agencies (LEAs).

As of this date, CCYAs are advised to utilize the Placement Notification Form to notify LEAs of a student’s entry into foster care or change in foster care placement. CCYAs should NOT provide court orders, adoption decrees, resource parent stipend amounts, the name of a person who reported abuse or neglect of a child, the substance use history and treatment of a student (without a signed specific release form), or other information that is not relevant to the academic needs, safety, or well-being of the student. The information should only be disclosed to the individuals providing support to the child.

If you have any questions or concerns related to the education of children served by OCYF, please contact OCYF via email, contact the appropriate regional office, or contact RCPA Children’s Director Jim Sharp.

The sustained funding of community-based mental health services, such as community residential programs, family-based support, outpatient care, and crisis intervention, are critical to the wellbeing of our constituents and our communities. Funding levels for county mental health services have direct impacts on whether these important community and family supports will be available. Yet for too many years, state funding for mental health services has lagged far behind its needs. Counties find themselves advocating to prevent funds from being cut instead of achieving the increases that are needed to catch up from years of underfunding.

This year, RCPA and other system stakeholders have teamed with the County Commissioner Association of Pennsylvania (CCAP) through the Mental Health Safety Net Coalition. We join this campaign to bring awareness of the critical funding needs of mental health services for vulnerable Pennsylvanians. We ask our members, stakeholders, and partners to join us in this collaborative effort by engaging with your legislators. “County mental health services provide a critical piece to the public safety net for people in need,” notes Richard S. Edley, PhD, President and CEO of RCPA. “The system sustained cuts over a decade ago with little relief since then. It is time to restore those dollars and further enhance the system. Not only will it provide critical funding for the individuals receiving services, but there are positive benefits — both financially and clinically — to the entire community.”

The time to act is now for engaging with your representative, as local communities and providers have come together to sustain the safety net and serve those who need it most. The reality is that the demand for service far outweighs capacity and rate structures to serve this population. CCAP has created the following materials to assist in providing strategic talking points for our outreach:

If you have further thoughts or questions, please contact your RCPA Policy Director.

The Office of Long-Term Living (OLTL) has updated its guidance about payments to strengthen the home and community-based services (HCBS) workforce and assist Adult Day Service (ADS) providers. The updated Frequently Asked Questions (FAQ) document is available under the “Strengthening the Workforce” heading on the DHS Long-Term Care Providers page.

To maximize the use of federal funding under Section 9817 of the American Rescue Plan Act (ARPA) of 2021, OLTL has moved the date by which providers must spend “Strengthening the Workforce” and “Adult Day Services” funds from March 31, 2024, to October 1, 2023. This change allows sufficient time for providers to file an expenditure report and return unspent funds as applicable. OLTL will offer additional details about ARPA expenditure reporting in coming months.

Providers that have questions about this information should contact the OLTL Provider Helpline at 800-932-0939.

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DDAP Modifies ASAM Transition Web Page, Archives Addendums That Outlined IOP Ratio and Daily Therapeutic Hour “Expectations”

The Pennsylvania Department of Drug and Alcohol Programs (DDAP) has overhauled its ASAM Transition web page, removing previous references to “expectations for contractual compliance” in areas of ASAM Criteria where DDAP originally went beyond the Criteria as explicitly written. Newly revised information, including an updated “Guidance for the Application of The American Society of Addiction Medicine, 3rd Edition, 2013 in the Pennsylvania Substance Use Disorder Treatment System for Adults” and “ASAM Frequently Asked Questions” document, references the 1:15 intensive outpatient (IOP) counselor-to-patient ratio and the six to eight daily therapeutic hours at residential level of care as a DDAP “recommendation.”

The change is significant because, according to the Pennsylvania Department of Human Services (DHS) Office of Mental Health and Substance Abuses Services (OMHSAS), per its HealthChoices Behavioral Health Program Standards and Requirements for Primary Contractors document, “the Primary Contractor and its BHMCO must ensure that the SUD providers in the network comply with program standards in the ASAM Criteria, included but not limited to admission criteria, discharge criteria, interventions/types of services, hours of clinical care, and credentials of staff as set forth in the ASAM transition requirements found at https://www.ddap.pa.gov/Professionals/Pages/ASAM-Transition.aspx.” In other words, providers were expected to be in compliance with any information published as an expectation on that page.

For months following DDAP’s testimony in Commonwealth Court that the IOP and daily therapeutic overreaches were simply “guidelines,” the provider community remained unclear on whether they would be required to comply with the “guidelines” as part of their contracts with the BHMCOs. Still, providers have not yet seen the evaluation tool that will be used to audit their compliance with ASAM Criteria despite DDAP’s expectation that they be “substantially aligned” with those Criteria by Jan. 1, 2022.

ODP Announcement 22-010 announces that the Operational Guide for Appendix K has been updated to align with current guidance from the Centers for Disease Control and Prevention (CDC), the Centers for Medicare and Medicaid Services (CMS), and the Pennsylvania Department of Health (DOH).

Additionally, guidance has been added regarding regulatory compliance during the COVID-19 pandemic. The purpose of the Operational Guide is to provide guidance to Providers (including services rendered under a participant-directed services model), Supports Coordination Organizations, Administrative Entities, and the Office of Developmental Programs (ODP) to ensure adherence with current state and federal guidance.

The Operational Guide applies only to participants impacted by COVID-19. Examples of participants impacted by COVID-19 include participants impacted due to staffing shortages, a COVID-19 diagnosis for the participant or a participant’s housemate or caregiver, and closures of service locations (residential homes, Community Participation Support service locations, etc.). For any requirement not listed in the Operational Guide, refer to the current approved ODP waivers.

ODP is finalizing Version 3 of the Operational Guide for the Adult Autism Waiver and will publish it soon.