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Tags Posts tagged with "ibhs"

ibhs

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In a presentation to the Medical Assistance Advisory Committee today, Office of Mental Health and Substance Abuse Services (OMHSAS) Deputy Secretary Jen Smith shared data that shows a significant increase over the past three years in behavioral health managed care organization (BH-MCO) decisions to deny services to their members or contracted providers.

In addition to denial data for calendar years 2022 through 2024, the report also provides data on grievances and complaints and defines what each of those is. Notably, the 2024 data does not include the fourth quarter of the year.

The most egregious service type denials are seen in two categories: 1) non-hospital residential withdrawal management, rehabilitation and halfway-house services for drug/alcohol abuse or substance use disorders; and 2) IBHS for children and adolescents with mental health or substance use disorders. Although the IBHS denials appear down slightly in 2024, when the fourth quarter data is added, the number is likely to increase. On the SUD side, even without fourth quarter data, denials for the non-hospital residential substance use disorder treatment services are up 45 percent over 2023.

The presentation breaks down the number of denials per year per BH-MCO since 2022.

The increases in denials in 2024 occurred at the same time OMHSAS acknowledged a significant miscalculation of capitation rates, resulting in underfunding of the behavioral health system, including primary contractors and BH-MCOs, by hundreds of millions of dollars.

Deputy Secretary Smith cautioned that there are multiple factors to consider when reviewing the data and increase in denials, including Pennsylvania’s SUD treatment system’s ongoing alignment with ASAM Criteria and the increased BH-MCO scrutiny on providers and individual BH-MCO interpretation of ASAM Criteria.

The full presentation is available here.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the Intensive Behavioral Health Services (IBHS) Regulatory Compliance Guide (RCG). This guide has been developed to provide clear explanations of the regulatory requirements of Title 55 Pa. Code, Chapter 5240, “Intensive Behavioral Health Services” regulations. It is meant to help agencies providing IBHS services, with the goal of ensuring safe and effective services to children, youth, and young adults through regulatory compliance as well as to help OMHSAS Licensing Representatives protect those served by these programs by conducting consistent and comprehensive inspections.

This guide is a companion piece to Title 55 Pa. Code Chapter 5240 regulations. It is intended to be a helpful reference for these regulations. The explanatory material contained in this guide in no way supplants the plain meaning and intent of the regulations set forth in 55 Pa. Code Chapter 5240.

The RCPA IBHS Steering Committee will be reviewing UBHS RCG and will provide further clarification to members in the near future.

Feedback or questions on the RCG can be sent to OMHSAS electronically.

If you have any questions or are interested in joining the RCPA IBHS Committee, please contact RCPA COO & Mental Health Policy Director Jim Sharp or RCPA Policy Associate Emma Sharp.

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The Pennsylvania Independent Regulatory Review Commission (IRRC) has completed their review of existing Intensive Behavioral Health Services (IBHS) regulations codified at 55PA. Code chapters 1155 and 5240, as requested by the RCPA IBHS Steering Committee.

The RCPA IBHS Regulatory Reform Recommendations, submitted on November 29, 2022, requested the commission to review the IBHS regulations under section 8.1 of the Regulatory Review Act, which provides that the commission may review any existing regulation which has been an effect for at least three years.

The commission has noted the burden placed on providers by the Department of Human Services regulation, but while they appreciated our concerns, the commission’s role is to determine whether existing regulations, as a whole, remain in the public interest. In the commission review letter, they determined that further action by the commission is not warranted in this matter.

We have been in contact with OMHSAS throughout this two-year period, and the commission provided the department with guidance as part of the review process. Despite the ruling from the IRRC, OMHSAS has agreed that they will reopen the IBHS for review as announced by OMHSAS Deputy Secretary Jennifer Smith at the RCPA Conference last week. RCPA will be reviewing the recommendations to calibrate those areas that continue to create barriers to access that have arisen since the recommendations created in the Fall of 2022.

If you have any questions, please contact RCPA COO and Policy Director Jim Sharp.

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Visualizing the Behavioral Health Workforce Crisis
February 22, 2024, 12:00 pm – 1:00 pm EST
Register Here
Featuring Charles Klinger, Chief Operating Officer, Behavioral Health Alliance of Rural PA (BHARP)

Charles has led a collaborative data project across 24 Pennsylvania counties. It paints a picture of a devastated workforce.

Agencies provide this data, and review it with government and managed care. It is being used to support recruitment and retention efforts.

Charles and his team are working together to find solutions to the BH workforce crisis.

Charles has led the Provider Workforce Staffing (PWS) report in response to the major changes in behavioral health staffing since 2020. Over 20% of available positions remain unfilled, signaling an increased divide between available workers and population need.

This report highlights the costs of adequately filling our network in a clear and comprehensive way. Average rate of pay for a multitude of mental health jobs have been reviewed in the PWS report, from psychiatrists to housekeepers.

Most BH staffing problems arise from lack of available workers. According to Charles’ research, workers are leaving jobs, and there are no candidates available to replace them. Many jobs have consistently remained vacant.

For those from Pennsylvania, the PWS is particularly illuminating, as it focuses on state-specific needs, like the loss of workers in every level from outpatient care, to intensive behavioral health services (IBHS).

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The Mental Health Planning Council, under the direction of the Office of Mental Health and Substance Abuse Services (OMHSAS), has extended the survey on delivering Intensive Behavioral Health Services (IBHS) until September 22, 2023. Agencies may access the provider survey directly and view the flyer for more details. Feedback will be de-identified and compiled by the Family Satisfaction Team of Montgomery County to be shared with relevant stakeholders and survey participants.

RCPA, on behalf of our members and those they serve, continues our efforts advocating for children, families, and practitioners delivering IBHS services. We respectfully ask our members to share this survey with families they are currently serving. The information will be utilized to examine challenges and opportunities in creating more viable pathways to IBHS services. Feel free to also share this information with other providers in your network of stakeholders.

If you have questions, please contact Clare Higgins or RCPA Policy Director Jim Sharp.

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Image by Dirk Wouters from Pixabay

The Mental Health Planning Council, under the direction of The Office of Mental Health and Substance Abuse Services (OMHSAS), is conducting a survey on delivering Intensive Behavioral Health Services (IBHS) and is requesting assistance in provider responses to the survey. Agencies may access the provider survey directly and view the flyer for more details. Feedback will be de-identified and compiled by the Family Satisfaction Team of Montgomery County to be shared with relevant stakeholders and survey participants.

Data collection for the survey will run from August 1, 2023 – August 31, 2023.

RCPA, on behalf of our members and those they serve, continues our efforts advocating for children, families, and practitioners delivering IBHS services. We respectfully ask our members to share this survey with families they are currently serving. The information will be utilized to examine challenges and opportunities in creating more viable pathways to IBHS services. Feel free to also share this information with other providers in your network of stakeholders.

If you have questions, please contact Clare Higgins or RCPA Policy Director Jim Sharp.

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Photo by Markus Winkler on Unsplash

The Pennsylvania Independent Regulatory Review Commission (IRRC) has approved RCPA’s request to review the RCPA IBHS Regulatory Review Recommendations within the context of the current IBHS regulations.

The premise of the recommendations addresses the challenges and barriers IBHS providers have faced in creating the staffing infrastructures and meeting the burdensome operational protocols for regulatory compliance. The overreaching nature of the regulations, coupled with the impact of the pandemic, has caused great strain on an already depleted behavioral health workforce. These system stressors limit the ability to provide vital, quality services to children and families. Due to the prohibition for the use of waiting lists, it is difficult to capture the true number of children and families going without these essential services. We contend there are thousands of children across the Commonwealth with unmet treatment needs and written orders for IBHS services who await care.

The current lack of access to care is a result of the workforce crisis and operational requirements of implementing the regulations. We feel these access issues and children waiting for services are compelling reasons, in the interest of the public, to merit a review of the regulations. We have also provided these recommendations to OMHSAS, the HealthChoices BHMCOs, and leadership in the Pennsylvania General Assembly.

RCPA extends its gratitude to our members and those who have supported this process as well as the IRRC for their review. There is no current timeframe for the review, as there are many other, similar regulatory review requests on the docket. With that said, we remain vigilant in our efforts and seek partnership and collaboration with all stakeholders to address the current crisis.

If you have any questions, please contact RCPA Mental Health Policy Director Jim Sharp.

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On behalf of the RCPA IBHS Providers and the children and families of Pennsylvania, RCPA has requested the Independent Regulatory Review Commission (IRRC) to reopen for review Regulation #14-546: Intensive Behavioral Health Services, based on section 8.1 of the Regulatory Review Act (71 P.S. § 745.8a).

The premise of our recommendations addresses the challenges and barriers IBHS providers have faced in creating the staffing infrastructures and meeting the burdensome operational protocols for regulatory compliance. The overreaching nature of the regulations, coupled with the impact of the pandemic, has caused great strain on an already depleted behavioral health workforce. These system stressors limit the ability to provide vital, quality services to children and families. Due to the prohibition for the use of waiting lists, it is difficult to capture the true number of children and families going without these essential services. We contend there are thousands of children across the Commonwealth with unmet treatment needs and written orders for IBHS services who await care.

The current lack of access to care is a result of the workforce crisis and operational requirements of implementing the regulations. We feel these access issues and children waiting for services are compelling reasons, in the interest of the public, to merit a review of the regulations.

The COVID-19 DHS regulatory flexibilities provided initial relief for providers, and OMHSAS continues to offer waivers to agencies experiencing critical staffing shortages. Providers are grateful for these temporary solutions; however, these waivers do not address the long-term impacts of the current regulatory requirements. Providers continue to struggle to hire qualified staff and contend with burdensome operational requirements, many of which negatively contribute to the efficiency of care delivery.

The expressed purpose of the IBHS regulations was to ensure access to quality care in a consistent and efficient manner. Conversely, the result has been a labyrinth of regulatory and operational interpretations, differentiated reimbursement for the same services, and a human services workforce crisis with no upcoming relief.

RCPA would like to thank the members of the RCPA IBHS Steering Committee for their commitment to conduct the review and the Commission for their willingness to consider this request. We believe these recommendations, if implemented, can address the barriers identified without compromising the original vision for high-quality services and broad access to care.

At last correspondence, the IRRC is in receipt of the recommendations. We will be providing a copy to the Office of Mental Health and Substance Abuse Services (OMHSAS), as requested by the Commission. We will continue to keep members apprised of the review process. If you have further questions, please contact RCPA Policy Director Jim Sharp.

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