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Public Comment

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The Office of Long-Term Living (OLTL) is sharing the message below from the Pennsylvania Department of Aging (PDA):

As part of Aging Our Way, PA, PDA is conducting an evaluation of the PA Link to inform the design of a strategic plan. The goal is to improve and redesign the program to better serve older adults, people with disabilities, and caregivers. The entire project was informed by extensive stakeholder engagement, including consultation of an advisory committee.

Please use the Public Comment Form to review the DRAFT Evaluation Report and DRAFT Recommendation report. You will then be able to upload your comments.

The public comment period will close on Monday, July 28, 2025, and all comments will be considered in the creation of the final strategic plan to refresh the PA Link.

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On July 2, the U.S. Department of Labor (DOL) took an important step to restore fairness and flexibility in the home care industry by issuing a proposed rule that would rescind restrictive provisions introduced in 2013 under the Obama administration. Those earlier changes, fully enforced in 2015, significantly narrowed the “companionship services” exemption under the Fair Labor Standards Act (FLSA), adding complex and costly wage requirements for home care agencies and Medicaid-funded services.

The 2013 rule redefined key terms, eliminated the exemption for third-party employers, and imposed overtime obligations on agency-employed direct care workers — contributing to increased costs and administrative burdens. These unintended consequences have strained both providers and public programs, particularly in Medicaid-funded home and community-based services (HCBS).

Now, DOL is proposing to correct course. In its justification, the Department noted that the previous regulations “might not reflect the best interpretation of the FLSA and might discourage essential companionship services by making these services more expensive.”

Why This Matters
This proposed rule is a welcome change for providers, participants, and state Medicaid leaders alike. Overtime costs are a major driver of financial pressure in long-term services and supports. When direct care workers live in the same home as the individuals they serve, current law allows participant-directed employers to avoid overtime pay. However, because of the 2013 changes, agency-employed workers doing the exact same job do not receive the same treatment — creating an inequitable and unsustainable two-tiered system.

If finalized, the proposed rule would allow third-party agency employers to once again access the same companionship exemption. This would create consistency across employer types and make it easier to recruit and retain direct care staff — particularly in shared living or live-in arrangements that are vital to participant independence and stability.

Act Now: Submit a Letter of Support
The DOL is accepting public comments on this proposed rule, and it is crucial that the provider community raise its voice. RCPA encourages home care agencies, managed care partners, and Medicaid stakeholders to submit letters of support highlighting how this change will:

  • Increase flexibility in service delivery;
  • Align federal and state wage policy;
  • Promote cost-effective care models;
  • Support direct care worker retention; and
  • Sustain vital programs that keep individuals in their homes.

Your voice matters. Together, we can ensure federal policy reflects the realities and needs of today’s home and community-based care system. View a sample letter for public comments here.

How to Submit Your Letter of Support
Visit the Regulations government website and search for the DOL proposed rule on companionship services. Comments must be submitted by July 31, 2025

If you have any questions, contact Fady Sahhar, RCPA PD&A Division Director.

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The Department of Labor (DOL) just announced its intent to publish a Notice of Proposed Rulemaking (NPRM) that would exempt certain types of home health workers from minimum wage and overtime requirements under the Fair Labor Standards Act (FLSA). In its reasoning, DOL said that the existing regulation “might discourage essential companionship services by making these services more expensive” and is proposing to exempt those employees from the minimum wage and overtime requirements of the FLSA. The proposed rule would also allow third party employers to claim those exemptions.

DOL will be accepting comments on their NPRM up to sixty days following its publication in the Federal Register, which is currently scheduled for July 2, 2025.

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The PA Department of Human Services (DHS) Office of Children, Youth and Families (OCYF) has issued a bulletin on the Draft Needs-Based Plan and Budget Guidelines for FY 2026/27. OCYF is seeking comment and feedback to be sent electronically by June 14. The subject of the email should state “Draft NBPB Comments.”

If your organization submits comments regarding this bulletin, please copy RCPA Policy Associate Emma Sharp on your responses. For members of the RCPA Children’s Residential Services Committee, please contact Emma Sharp for thoughts or guidance that will be included in the RCPA Bulletin Comments.

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The Office of Developmental Programs (ODP) is hosting a series of public comment webinars to provide an overview of how ODP proposes to implement Performance-Based Contracting (PBC) for Supports Coordination (SC) services, effective January 1, 2026. Additional proposed changes to the Consolidated, Person/Family Directed Support (P/FDS), and Community Living Waivers that are not related to Performance-Based Contracting will also be covered.

Preregistration is required. Registered participants will have the opportunity to provide verbal comments during the session. Each session will also be held for specific stakeholder groups.

The SCO meeting will be held May 6, 2025, at 1:00 pm – 2:30 pm. You can register here.

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The Office of Developmental Programs (ODP) has shared ODPANN 25-041, which informs all interested stakeholders of the opportunity to submit public comments on:

  • Performance-Based Contracting for Supports Coordination services scheduled to take effect January 1, 2026. This includes:
    • Proposed changes to the 1915(b)(4) waiver and Consolidated, Community Living, and P/FDS waivers related to Performance-Based Contracting;
    • Proposed Implementation Plan for Performance-Based Contracting for Supports Coordination;
    • Proposed rates effective July 1, 2026, for Supports Coordination Organizations that meet criteria for the Select tier; and
    • Proposed changes to the Targeted Support Management State Plan.
  • Additional waiver amendments (not related to Performance-Based Contracting) to the Consolidated, Community Living, and P/FDS waivers scheduled to take effect January 1, 2026.

The public comment period starts on April 19, 2025, and ends on May 26, 2025, at 11:59 pm for all proposed changes in this communication. Please view the announcement for additional information and details.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) is pleased to announce that the draft application for the Fiscal Year 2025 Projects for Assistance in Transition from Homelessness (PATH) grant is now available for public comments. The draft application has been posted for public review on the Mental Health in PA website.

The PATH grant is a non-competitive formula grant available to all states and territories by the Stewart B. McKinney Homeless Assistance Amendments Act of 1990. PATH programs serve individuals with serious mental illness experiencing or at imminent risk of homelessness. The PATH grant application is submitted to the federal agency Substance Abuse and Mental Health Services Administration (SAMHSA) annually.

Please note that this is the Pennsylvania application to SAMHSA. This is not a request for new PATH project proposals.

The PATH Application public comment period will remain open until 10:00 am Friday, March 21, 2025. If you have any questions or comments, please send them to Lauren MacWithey, Pennsylvania PATH Grant Coordinator, via email.

Please contact RCPA Policy Associate Emma Sharp with any additional questions.

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Earlier this month the Drug Enforcement Agency (DEA) issued a Notice of Proposed Rulemaking (NPRM) for Special Registrations for Telemedicine and Limited State Telemedicine Registrations. DEA is seeking public comment by March 18, 2025.

RCPA is considering whether it will submit comments. If you have comments about the proposed rule that you would like to make part of any RCPA response or if you would like to discuss the proposed rule, please contact RCPA SUD Treatment Services Policy Director Jason Snyder.

The NPRM introduces three types of Special Registrations for Telemedicine:

  1. A Telemedicine Prescribing Registration, authorizing qualified clinician practitioners to prescribe Schedule III-V controlled substances via telemedicine;
  2. An Advanced Telemedicine Prescribing Registration, authorizing qualified, specialized clinician practitioners (i.e., psychiatrists, hospice care physicians, physicians rendering treatment at long-term care facilities, and pediatricians for the prescribing of medications identified as the most addictive and prone to diversion to the illegal drug market) to prescribe Schedule II-V controlled substances via telemedicine; and
  3. A Telemedicine Platform Registration, authorizing covered online telemedicine platforms, in their capacity as platform practitioners, to dispense Schedule II-V controlled substances. To satisfy the statutory requirements, DEA would also require the special registrant to maintain a State Telemedicine Registration for every state in which a patient is treated by the special registrant, unless otherwise exempted. The State Telemedicine Registration would be issued by DEA, not the states, and operate as an ancillary credential, contingent on the Special Registration held by the special registrant.

Public comments are also requested on additional patient protections for the prescribing of Schedule II medications by telemedicine, including:

  • Whether the special registrant should be physically located in the same state as the patient being prescribed Schedule II medications;
  • Whether to limit Schedule II medications by telemedicine to medical practitioners whose practice is limited to less than 50 percent of prescriptions by telemedicine; and
  • The appropriate duration needed for the rules’ provisions to be enacted.

The special registration rule will also require the establishment of a national prescription drug monitoring program (PDMP) to help the health industry protect against abuse and the diversion of controlled substances into the illegal drug market. A national PDMP will provide pharmacists and medical practitioners with visibility of a patient’s prescribed medication history.

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The Substance Abuse and Mental Health Services Administration (SAMHSA) has released updated National Behavioral Health Crisis Care Guidance aimed at enhancing the nation’s response to mental health and substance use crises. This effort is part of an ongoing initiative to address record-high rates of suicide and overdose, while also building on the transition to the 988 Suicide & Crisis Lifeline in 2022.

The updated National Behavioral Health Crisis Care Guidance is comprised of three key documents. These are the 2025 National Guidelines for a Behavioral Health Coordinated System of Crisis Care, Model Definitions for Behavioral Health Emergency, Crisis, and Crisis-Related Services, and a draft Mobile Crisis Team Services Implementation Toolkit, which is open for public comment until March 21, 2025. Together, these resources set forth a framework for reshaping community crisis care systems and ensuring timely access to care.

SAMHSA’s framework is built on three foundational pillars essential to an integrated crisis care system:

  1. Someone to Contact — The 988 Lifeline and other hotlines provide immediate, accessible support for individuals in crisis.
  2. Someone to Respond — Mobile crisis teams are a critical component, delivering rapid, on-site assistance to de-escalate crises and connect people with appropriate care.
  3. A Safe Place for Help — Stabilization services offer facilities where individuals in crisis can access care, resolve crises, and transition to ongoing treatment when necessary.

The new guidance emphasizes scalability and sustainability for these systems, equipping state, tribal, local, and territorial governments with the tools needed to design and improve crisis care services. It also provides practitioners with actionable steps for delivering quality care.

The 988 Suicide & Crisis Lifeline, launched nationwide in 2022, represents a significant shift in behavioral health crisis response. The easy to remember three digit number aims to provide individuals with immediate access to trained crisis counselors, significantly reducing reliance on law enforcement and emergency departments for mental health emergencies. The updated guidance builds on this progress while addressing the urgent need for comprehensive crisis care systems.

The guidance reflects substantial input collected through listening sessions, expert consultations, and public feedback. Crucially, it underscores the importance of a coordinated, flexible, and compassionate approach to behavioral health crises at a time when the nation continues to grapple with increasing demand for services.

With public comments being sought on the draft Mobile Crisis Team Services Implementation Toolkit, SAMHSA aims to refine and finalize tools that advance the capacity of crisis teams to stabilize situations and connect individuals with long-term support. Please forward your comments to RCPA COO and Mental Health Services Director Jim Sharp for inclusion in the RCPA response to SAMHSA. This will addressed in the February 18, 2025, RCPA 988/Crisis Services meeting. You can register for the meeting here.

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