A Response from the Bureau of Policy, Planning, and Program Development at DHS!
Today, I received the following response from Jill Stemple, Director of the Bureau of Policy, Planning, and Program Development at DHS. Jill shared the following information regarding how OMHSAS relates to county-specific BH-MCOs:
"Thanks for following up, Okichie. Our team has been working to gather some information from the HealthChoices BH-MCOs to understand their current policies for associate licenses. I’m happy to follow up when we’ve completed that analysis.
However, the short answer is that OMHSAS has no authority to require coverage of LAPCs in the HealthChoices Program. OMHSAS can only mandate that BH-MCOs are covering Medicaid State Plan Services. I’ve linked the Medicaid State Plan below for your reference. Individuals practitioners including LMFTs, LPC, LCSW and the related associate level licenses are not state plan services as individual practitioners or group practices. The PA Medicaid state plan does cover therapy services, but only under the umbrella of a licensed clinic, meaning those professionals have to work under a DHS/OMHSAS licensed Outpatient Psychiatric Clinic or a DDAP licensed D&A clinic to bill Medicaid FFS. Likewise, the BH-MCOs must cover licensed clinic service, including when they are provided by a range of licensed practitioners. Under managed care flexibilities, the BH-MCOs do have the option of reimbursing the services of individually licensed practitioners (either working in a solo practice or a group practice), but they are not required to do so and OMHSAS cannot require them to cover these services or to cover any particular license type.
Thanks, Jill
References: Medicaid State Plan: Medicaid State Plan | Department of Human Services | Commonwealth of Pennsylvania, attachment 3.1A/3.1B will be most helpful for the question you are raising.
Jill Stemple, MPPM
Director, Bureau of Policy, Planning, and Program Development"
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This news makes me very hopeful! Here's why: CBH has told many of us that they cannot credential LAPCs in group practice because their understanding is that the PA Medicaid state plan restricts them from doing so.
According to what OMHSAS has shared, no such restriction may actually exist!
To make absolutely certain, I have followed up with Jill regarding the practical implications of what she has shared, asking her to confirm the following:
- That there is currently no PA Medicaid state plan statute or regulation which restricts BH-MCOs from covering services rendered by associate clinicians (e.g. LSWs, LAPCs, LAMFTs) in private/group practice settings
- That so long as BH-MCOs cover all services outlined in the PA Medicaid state plan, BH-MCOs have individual authority/flexibility to designate which provider types they allow to render the services within their networks
- That a provider type does not have to be specifically identified in the language of the PA Medicaid state plan in order to be eligible to render services as individual providers under the plan
- Many PA BH-MCOs, including CBH, already credential LCSW, LPC, and LMFT providers in private/group practice settings, despite as Jill noted, these providers not being specifically identified as individual providers under the PA Medicaid state plan
- That BH-MCOs can similarly choose to cover services rendered by associate licensed clinicians (e.g. LSW, LAPC, LAMFT) in private/group practice settings without those provider types being specifically identified in the PA Medicaid state plan language, so long as these providers are in accordance with all other state regulations governing lawful practice
- CBH presently does with LSW providers, which is the same policy under which we are advocating for parity for LAPCs and other associate clinicians
- That BH-MCOs can cover services rendered by associate licensed clinicians (e.g. LSW, LAPC, LAMFT) in private/group practice settings without violating any existing PA Medicaid state plan statutes or regulations regarding which types of providers are eligible to render services
I have also asked Jill and her office at OMHSAS to issue a memorandum clarifying the flexibility on the part of BH-MCOs to designate their own eligible provider types and to reiterate the lack of restriction from OMHSAS and the PA Medicaid plan regarding credentialing associates. My hope is that such a memorandum from OMHSAS can push our advocacy to the next level.
At we continue to push towards our goal of obtaining 1000 signatures on this petition, we must continue to engage in other advocacy to further our goal. I have personally been pursuing this advocacy for two years. Your ongoing support pushes us ever closer to the goal. Please continue to share the petition, talk about this issue with your colleagues, and reach out to the relevant decision-makers.
Contact OMHSAS to let them know how important this issue is to Medicaid recipients of Pennsylvania!
- Jill Stemple, MPPM, Director of the Bureau of Policy, Planning, and Program Development
Contact CBH to demand they exercise their autonomy to allow LAPCs and other associates into the network!
- Mark Miller, MEd, LPC, Director of Credentialing
- Lisa Swyer, MMT, M Ed, Manager of Provider Contracting
Contact DBHIDS to make them aware of this critical missed opportunity to close the provider shortage gap!
- Kehinde ‘Kenny’ Solanke, MSW, LSW, DBHIDS Commissioner
- Amanda David, MSW, LSW, Deputy Commissioner - Behavioral Health Division
- Donna E.M. Bailey, MS, MBA, CEO - Division of Community Behavioral Health
We CAN make this happen!
Okichie