1. Section A: Statement of Need (15 points) Describe how behavioral health services are
organized, funded, and provided in the state.
The Commonwealth of Pennsylvania has a state supervised, county administered system of
community behavioral health (BH) services, with county government having the primary
responsibility for the provision of mental health and substance use services. The Mental Health
and Mental Retardation (MH/MR) Act of 1966 requires county governments to provide
community mental health services, including short-term inpatient treatment, partial
hospitalization, outpatient care, emergency services, specialized rehabilitation training,
vocational rehabilitation, and residential arrangements. In addition, Single County Authorities
(SCAs) are responsible for county-wide assessment, planning, implementation, and evaluation of
prevention and treatment services for individuals with substance use disorders (SUDs).
In addition to the county-operated community BH system, Pennsylvania operates a state mental
hospital system. The primary purpose of the state hospital system is to ensure state-of-the art
inpatient treatment to persons committed under the Mental Health Procedures Act to state mental
hospitals. The goal is to ensure that the men and women who come to the state hospitals develop
the skills, resources, and supports needed for recovery and successful return to the community.
There are six state hospitals (with a capacity of 1,341 beds) and one long-term nursing care
facility (with a capacity of 159). Nearly 50 percent of all consumers have a length of stay less
than two years. Nearly 50 percent of all individuals admitted to a state mental hospital have a cooccurring SUD. Over the past 10 years, a concerted effort to reduce reliance on the state mental
hospitals has allowed over 1,500 individuals to return to their lives in the community and many
more to be served by moving commonwealth hospital funds to treatment and recovery-oriented
support services in the community.
Funding for community BH services is provided through a mixture of commonwealth funds and
Medicaid dollars. Services are delivered through a system of BH Managed Care Organizations
(BH-MCOs) working collaboratively with counties and a system of private provider agencies.
Implemented in 1997, the HealthChoices BH (HC-BH) program is the Commonwealth of
Pennsylvania’s Medicaid managed care program for BH services. The HC-BH program is
operated by the Pennsylvania Department of Human Services (DHS), Office of Mental Health
and Substance Abuse Services (OMHSAS). Medicaid-eligible individuals have a choice of
managed care plans for medical coverage and are enrolled in a separate managed care BH plan
based on the county in which they reside. There are thirty-four HC-BH contracts with five BHMCOs providing services for the HC-BH program.
HC-BH was conceived and developed with the vision of increasing access to services, improving
quality of care, and containing costs. Since the program’s inception, DHS has been committed to
evolving the HC-BH program beyond this original vision to also achieve system transformation
according to the following goals:
o The children’s BH system will be family-driven and youth-guided.
o BH services and policies in the adult system will be grounded in recovery and resiliency
principles.
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o BH services and supports will recognize and accommodate the unique needs of older
adults.
2. Describe the prevalence rates of adults and children with mental illness and/or
substance use disorders in the state and particularly in the areas of the state being
considered for CCBHC’s. Include sub-populations such as adults with serious mental
illness and children with serious emotional disturbances, and those with long term and
serious substance use disorders and populations experiencing behavioral health
disparities.
Prevalence rates in Pennsylvania are similar to national rates, with unique features based on
geography and ethnic/racial characteristics. Pennsylvania is a mix of urban and rural areas.
Approximately 63 percent of Pennsylvanians live in urban or suburban areas while 3.4 million
residents, or 27 percent of the state’s population, live in rural areas. Forty-eight of the state’s 67
counties are considered rural; only Delaware and Philadelphia counties have no rural populations
(Medicaid Expansion: A Benefit for Rural Pennsylvania, January 2013, Pennsylvania Health
Law Project & Pennsylvania Office of Rural Health).
Several issues have been identified that affect the delivery of BH services to Pennsylvania’s rural
population, including shortages of trained and credentialed treatment professionals, insufficient
transportation systems, inadequately developed continuums of care, lack of knowledge on how to
access treatment, and the stigma associated with having a mental illness, especially in small
communities. (Pennsylvania Rural Health Care, August 2010, Pennsylvania Rural Health
Association).
SUDs are major problems confronting all of Pennsylvania. About 314,000 individuals aged 12
or older, or 2.9 percent) per year in 2009-2013 were dependent on or abused illicit drugs. In
Pennsylvania, about 713,000 individuals aged 12 and older per year in 2009-2013 were
dependent on or abused alcohol. This represents 6.7 percent of all individuals in this age group.
(SAMHSA Behavioral Health Barometer Pennsylvania, 2014). Dependence or abuse of alcohol
was more prevalent in the western part of the commonwealth including Allegheny County and
the more rural western counties. Illicit drug dependence or abuse had similar results with higher
reported rates in western Pennsylvania. (National Survey on Drug Use and Health (NSDUH),
2014).
A large proportion of health care resources in the United States are consumed by a relatively
small number of individuals. The term ‘super-utilizer’ describes people who make frequent trips
to hospital emergency rooms or have repeated inpatient hospital stays. In Pennsylvania, superutilizers were identified as those with five or more admissions to a general acute care hospital for
fiscal year 2013-2014. This population represented 3 percent of hospitalized patients, 11 percent
of hospital admissions and 14 percent of all hospital stays. The top reasons super-utilizers were
admitted included heart failure, septicemia, and mental health disorders. (Top Reasons for
Admission among Super-Utilizers in FY 2014, by PA County, Pennsylvania Health Care Cost
Containment Council, 2014).
Suicide prevention remains a high priority both nationally and in Pennsylvania. In the
Commonwealth about 74,000 youths (7.9 percent of all youths) per year in 2008-2012 had at
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least one Major Depressive Episode (MDE) within the year prior to being surveyed. About
30,000 youths with MDE (40.4 percent of all youths with MDE) per year in 2008-2012 received
treatment for their depression within the year prior to being surveyed. In 2012 there were a total
of 1,613 completed suicides, which is a rate of 12.1 per 100,000. The 45-49 age group had the
highest rate of 21.1, while the 15-19 age group had a rate of 6.7. The Pennsylvania Department
of Health (PA DOH) and DHS are focused on reducing the suicide rate. Improving access to
quality care that is integrated to treat the whole person will aide in this endeavor. CCBHC’s will
help move Pennsylvania in that direction.
The incarceration of individuals with mental illness has become a rallying point for much of the
country. In Pennsylvania, the General Assembly held mental health hearings to examine the
issue. The Pennsylvania Department of Corrections indicates that approximately 8 percent of
their inmates have serious mental illness (SMI). Data from the county jails varies from 8 percent
to over 50 percent; however, the data is largely reflective of self-reporting and may not be
accurate. DHS believes that CCBHCs, through case management addressing social determinants,
and Medicaid expansion, can have an impact on reducing incarceration and re-incarceration of
individuals with mental illness and SUDs.
Pennsylvania ranks fourth among states with the highest veteran population and the number of
Selected Reserve Members. (Demographics Report, Profile of the Military Community,
Department of Defense (DOD), 2012). Pennsylvania is also home to eight Veterans Hospitals
and forty-four Veterans Administration (VA) clinics.
According to statistics from SAMHSA, among adults aged 18 or older, the national rate of SMI
from 2012-2013 was 4.1 percent. In Pennsylvania the rate was 4.0 percent, about the same as the
national average. The percentages of persons with SMI 18 or older ranged from a rate of 5.39
percent in Erie and surrounding counties to 3.15-3.46 percent in the southeast counties of the
commonwealth. The number of children with serious emotional disturbance served in
community outpatient programs in fiscal year 2013-14 was 148,158.
The 2012 population estimates for Pennsylvania show 1,763,000 individuals aged 16 to 25,
approximately 14 percent of the total state population. Research suggests that many of these
individuals are at-risk for, or diagnosed with, serious mental health conditions. NSDUH findings
as applied to Pennsylvania youth indicate a prevalence rate in the past year of over 300,000
individuals aged 16-25 with a mental illness and nearly 125,000 individuals with mental illness
as well as a SUD.
In regard to Medicaid penetration rates, the total number of HC-BH Medical Assistance (MA)
eligible individuals in Pennsylvania as of March 2015 was 1,973,262. The percent of HC-BH
MA eligibles to the Pennsylvania population based on the 2010 Census data is 15.5 percent.
Thirty eight percent of HC-BH MA eligibles live in rural areas of the state versus 62 percent who
live in an urban area. Based on the 2010 Census data, 15 percent of the rural population is HCBH eligible and 16 percent of the urban population is HC-BH eligible.
3. Describe the capacity of the current Medicaid State Plan to provide the services listed in
Appendix II.
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The Pennsylvania Medicaid State Plan provides a full array of mental health and substance use
services that include many of the services listed in Appendix II of the grant summary. Outpatient
psychiatric clinic, mobile mental health treatment, outpatient drug and alcohol treatment,
methadone maintenance, peer support, crisis intervention and targeted case management services
are in the State Plan.
A range of services for individuals birth to age 21 are included in the State Medicaid Plan as well
as available under the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT)
provisions of Medicaid. Thus the standard array of outpatient, inpatient, and partial hospital
services are available as well as in-home family based mental health services and psychiatric
residential treatment services. In addition, an extensive range of individualized BH rehabilitation
services are available including services such as behavior specialist consultants, mobile
therapists, and therapeutic staff support.
Although not in the State Medicaid Plan, psychiatric rehabilitation services are offered as a
licensed program. Pennsylvania requires every county or county joinder to have a licensed Crisis
Intervention Program that requires mobile, telephone, and site based services. BH licensing
regulations require providers of services to have letters of support with various agencies and
providers to ensure coordination of care to treat the whole person and seamless transition
between services.
SUD services in Pennsylvania are provided through fee-for-service (FFS), 1115 and 1915(b)
waiver programs. FFS and 1115 waivers support acute care model benefits, and the 1915(b)
waiver includes recovery-oriented services. SUD services within Medicaid include inpatient,
residential detoxification and rehabilitation, outpatient therapy, and methadone maintenance
treatment. 1915(b) reinvestment supports an array of recovery support services.
About 709,000 persons aged 12 or older in Pennsylvania between 2008-2012 were dependent on
or abused alcohol within the year prior to being surveyed, and about 48,000 persons between
2008-2012 received treatment for their alcohol use within the year prior to being surveyed.
About 308,000 persons aged 12 or older between 2008-2012 were dependent on or abused illicit
drugs within the year prior to being surveyed. About 699,000 persons aged 21 or older between
2008-2012 reported heavy alcohol use within the month prior to being surveyed. Of these, about
one in 28 (3.5 percent) received treatment for alcohol use within the year prior to being surveyed.
The use of opioids nationally has increased dramatically, and the number of drug-related
fatalities has soared. Pennsylvania is working to address these concerns through the following
methods: development of statewide practice guidelines for narcotic prescribing; a review of
methadone related deaths; the development of guidance for patient consent to coordinate care for
consumers with SUD; enacting into law a prescription drug monitoring program and a ‘Good
Samaritan’ law (Act 139 of 2014) that enables police and family members to have access to
Naloxone spray and provides immunity to those who call 911 or otherwise aid a person who is
overdosing; and, the proposal of a pilot program to make Vivitrol and other forms of medication
assisted treatment (MAT) available to individuals with opioid dependence who are being
released from incarceration.
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Pennsylvania is working through the Innovation Accelerator Program Substance Use Disorder
High Intensity Learning Collaborative (IAP-SUD HILC) to explore and implement changes in
how SUD care is delivered and to reform payment mechanisms. Data from the Behavioral
Health Barometer reveals that the number of individuals receiving methadone increased from
15,723 in 2008 to 18,693 in 2012. The number of people receiving buprenorphine, a medication
used to assist in the treatment of those addicted to opioids, increased from 335 in 2008 to 1,852
in 2012. A study performed by the University of Pittsburgh indicated that 80 percent of the
prescribers of buprenorphine were primary care providers and only 40 percent of those
individuals in treatment attended a BH appointment. This would suggest the need for a system
which encompasses a comprehensive approach to SUD treatment. National data shows that drug
overdoses have continued to increase. According to data from the Department of Health, drug
induced deaths in Pennsylvania is highest for the 20-59 age group, ranging from a rate of 23.3
percent (20-24 age) to 36.9 percent (30-34 age). Improving access to quality care that is
integrated to treat the whole person will aide in this endeavor. CCBHCs will ensure that
Pennsylvania is moving toward timely and effective integrated care.
4. Describe the nature of the problem, including service gaps, and document the need (i.e.,
current prevalence rates or incidence data) for the population(s) of focus based on data.
Identify the source of the data. Documentation of need may come from a variety of
qualitative and quantitative sources. Examples of data sources for the quantitative data
that could be used are local epidemiologic data, state data (e.g., from state needs
assessments), and/or national data [e.g., from SAMHSA’s National Survey on Drug Use
and Health or from National Center for Health Statistics/Centers for Disease Control
and Prevention (CDC) reports, and Census data]. This list is not exhaustive; applicants
may submit other valid data, as appropriate for the program.
Despite an extensive array of publicly-funded community BH services for children, adults, and
older adults in Pennsylvania, serious service gaps remain. One such gap is the treatment of
children with serious emotional disturbances which is severely impacted by a shortage of childadolescent psychiatrists. The Pennsylvania community mental health system served nearly
150,000 children with serious emotional disturbances in 2014. In addition, Pennsylvania has a
significant issue with the lack of available/accessible SUD treatment. In 2013, 82 percent of
Pennsylvanians with substance dependence or abuse did not receive treatment; and 55 percent
who had any mental illness did not receive treatment (BH Barometer: Pennsylvania, 2013,
SAMHSA).
BH disorders affect a substantial portion of the population. One in four Americans experiences a
mental health or substance use disorder each year. Over the course of their lifetimes, 46 percent
of all Americans will have a BH disorder. Disadvantaged populations are at an even higher risk
of developing BH disorders than the general population. In 2012, PA DOH published the
Pennsylvania Health Disparities Report, which highlighted data from 2009 and revealed that
among the population with any mental illness, only 37.9 percent received mental health services.
Studies indicate that ethnic minorities accessing BH services have been negatively impacted by
education, employment, and income factors.
DHS will use the National Standards for Culturally and Linguistically Appropriate Services
(CLAS) in Health and Healthcare as a strategy for addressing health disparities. Utilizing input
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from stakeholders during the planning process, other strategies may emerge which would then be
incorporated into the process. Pennsylvania has a sizeable and increasingly diverse population
with attributes that include:

Youth under age 18 represent 23.8 percent of the population of Pennsylvania. The estimate of
youth and families from racial and ethnic groups include the following: Caucasian: 86
percent; African American: 11 percent; Hispanic/Latino: 4 percent; Asian: 2 percent;
American Indian/Alaskan Native: 0.2 percent. Nine percent of Pennsylvanians speak a
language other than English in their homes (US Census).

The Office of Child Development and Early Learning reports that young children in 37
counties (55 percent) are at moderately high or high risk of school failure. More than onethird (35 percent) of children under age five participate in state and/or federally-funded
quality early childhood education programs.

The Annie E. Casey Foundation’s 2013 Kids Count Data Book ranks Pennsylvania 25th in
the family and community domain, down from 23rd the previous year. This domain
examines the percentage of children living in high-poverty areas, single-parent households,
and education levels among heads of households, as well as teen birth rates. Pennsylvania is
ranked 17th in economic well-being, the same ranking as 2012. The economic well-being
domain examines data related to child poverty, family employment, housing costs, and
whether older teens not in school are working.

The recent NSDUH found 9.27 percent of youth in Pennsylvania used an illicit drug in the
past month. The Kids Count Data Book ranks Pennsylvania 22nd in overall health, down
from 8th last year. The health domain looks at the percentage of children who lack health
insurance, child and teen death rates, low-birth weight babies, and alcohol or drug abuse
among teens. The severe drop in ranking is an area of great concern.

U.S. Census data indicate that youth of color in Pennsylvania face more disadvantages than
their counterparts. Hispanic/Latino youth represent a much higher proportion of youth living
in poverty (30 percent) and 11.9 percent of the households in which these youth reside are
headed by a single parent. While youth of color (primarily African American and
Hispanic/Latino) between the ages of eight and 18 represent only 14.3 percent of the total of
youth in this age group in Pennsylvania, the proportion of non-whites being served in the
county child serving systems is larger than that of Caucasians relative to their population.
Most concerning is the disproportionate use of restrictive residential settings for these youth.

Another important consideration is the significant number of lesbian, gay, bisexual,
transgender, questioning, and intersex youth (LGBTQI) in Pennsylvania’s youth population.
The National Gay and Lesbian Task Force Policy Institute cite studies that show that
approximately 5 percent of the teen population self-identify as gay or bisexual. They are at
increased risk to use substances and suffer from major depression.

Another significant population Pennsylvania wants to be responsive to is the children of
military active duty personnel, veterans, and their families. There are approximately 31,000
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military children living in the Commonwealth of Pennsylvania. Pennsylvania provides the
nation’s highest number of National Guard troops and the third largest number of all
personnel serving in the military effort. Sensitivity to the needs of youth in these families is
essential to a comprehensive approach and will be a focus in the CCBHCs.
In a 2009 SAMHSA study, 4.8 percent of adults were found to have a SMI within the past year.
Participants with a poverty status of “Poor” or “Not Poor” had SMI rates of 9.1 percent and 6.1
percent respectively. The SAMHSA BH Barometer: Pennsylvania, 2013, reveals that 3.7 percent
of all adults had SMI in the year prior to being surveyed. According to the NSDUH, 55 percent
of adults with any mental illness (AMI) did not receive treatment. Factors that impact a person
not receiving treatment include, but are not limited to: stigma, lack of transportation, medication
side effects, and poor relationship with a mental health provider. Through the use of CCBHCs
with a person/family and recovery-centered approach and improved coordination of care
including physical health (PH), Pennsylvania would expect to see the following outcome
measures: improved initiation and engagement with substance use treatment, a significant
decline in the percent not treated which we anticipate would lead to decreases in
hospitalization/re-hospitalization rates, incarceration, employment opportunities, and increased
quality time with family/friends.
Individuals with mental illness die, on average, 25 years earlier than individuals without mental
illness. Causal factors include heart disease, cancer, stroke, pulmonary disease and diabetes
(Medical Director’s Technical Report, National Association of State Mental Health Program
Directors). People with a mental illness are more than twice as likely to smoke cigarettes and
more than 50 percent more likely to be obese compared to the rest of the population (National
Institutes of Mental Health Director Blog, September, 2011). In Pennsylvania, about 97,000
youths (10.0 percent of all youths) per year in 2008-2012 reported using cigarettes within the
month prior to being surveyed (NSDUH). These statistics underscore the importance of
integrating care between behavioral health and physical health.
Section B:
Proposed Approach (40 points)
1. Describe how the capacity, access and availability of services to the population of focus
will be expanded. Include activities such as outreach and engagement, staff training,
and workforce diversity.
Certified Community Behavioral Health Clinics (CCBHCs) will be existing community mental
health clinics or Federally Qualified Health Centers which are able to provide a wide array of
treatment services to individuals with SMI, SED, and SUD. The treatment will include evidencebased approaches provided in an environment which supports whole person, integrated care.
Integrated care increases capacity by reducing stigma, improves access by addressing co-morbid
conditions, improves prevention and detection of mental disorders; reduces chronicity and
improves social integration, promotes better health outcomes, and improves human resource
capacity for mental health.
The CCBHCs will primarily serve individuals eligible for Medicaid; however, any individuals
presenting for services, regardless of their ability to pay or place of residence, will be accepted
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for services and provided with a welcoming environment. The CCBHCs will also serve
individuals whose treatment is court-ordered.
Availability and accessibility of services:
 Because many individuals are unable to access services during traditional business hours,
8:00 am – 4:00 pm, the CCBHCs will maintain evening and weekend hours. The clinics
will have clearly established relationships with local emergency departments and other
sources of crisis care to facilitate care coordination, discharge, and follow-up. The
CCBHCs will also have established relationships with local hospitals to facilitate postdischarge follow-up within seven days of an inpatient stay. The CCBHCs will utilize
peer, recovery, and clinical supports in the community and increase access through the
use of telehealth/telemedicine and mobile in-home supports.
 All new consumers requesting or being referred for BH services will receive a
preliminary screening and risk assessment during the first contact, which will be followed
by an initial evaluation. A more comprehensive person-centered and family-centered
diagnostic and treatment planning evaluation will be completed within 60 calendar days
of the request for services and updated at least every 90 days. Outpatient clinical services
for CCBHC consumers seeking an appointment for routine needs must be provided
within 10 business days of the requested date for service. Crisis management services
will be available and accessible 24-hours a day and delivered within three hours.
 The importance of integrating BH and PH is underscored by the significantly decreased
life expectancy for those individuals with mental illness. The CCBHCs will incorporate
wellness themes and collect data including but not limited to: hemoglobin A1C,
cholesterol, BMI, blood pressure, etc. CCBHCs will work with the DOH to integrate their
smoking cessation and quitline program into the service delivery system. PA DOH,
Division of Tobacco Prevention and Control partners with National Jewish Health to
provide tobacco cessation services through the PA Free Quitline (1-800 QUIT NOW).
Quitline is a telephonic and web-based program available 24 hours a day/ 7 days a week.
Services are provided in English and Spanish, with third-party coaching in Mandarin,
Cantonese, Korean, Vietnamese, French, and Russian; interpretive services with
translation are available in over 170 languages. Specialized materials are provided for:
youth under 18, pregnant tobacco users, racial and ethnic populations, smokeless tobacco
users, LGBTQI individuals, and persons with chronic health conditions. Quitline coaches
provide counseling for MH/people with intellectually disabilities (ID) tobacco users,
including people who have autism and Down’s syndrome. The cessation program
includes free nicotine replacement therapy (patch, gum, and/or lozenge) for up to eight
weeks for qualified callers, as available and medically indicated.
Outreach and engagement:
 The CCBHCs will have policies and procedures in place to ensure outreach to and
engagement of the target population. Strategies utilized will include group education and
mass media campaigns. Social media can be an effective method to reach millennials.
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 Activities will include assisting consumers and families in accessing benefits and formal
or informal services to address behavioral health conditions and needs.
 Each CCBHC will have a communication plan to address health literacy.
Staff Training:
 The CCBHCs will develop training plans that are applicable for all employed and
contract staff and for providers the CCBHC has an agreement with to provide indirect
services to CCBHC consumers or their families.
 Training plans will include cultural competence including information related to military
culture as appropriate; person-centered and family-centered, recovery-oriented, evidencebased, and trauma-informed care; and, primary care and BH integration.
 Training will be provided as part of orientation at least annually; however, some training
may require more frequent updates. Additional training provided at orientation and
annually will include, but not be limited to, risk assessment, suicide prevention, and
suicide response.
Workforce Diversity:
 The workforce at a minimum should be reflective of the community the CCBHCs serve,
but CCBHCs will otherwise look to expand the diversity of the workforce whenever
possible. Strategies include: recruiting and promoting from diverse pools of candidates,
supporting flexible work arrangements, providing leadership education, and measuring
diversity and inclusion.
 If the population served by the CCBHCs includes individuals and/or family members
with Limited English Proficiency, the CCBHCs will provide interpretation/translation
services and auxiliary aids and services.
2. Describe how input on the development of the demonstration program will be solicited
from consumers, family members, providers, and other stakeholders including
American Indian/Native Alaskans and how they will be kept informed of the activities,
changes, and processes related to the project.
Use of existing advisory structures
DHS values regular input from stakeholders representing the diverse population of Pennsylvania.
DHS’ OMHSAS will continue to use an existing four-part strategy to connect with consumers,
family members, providers, and other stakeholders that will be incorporated into the CCBHC
project. The Pennsylvania Mental Health Planning Council will provide input and oversight for
the CCBHC proposal and planning process as described below. DHS/OMHSAS will also create
a new sub-committee of the Planning Council to serve as the State Level Steering Committee.
The CCBHC sub-committee will include OMHSAS council members and representatives of
other stakeholder groups, as described in 3 below.
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1. Pennsylvania Mental Health Planning Council
The Pennsylvania Mental Health Planning Council utilizes three committees and two
sub-committees: Children’s Advisory Committee, Adult Advisory Committee, Older Adult
Advisory Committee, Transition Age Youth Sub-Committee, and Persons in Recovery
Sub-Committee. These committees advise on a broad behavioral mandate to include, but
not be limited to, mental health, SUDs, and cross-system disability.
DHS will create a new sub-committee to focus on the CCBHC planning grant for
Pennsylvania. The sub-committee will include representatives from each of the existing
Council sub-committees, plus statewide and regional consumer and family organizations
(see 3.a through 3.e below). The CCBHC sub-committee will provide regular reports and
information exchanges with the Council-at-large and its other committees and subcommittees.
The DHS/OMHSAS Advisory Committees include individual representatives of youth,
adult, and older adult individuals who have been served by the BH system, family
members of such youth and adults, providers, advocates, professionals, their respective
organizations, as well as governmental organizations. At least 51 percent of the members
of the Council and each of its sub-committees are current or prior BH consumers and
family members.
The purpose of the Pennsylvania Mental Health Planning Council shall be to provide
counsel and guidance to the DHS/OMHSAS in order to ensure an infrastructure and full
array of mental health, substance abuse, and BH services which comply with the Mission,
Vision and Guiding Principles of OMHSAS, as well as core principles of Community
Support Program (CSP), Child and Adolescent Service System Program (CASSP),
Cultural Competency, and the Department of Drug and Alcohol Programs (DDAP).
DHS/OMHSAS will partner with Youth MOVE PA, a statewide chapter of National
Youth MOVE. This organization is comprised of youth, young adults, youth
organizations, system advisors, and youth allies who support youth empowerment and
voice in the services delivery system. Youth MOVE PA is committed to reducing stigma
surrounding youth with mental health concerns, as well as the stigma youth and the
community have regarding accessing services. Youth MOVE PA is also committed to
impacting social and public policy and promotes the availability and accessibility of
quality and relevant resources and services for youth and young adults.
2. Special Planning Task Forces, Public Forums and Focus Groups convened by
DHS/OMHSAS
DHS/OMHSAS convenes special forums to extend its connection to a broad array of
stakeholders across the Commonwealth. Over the past two years, DHS/OMHSAS
convened regional forums to gather input from external stakeholders in addition to those
who may serve on the Council or other standing committees. DHS/OMHSAS used an
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audience response system to help gauge the backgrounds of participants and record
participant feedback.
DHS/OMHSAS invited stakeholders to participate in the planning process to address the
BH needs of Pennsylvania residents. Over 500 stakeholders participated in the twenty
forums which included regional Community Support Programs, individuals receiving
services, family members, advocates, providers, county personnel, and other stakeholders
to initiate a review of our current system and to begin to consider planning steps.
DHS/OMHSAS partnered with the Pennsylvania Department of Military and Veterans
Affairs to facilitate sessions with veterans, service members, and their families at four of
the state veteran homes. Members of the community also participated in these forums.
Feedback from the forums on how DHS/OMHSAS can build connections with
stakeholders includes:
 Regional meetings
 Surveys
 E-mail blasts
 More drop-in centers
 Webinars and forums
 Website communication
DHS/OMHSAS will use this acquired information and feedback in the development and
implementation of the CCBHC proposal. DHS/OMHSAS will continue to convene
regional forums to meet with stakeholders in communities across the commonwealth to
help frame its approach to the development and use of CCBHCs.
3. Engagement with statewide and regional consumer and family oriented
organizations
DHS/OMHSAS also connects on a recurring basis with stakeholders through meetings
and forums convened by consumer and family oriented organizations including:
a. National Alliance on Mental Illness of Pennsylvania (NAMI PA)
NAMI PA is the largest statewide nonprofit organization with over 60 affiliates
across Pennsylvania dedicated to helping mental health consumers and their families
rebuild their lives and conquer the challenges posed by severe and persistent mental
illness. A wide variety of support activities are carried on by NAMI PA affiliates
including family support group meetings, consumer specific support group meetings,
NAMI-CAN (Children and Adolescents Network) for young families, and NAMICARE (Consumers Advocating Recovery through Empowerment).
b. Pennsylvania Mental Health Consumer Association (PMHCA)
PMHCA recognizes the expertise that comes out of lived experience. PMHCA is an
organization governed, managed, and staffed by individuals who identify as being on
their own mental health recovery journeys. PMHCA advocates on issues directly
related to mental health recovery and services in Pennsylvania both for individuals
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and system-wide. PMHCA promotes and supports recovery through advocacy and
education with the goal of eliminating stigma and discrimination around mental
health issues.
c. Mental Health Association of Pennsylvania (MHAPA)
MHAPA is a nonprofit organization that reflects the ethnic and cultural diversity of
the Commonwealth, works on behalf of the mental health of its citizens, instilling
principles that facilitate recovery and resiliency of individuals and their families,
through advocacy, education, and public policy. MHAPA is a statewide, proactive
organization seeking to promulgate the best practices and standards of excellence for
achieving the ultimate goal of a just, humane, and healthy society, in which all people
are accorded respect, dignity, choices, and the opportunity to achieve their full
potential free from stigma and prejudice.
d. Community Support Program (CSP)
The Community Support Program (CSP) of Pennsylvania is a coalition of mental
health consumers, family members, and professionals working to help adults with
serious mental illnesses and co-occurring disorders live successfully in the
community. This statewide coalition links regional and local CSPs throughout the
commonwealth. CSP committees offer forums across Pennsylvania where consumers,
family members, and professionals are united by a common set of beliefs and values
and use their combined strengths to promote systems change.
e. Pennsylvania Recovery Organizations Alliance (PRO-A)
PRO-A works with regional organizations to develop a statewide organizational
structure and identify recovery groups throughout the commonwealth to work
together on behalf of the recovery community. Through this organization, members
can join together to support quality services, combat stigma and discrimination
associated with addiction, and represent the unique perspective of the recovery
community in Pennsylvania.
PRO-A believes the potential exists to involve even greater segments of the recovery
community living in this expansive, culturally diverse state in the public dialogue
about addiction, treatment and recovery, and significantly impact the policies,
systems and services that meet their needs.
4. Engagement with commonwealth and county government offices and related
organizations
DHS/OMHSAS also connects with other governmental departments and related
organizations through participation in a recurring schedule of meetings and forums
including:
1. Statewide advisory groups representing DHS stakeholders
a. Medical Assistance Advisory Committee (MAAC)
b. Consumer subcommittee of the MAAC
c. Managed Care Sub-committee of the MAAC
d. System of Care State Leadership and Management Team
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2. Statewide Organizations directly involved in BH care services
a. Pennsylvania Mental Health Consumer Association (PMHCA)
b. Pennsylvania Mental Health Association (PMHA)
c. Drug and Alcohol Service Providers Association of Pennsylvania (DASPOP)
d. Rehabilitation and Community Providers Association of Pennsylvania (RCPA)
e. Hospital Association of Pennsylvania (HAP)
f. Pennsylvania Suicide Prevention Coalition
g. Pennsylvania Psychiatric Leadership Council (PPLC)
h. Pennsylvania Association of Psychiatric Rehabilitation Services
i. Commonwealth Prevention Alliance (CPA)
4. Other Government Related Advisory Structures
a. County Commissioners Association of Pennsylvania (CCAP)
b. Pennsylvania Association of County Administrators Mental Health/Disability
Services (PACA MH/DS)
c. Pennsylvania Association of Human Service Administrators (PACHSA)
d. Pennsylvania Association of County Drug and Alcohol Administrators
(PACDAA)
e. Pennsylvania Commission on Crime and Delinquency (PCCD)
1) Mental Health and Justice Advisory Committee (MHJAC)
2) County Justice Advisory Committee (CJAC)
f. Pennsylvania Department of Corrections (DOC)
g. Pennsylvania Department of Military and Veterans Affairs (DMVA)
DHS/OMHSAS will make the CCBHC planning grant a part of the conversation across the
spectrum of groups involved in BH issues. DHS/OMHSAS will also reach out beyond the
existing structures to reach other interested parties and to engage with individuals who represent
at-risk and underserved populations including LGBTQI, service members and their families,
transition age youth, and individuals involved in the criminal justice system.
3. Describe how community behavioral health clinics will be selected to participate and
how the state will work with them to meet or prepare to meet the requirements in
Appendix II.
In Pennsylvania there are 16 Community Mental Health Centers that are certified by Medicare
and a total of 267 facilities licensed to provide outpatient mental health services. Over 650,000
individuals are served by this system. There are 49 Federally Qualified Health Centers (FQHCs)
and look-a-likes in Pennsylvania caring for approximately 700,000 individuals. DHS proposes
utilizing a request for application (RFA) process that would require completion of a survey tool
and the Certified Clinic Readiness Tool (CCRT) to determine which of these entities are best
prepared in terms of existing infrastructure and leadership to make the commitment to work
toward meeting the criteria to become a CCBHC during the planning year.
Pennsylvania would select a minimum of two sites to be certified during the planning year; there
would be no maximum number set. However, DHS would anticipate a regional approach and
would utilize the planning year to reach a consensus on whether the commonwealth would be
divided into four or five geographic regions. Only clinics established prior to April 1, 2014, will
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be considered eligible to become a CCBHC, and the clinics would be certified based on their
ability to achieve quality indicators. The health system landscape in Pennsylvania will enable us
to ensure inclusion of both rural and urban facilities. DHS will assist the clinics selected for
CCBHC status as they work to meet the certification standards by facilitating access to training,
providing technical assistance assessing gaps in staffing and services, building partnerships and
formal relationships, implementing evidence based practices with fidelity, assisting the
development of care coordination performance measurement and reporting practices,
recommending continuous quality improvement processes, and implementing and optimizing
health information technology infrastructure. DHS will facilitate cultural, procedural, and
organizational changes to CCBHCs that will result in the delivery of high quality,
comprehensive, person-centered, and evidence-based services that are accessible to the target
population. DHS will assist CCBHCs to improve the cultural diversity and competence of their
workforces. We will verify that CCBHC’s have a mechanism for, and commitment to,
meaningful input from consumers, persons-in-recovery, and family members. We will ensure
that the CCBHCs have the capacity to accept, utilize, and collaborate with all service systems
and funding sources necessary to meet the needs of persons with mental illness and SUDs
presenting for services independent of where the payment sources originate, i.e. self-pay,
Medicaid/Medicare, private insurance, block grant funds, state or local funds, Department of
Defense, Department of Veterans Affairs, social security, and so forth.
4. Describe how all of the services outlined in Appendix II will be provided by CCBHC’s
in the state.
After selecting sites that will serve as CCBHCs, but before issuing certification, DHS will review
the needs assessments that have been completed within the past the years by the PA DOH, HAP,
and any other pertinent group that has conducted such a needs assessment. DHS will then
complete an appropriate needs and gap analysis for the target consumer population and formulate
a staffing plan for the prospective CCBHC. The needs assessment will include cultural,
linguistic, and treatment needs. Based on the needs identified in the DHS assessment, the
prospective CCBHCs will implement the staffing plan, which will include Medicaid enrolled
providers who can adequately address the needs of the consumer population served. The
management team will consist of a Chief Executive Officer (CEO) or Executive Director/Project
Director and a Medical Director. The Medical Director will be a psychiatrist who will be
responsible to ensure the medical component of care and the integration of BH and primary care
are facilitated. In the absence of the Medical Director, the Executive Director or Project Director
will appoint an appropriately trained person to assist with the integration of care.
The CCBHCs will maintain a core staff comprised of employed and/or contracted staff as
appropriate to meet the needs of the CCBHC consumers. DHS will ensure that staffing includes
medically-trained BH care providers including, but not limited to: providers who can prescribe
and manage medications, credentialed substance abuse specialists, individuals with expertise in
addressing trauma and promoting the recovery of children and adolescents with serious
emotional disturbances (SED) and adults with SMI and those with SUDs, psychiatrists
(child/adolescent, general adult, and geriatric as appropriate), nurses trained to work with
consumers across the lifespan, licensed independent clinical social workers, licensed marriage
and family therapists, licensed occupational therapists, staff trained to provide case management,
certified peer specialists/recovery coaches, certified recovery specialists, licensed addiction
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counselors, staff trained to provide family support, medical assistants, Certified Registered Nurse
Practitioners (CRNP)/Advanced Nurse Practitioners (ANP), community health workers, and any
other qualified personnel as determined by the needs assessment. Staffing will consist of
credentialed, certified, and licensed professionals trained in person-centered, family-centered,
trauma informed, culturally-competent, and recovery-oriented care.
Through the use of care coordination, the CCBHCs will intentionally organize patient care
activities and share information among all of the participants concerned with a patient’s care to
achieve safer and more effective care. Care for patients will be coordinated across the spectrum
of health services and will include access to high-quality PH (acute and chronic), BH care, social
services, housing, educational systems, and employment opportunities as necessary to facilitate
wellness and recovery of the whole person. The CCBHCs will establish partnerships or formal
contracts with FQHCs, rural health clinics (as applicable), inpatient psychiatric facilities and
substance use detoxification, post-detoxification step-down services, and residential programs;
with other community or regional services, supports and providers including schools, county
child welfare agencies, and juvenile and criminal justice agencies and facilities, state licensed
and nationally accredited child-placing agencies for therapeutic foster care services; with the
Department of Military and Veterans Affairs medical centers, independent outpatient clinics,
drop-in centers; with inpatient acute care hospitals, and hospital outpatient clinics. Other
community regional services, supports, and providers who may enter into a care coordination
agreement with the CCBHCs (based on the population served) include, but are not limited to, the
following: specialty providers of medications for treatment of opioid and alcohol dependence,
suicide crisis hotlines and warm lines, homeless shelters, housing agencies, employment services
systems, services for older adults such as Aging and Disability Resource Centers, and other
social and human services programs and agencies. The CCBHCs will establish and maintain
health information technology (HIT) systems that include electronic health records and have the
capacity to capture structured information in consumer records, provide clinical decision support,
and electronically transmit prescriptions to the pharmacy. These HIT systems will assist the
CCBHCs with population health management, quality improvement, reducing disparities, and
research and outreach. CCBHC Treatment Teams will consist of the individual in treatment, the
family/caregiver of a child-in-treatment, the adult individual’s family to the extent the individual
does not object, and any other person the individual chooses. The CCBHCs will also designate
interdisciplinary treatment teams that will work in collaboration with the individual or
family/caregiver to direct, coordinate, and manage care and services for the individual. These
teams will also coordinate medical, psychosocial, emotional, therapeutic, and recovery support
needs of individuals served by the CCBHCs.
DHS will establish scope of service requirements that encourage CCBHCs to expand the
availability of high-quality, integrated, person-centered, and family-centered care and to ensure
the continual integration of new evidence based practices. Pennsylvania will require the CCBHC
services to include the following: crisis BH services that include 24 hour mobile crisis teams,
emergency crisis intervention services, and crisis stabilization; screening, assessment, and
diagnosis that would include a comprehensive person and family-centered diagnostic and
treatment planning evaluation that is completed within 60 days by licensed BH professionals;
screening and assessment using validated tools that are culturally and linguistically appropriate;
where appropriate, brief motivational interviewing techniques; person-centered and familycentered treatment planning, during which an individualized treatment plan will integrate
Page 15
prevention, medical, and BH needs, and service delivery that is developed in collaboration with
the individual and the family; outpatient mental health and substance use services; outpatient
clinic primary care screening and monitoring of key health indicators and health risk; targeted
case management services that include supports for persons deemed at high risk of suicide,
particularly during times of transitions such as from an emergency room or psychiatric
hospitalization; psychiatric rehabilitation services that include, but are not limited to, medication
education, self-management, training in personal care skills, individual and family /caregiver
psycho-education, community integration services, recovery support services including illness
management and recovery, financial management, and dietary and wellness education; peer
supports, peer counseling, and family/caregiver supports, including but not limited to, peer-run
drop-in centers, peer crisis support services, peer bridge services to assist individuals
transitioning between residential or inpatient settings to the community, peer trauma support,
peer support for older adults or youth , and other peer recovery services; and, intensive
community-based mental health care for members of the armed forces and veterans. Crisis
services, screening, assessment and diagnosis, treatment planning, and outpatient mental health
and substance use services will be provided directly by the CCBHCs. The other services may be
provided through a contract with a Designated Collaborating Organization (DCO).
DHS will collect and report on encounter, clinical outcomes, and quality improvement data. The
data collection will be used to assess the impact of the demonstration program on 1) access to
community-based, BH treatment in the area(s) of the commonwealth targeted by a demonstration
program compared to other areas of the commonwealth; 2) quality and scope of services
provided by CCBHCs compared with non-CCBHC providers; and 3) federal and state costs of a
full range of BH services including inpatient, emergency, and ambulatory services. The
CCBHCs will have the capacity to collect and report on data capturing consumer characteristics,
staffing, access to services, use of services, screening, prevention and treatment, care
coordination, other processes of care, cost, and consumer outcomes. In order to be certified, the
CCBHC must develop, implement, and maintain an effective CCBHC-wide, data-driven,
continuous quality improvement (CQI) plan for clinical services and clinical management that is
reviewed and approved by DHS during certification.
5. Identify the evidence-based practices that CCBHC’s will be required to provide and
justify the selection of the evidence-based practices.
As part of the planning process, DHS, in collaboration with the Department of Drug and Alcohol
Programs (DDAP) and the clinics committed to becoming certified, will complete a needs
assessment. Based upon the findings of the needs assessment, DHS will establish a minimum set
of evidence based practices (EBPs) required of the CCBHCs that will include: motivational
interviewing; cognitive behavioral individual, group, online, and recovery-oriented therapies
(CBT); dialectical behavioral therapy (DBT); addiction technologies; recovery supports; first
episode early intervention for psychosis; multi-systemic therapy; assertive community treatment
(ACT); forensic assertive community treatment (F-ACT); evidence based medication evaluation
and management; community wrap around services for youth and children; and, specialized
clinical interventions to treat mental and SUD experienced by youth.
When selecting the EBPs, DHS and partners will consider themes of support recovery-orientedcare. It is expected that the CCBHCs will offer care that is person and family-centered as well as
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trauma informed; the integration of physical and BH care will serve the whole person rather than
one disconnected aspect of the individual. Care coordination, such as community-based mental
and SUD services, integration of BH with PH care, assimilating and utilizing evidence based
practices on a more consistent basis, and promoting improved access to high quality care will
serve as the centerpiece of all aspects of CCBHC care.
6. Describe how the state will certify community behavioral health clinics in both urban
and rural areas (where applicable) in the state.
DHS will select clinics that are interested and committed to meeting the criteria for certification
as demonstrated by their responses to the commonwealth’s RFA and their ability to meet quality
indicators. Receipt of accreditation by a nationally-recognized organization such as The Joint
Commission (TJC), the Commission on Accreditation of Rehabilitation Facilities (CARF), the
Council on Accreditation (COA), and/or the Accreditation Association for Ambulatory Health
Care (AAAHC) will be considered, but not required.
7. Describe how the state will finalize planning activities and assist with the transition to
implementation of the demonstration program, if selected to participate in the
demonstration program.
DHS/OMHSAS will use a five part strategy to transition from planning activities and proposal
preparation to CCBHC implementation.
a. DHS/OMHSAS will continue using the Pennsylvania Mental Health Planning Council and
CCBHC-interested stakeholder groups to maintain effective communication and continuing
input on CCBHC project development from the planning phase through implementation.
The Pennsylvania Mental Health Planning Council utilizes three committees and two subcommittees: Children’s Advisory Committee, Adult Advisory Committee, Older Adult
Advisory Committee, Transition Age Youth Sub-Committee, and Persons in Recovery SubCommittee. These committees will be engaged in ongoing monitoring of CCBHC
implementation processes.
The Council will establish a new CCBHC sub-committee that will include representatives
from each of the existing Council committees and sub-committees plus statewide and
regional consumer and family organizations. The CCBHC sub-committee will receive
ongoing staff updates on CCBHC progress and in turn will provide regular reports and
information exchanges with the Council-at-large and its other committees and subcommittees.
At least 51 percent of the members of the Council and each of its sub-committees are current
or prior behavioral health consumers and family members.
b. DHS/OMHSAS will leverage the existing HealthChoices BH-MCO contracting framework
to engage and fund selected CCBHCs and serve as the structure for the CCBHC prospective
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payment system.
HealthChoices contracts are built on recovery and resiliency principals. Consumers and
families serve on a Quality Management Committee established under each BH-MCO
contract to oversee the program. Counties and BH-MCOs maintain Consumer/Family
Satisfaction Teams (C/FSTs) that conduct face-to-face surveys to determine if the program is
meeting the needs of people served. The HC-BH Performance report, published annually,
presents the results of C/FST survey questions and 29 quality indicators. The program is
reviewed annually by an external quality management organization which submits a report to
the Center for Medicare and Medicaid Services (CMS) regarding the effectiveness of the
state’s oversight.
The Pennsylvania Mental Health Planning Council and the DHS Medical Assistance
Advisory Committee (MAAC) will receive regular updates about the CCBHC program and
provide feedback from stakeholders about how the program is working. Each contract has an
DHS/OMHSAS contract monitoring team in the DHS/OMHSAS regional field office.
c. Use HealthChoices actuarial resources to assure effective Certified Clinic Prospective
Payment System (CC PPS-1) rate setting.
CMS requires that capitation rates (fees paid to the contractors on a per member per month
basis) be actuarially sound. DHS and CMS receive a certification from DHS’ actuaries that
ensures that the capitation rates were developed using actuarial standards and that the rate
setting meets the CMS requirements. The HealthChoices actuarial resources will be
responsible for creating the CCBHC PPS rate setting methodology. DHS/OMHSAS plans to
use the CC PPS-1 rate structure.
d. Utilize established HealthChoices resources to manage CCBHC Quality Assurance and
Quality Management functions.
The OMHSAS Quality Management program ensures public accountability and continuous
quality improvement of OMHSAS programs and services. The OMHSAS Quality
Management Committee includes consumers, advocates, providers, counties, and managed
care organizations in addition to OMHSAS staff. It includes representation for adults,
children, and older adults as well as for persons with mental health and SUDs. The
Committee also ensures participation by members of ethnicities and minority groups served
by DHS/OMHSAS. DHS/OMHSAS engaged families and consumers to develop and
establish the following Guiding Principles for the provision of quality services and supports.
Guiding Principles for Quality Services and Supports
The mental health and substance use treatment system will provide quality services and
supports that:
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Facilitate recovery for adults and resiliency for children
Are responsive to individuals’ unique strengths and needs throughout their lives
Focus on prevention and early intervention
Recognize, respect, and accommodate differences as they relate to culture/ethnicity/race,
religion, gender identity, and sexual orientation
Ensure individual human rights and eliminate discrimination and stigma
Are provided in a comprehensive array by unifying programs and funding that build on
natural and community supports unique to each individual and family
Are developed, monitored, and evaluated in partnership with consumers, families, and
advocates
Represent collaboration with other agencies and service systems
DHS/OMHSAS established an overarching quality framework that relies on consumers and
families, combined with the participation of the counties, providers, and BH-MCOs to
continuously improve services and supports. Key objectives of the DHS/OMHSAS (Plan-DoAct-Check (P-D-C-A)) Quality framework include:
 Increasing access to community- and family-based services and supports
 Providing high quality services
 Improving consumer satisfaction
 Obtaining stakeholder feedback to continuously improve DHS/OMHSAS services
The Bureau of Quality Management and Data Review measures HealthChoices’ success in
improving the value and quality of behavioral health services and will provide technical quality
management and data support through the CCBHC planning and implementation phases.
8. Describe and justify the selection of the PPS rate-setting methodology. Describe how
CCBHC’s base cost with supporting data, as specified in Appendix III will be collected.
The Commonwealth’s initial selection of a rate-setting methodology is to use Certified Clinic
(CC) Prospective Payment System (PPS)-1, the daily rate, as described in Section 2 of Appendix
III of RFA Document Part I. This decision is subject to additional review, pending analysis of
data and stakeholder involvement.
CC PPS-1 was selected for ease of implementation. A daily rate is consistent with how FQHC
providers are currently reimbursed, which indicates the current state system is capable of making
daily payments that correspond to delivered services. Alternatively, CC PPS-2 requires more
complex payment algorithms to execute. CC PPS-2 also requires significantly more detailed data
due to the additional parameters for outlier payments and special populations. These parameters
would require highly credible data and warrant a more robust analysis before a decision could be
made to select CC PPS-2 as the payment methodology. As the payment system is implemented
and data experience is collected, transitioning to the CC PPS-2 methodology could be
considered. In the interest of a successful launch, the commonwealth plans to move forward with
the CC PPS-1 methodology.
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The success of the program will depend in large part on the sufficiency and adequacy of the
initial payment rates. Significant time and effort will be put into collecting accurate and credible
cost report data to put the commonwealth in the best possible position to implement sufficient
and adequate payment rates. Daily visit and cost data from the cost reports will be used in the CC
PPS-1 calculation methodology. The cost reports will be designed and reviewed to ensure only
allowable costs are factored into the PPS rate calculation. Provider-specific cost reports will be
used to establish provider specific PPS-1 rates. This will preserve flexibility for rate differentials
for urban and rural providers if necessary.
9. Describe how the state will establish a PPS for behavioral health services provided by
CCBHCs in accordance with CMS guidance in Appendix III.
As mentioned above, the commonwealth plans to collect cost reports from each of the
participating CCBHCs. The cost report data will be limited to those services and populations
covered by CCBHC’s under the grant, and the daily payment rate for each CCBHC will be
calculated as the sum of trended allowable annual costs divided by the sum of daily visits over
the corresponding time period. Trend will be based on the Medicare Economic Index. This
manner is consistent with the methodology described for CC PPS-1 in the RFA and produces a
fixed payment rate for each CCBHC that does not vary with the participant type, CCBHC
services provided, or overall costs associated with the visit.
A Quality Bonus Payment will be offered, details of which are described in Section D of the
commonwealth’s response.
As the commonwealth currently provides a significant volume of behavioral services through
managed care contracts for MA recipients in HealthChoices, the ultimate payment for services to
CCBHCs will largely occur through the MCOs. Once the PPS rates are established, the
capitation rates for the HealthChoices program will be re-evaluated and adjusted using generally
accepted actuarial principles and practices to account for the CCBHC PPS rates and expected
utilization. The commonwealth does not intend to use a wraparound reconciliation process for
the CCBHC payment under managed care, which is a commonwealth decision point.
10. Identify any other organization(s) that will participate in the proposed project. Describe
their roles and responsibilities and demonstrate their commitment to the project.
Include letters of commitment from these organizations in Attachment 1 of the
application.
The Pennsylvania Mental Health Consumers Association (PMHCA) and the Mental Health
Association in Pennsylvania (MHAPA) will provide ongoing technical assistance and
resources to ensure the input and engagement of service recipients and family members in the
design and implementation of the CCBHC initiative and each local clinic that is certified as a
qualifying CCBHC.
PMHCA is a statewide organization that is governed and operated by and for mental health
consumers. It provides individual advocacy, systems advocacy, information and referrals, and
technical assistance to the CSP and the C/FST that will be engaged in the ongoing review and
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monitoring of the CCBHCs. PMHCA also maintains a resource library for mental health
consumers.
MHAPA also works on behalf of mental health consumers through advocacy, education, and
public policy. Advocacy work focuses on consumer empowerment and making sure people have
access to services and supports. Education is provided to eliminate discrimination against mental
illness by improving public understanding, attitudes, and actions regarding mental health and
mental illnesses. Public policy work is focused on developing and supporting policies that
promote mental health, consumer empowerment, and access to care.
With funding from DHS/OMHSAS, the MHAPA and PMHCA support two part-time Behavioral
Health Navigators, who assist individuals (youth, adults, and older adults), families, friends, and
professionals seeking information and/or guidance about a variety of issues and needs that are
encountered when looking for or using mental and/or substance use services and supports. The
navigators play a role in helping individuals and families gain access to and maintain health
benefits including Medical Assistance.
The Community Support Program (CSP) of Pennsylvania is a coalition of mental health
consumers, family members, and professionals working to help adults with serious mental
illnesses and co-occurring disorders live successfully in the community. This statewide coalition
links regional and local CSPs throughout the commonwealth. CSP committees offer forums
across Pennsylvania where consumers, family members, and professionals are united by a
common set of beliefs and values and use their combined strengths to promote systems change.
PMHCA provides support and assistance to CSPs across Pennsylvania.
The Pennsylvania Recovery Organizations Alliance (PRO-A) works with regional
organizations to develop and identify recovery groups throughout the state to work together on
behalf of the recovery community. Through this organization, members can join together to
support quality services, combat stigma and discrimination associated with addiction, and
represent the unique perspective of the recovery community in Pennsylvania.
PRO-A works to eliminate stigma and discrimination against those affected by alcoholism and
other drug addiction through education and advocacy. They do this by providing education and
outreach, developing their membership, publishing a newsletter and monitoring the activities and
budgets of state and county agencies responsible for drug and alcohol services.
The Pennsylvania Department of Military and Veterans Affairs (DMVA) collaborates with
DHS/OMHSAS on issues related to the behavioral health needs of military personnel, veterans
and their family members. DMVA will contribute it knowledge and resources assist CCBHCs
that serve members of the military community. DMVA will also serve as a link to benefits and
supports that are available to military families.
The Pennsylvania Department of Corrections (DOC) collaborates with DHS/OMHSAS on
issues related to behavioral health needs of individuals incarcerated with mental health concerns.
The DOC reports that approximately 8 percent of their population suffers from serious mental
illness. DOC will commit to being involved in the stakeholder process and to working with the
CCBHCs on developing strategies to prevent re-incarceration of individuals with SMI.
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The Rehabilitation and Community Providers Association (RCPA) is among the largest and
most diverse state health and human services trade associations in the nation with more than 325
members serving well over one million Pennsylvanians annually. RCPA members offer mental
health, drug and alcohol, intellectual and developmental disabilities, medical rehabilitation, and
brain injury services for children and adults in vocational and residential settings.
RCPA serves as a forum for the exchange of information and experience, represents providers on
legislative and administrative matters, and serves as a point of contact with other related
statewide organizations. RCPA will provide ongoing consultation to the CCBHC planning and
implementation process. RCPA is providing its teleconference and webinar resources to foster
input and engagement in this initial CCBHC application.
Pennsylvania Association of County Administrators Mental Health/Disability Services
(PACA MH/DS) represents county mental health and intellectual disability program
administrators from all of Pennsylvania’s counties. The association also has two classes of
associate members, representing supports coordination organizations and HealthChoices
behavioral health entities. PACA MH/DS is an affiliate of the County Commissioners
Association of Pennsylvania.
The PACA MH/DS Board meets monthly as the County Administrators Advisory Committee
with DHS/OMHSAS. The Association also monitors and is involved in advocacy on behalf of
counties managed services and supports including HealthChoices.
Pennsylvania Association of County Drug and Alcohol Administrators (PACDAA) is a
professional association that represents the Single County Authorities (SCAs) across the
commonwealth who receive state and federal dollars through contracts with the Department of
Drug and Alcohol Programs (DDAP), to plan, coordinate, programmatically and fiscally manage
and implement the delivery of drug and alcohol prevention, intervention, and treatment services
at the local level.
SCAs also receive funding for treatment services from DHS/OMHSAS. The services funded by
DHS are primarily targeted to individuals in non-hospital residential care who are eligible for
MA, or provide a continuum of treatment services for those individuals no longer eligible for
MA as a result of welfare reforms. PACDAA members also participate in the local governance
structure for the HealthChoices Behavioral Managed Care Program.
Youth MOVE PA, a statewide chapter of National Youth MOVE. This organization is comprised
of youth, young adults, youth organizations, system advisors, and youth allies who support youth
empowerment and voice in the services delivery system. Youth MOVE PA is committed to
reducing stigma surrounding youth with mental health concerns, as well as the stigma youth
and the community have regarding accessing services.
Letters of commitment from these organizations are included in Attachment 1 of the application.
11. Describe how the state will work with CCBHCs to develop a process of board
governance or other appropriate opportunities for meaningful input by consumers,
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persons in recover, and family members as described in Appendix II, Program
Requirement 6: Organizational Authority, Governance and Accreditation.
Consumer and family participation in CCBHC board governance
CCBHCs will verify that their corporate boards receive input and ongoing guidance from
program consumers and family members. Potential CCBHCs will provide details about board
membership as part of their CCBHC certification applications. The preferred configuration of
providers seeking CCBHC certification is to have a governing board with membership
comprised of no less than 51 percent individuals and family members served.
If an organization seeking CCBHC certification cannot meet this membership threshold for
consumers and family members it must document how it provides opportunities for meaningful
input from consumers and family members in its governance process. Organizations seeking
CCBHC certification may satisfy this requirement through the establishment of a consumer and
family advisory structure that includes direct communication between the advisory group and the
organization’s governing board and program administration. CCBHCs will be required to
provide documentation regarding the consumer and family participation on an annual basis.
Section C:
Staff, Management, and Relevant Experience (10 points)
1. Discuss the capability and experience of the applicant organization and other
participating organizations with similar projects and populations, including experience
in providing recovery-oriented and culturally appropriate/competent services.
The applicant agency is the Pennsylvania Department of Human Services/Office of Mental
Health and Substance Abuse Services (DHS/OMHSAS). DHS/OMHSAS is responsible for
public BH services in Pennsylvania. DHS/OMHSAS will work in partnership with the DHS
Office of Medical Assistance Programs (DHS/OMAP), the State Medicaid Agency, and the
Department of Drug and Alcohol Programs (DDAP), the Single State Agency for substance
abuse services. DHS/OMHSAS will utilize the expertise of Mercer, Drexel University, the
Pennsylvania Mental Health Consumer Association, and the Mental Health Association of
Pennsylvania to bring the critical subject matter expertise to the planning and implementation
process. Each of these partnering entities has expertise that will be critical to the implementation
of the planning, support, and certification of BHCCBHC’s within Pennsylvania.
DHS/OMHSAS has been the recipient of several relevant SAMHSA grants including a CoOccurring Disorder grant, a System of Care Cooperative Agreement, a System of Care
Expansion Planning Grant and several grants focused on expanding the use of recovery-oriented
services such as self-directed care and peer supports. The successful implementation of these
grants speaks to the current capacity within Pennsylvania to undertake transformative efforts in
the BH system as well as the investment and support for improving recovery-oriented services
across the commonwealth. The focus of these transformation projects align with the goals and
population that will be the focus of this planning effort. These efforts have been planned and
implemented in collaboration with consumers, family, and other key stakeholders. Inclusion of
these key stakeholders assures that these services are consumer driven, culturally and
linguistically appropriate, and directed toward improved outcomes for those individuals served.
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The Office of Medical Assistance Programs (OMAP) is the office of the state Medicaid Program.
DHS/OMAP includes oversight of eight managed care organizations and the Access fee-forservice program. In the past ten years DHS/OMAP has participated in a multi-payer medical
home collaborative, initiated three pay for performance programs, developed a multi-state
application for the Medicaid electronic health record incentive program, established nonpayment
policies for readmissions and preventable serious adverse events in hospitals, developed
telemedicine payment policies, implemented a pharmacy preferred drug management program,
and expanded the HealthChoices mandatory PH managed care program statewide. DHS/OMAP
and DHS/OMHSAS have been working on initiatives to integrate behavioral and physical health
by participating on the IAP-SUD HILC, the establishment of the Person-Center Medical Home
Advisory Council, and the development of combined pay-for-performance of the BH and PH
MCOs.
The Department of Drug and Alcohol Services (DDAP) is the single state agency for substance
abuse services, with responsibility for the planning, direction and coordination of statewide
efforts related to substance use disorder. DDAP’s mission is to engage, coordinate, and lead the
Commonwealth of Pennsylvania’s effort to prevent and reduce drug, alcohol and gambling
addiction and abuse; and to promote recovery, thereby reducing the human and economic impact
of the disease.
Mercer Government Human Services Consulting is one of several specialized consulting
practices within Mercer Health and Benefits that focuses on the challenges for public sector
health care clients to become more efficient purchasers of health and welfare services. They
provide a wide array of consulting services to the federal government and state Medicaid
agencies and behavioral health, developmental disability and human services departments. The
services include actuarial, clincial, financial, operational, system, pharmacy and strategic
consulting assistance to state Medicaid programs. Mercer has the rate-setting capabilites to
calculate the large voume of rates required in a timely manner. All of Mercer’s acuaries are
members of the American Academy of Acuaries. Mercer certifies that their rate-setting process
complies with the applicable regulations concerning acuarial soundness. Mercer has worked with
both OMHSAS and OMAP for many years on the setting rates and other fiscal and data issues.
Drexel University’s Behavioral Healthcare Education (BHE), an interdisciplinary consultation,
education and system intervention program has a long standing partnership with DHS/OMHSAS.
The mission of BHE is to translate research, clinical and policy advances to practitioners in the
field. BHE has been a leader in promoting evidence based continuing education in the areas of
co-occurring MH & SA disorders, cultural competency, psychiatric rehabilitation, recovery
oriented practices, trauma-informed treatment, suicide-prevention and veterans’ behavioral
health. BHE has partnered with the PA Mental Health Consumers’ Association, the Mental
Health Association of South East PA, NAMI-PA, the Forensic Training Advocacy Center
(FTAC), the Rehabilitation Community Providers Association (RCPA), the Psychiatric
Rehabilitation Association, the PA Department of Corrections and Philadelphia Department of
Behavioral Health on many initiatives.
Pennsylvania Mental Health Consumer Association (PMHCA)
PMHCA recognizes the expertise that comes out of lived experience. PMHCA is an organization
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governed, managed, and staffed by individuals who identify as being on their own mental health
recovery journeys. PMHCA advocates on issues directly related to mental health recovery and
services in Pennsylvania both for individuals and system-wide. PMHCA promotes and supports
recovery through advocacy and education with the goal of eliminating stigma and discrimination
around mental health issues.
Mental Health Association of Pennsylvania (MHAPA).
MHAPA is a nonprofit organization that reflects the ethnic and cultural diversity of the
Commonwealth, works on behalf of the mental health of its citizens, instilling principles that
facilitate recovery and resiliency of individuals and their families, through advocacy, education,
and public policy. MHAPA is a statewide, proactive organization seeking to promulgate the best
practices and standards of excellence for achieving the ultimate goal of a just, humane, and
healthy society, in which all people are accorded respect, dignity, choices, and the opportunity to
achieve their full potential free from stigma and prejudice.
2. Provide a complete list of staff positions for the project, including the Project Director
and other key personnel, showing the role of each and their level of effort and
qualifications.
A Project Director hired by Drexel University (.33 FTE) will be responsible for overseeing the
development and implementation of the CCBHC planning grant guiding the work of the
administrative team. Key functions for this position will include the solicitation of input from a
broad range of consumers, family members, providers, and other key stakeholders, development
and implementation of the process to certify clinics as CCBHCs within Pennsylvania, and
support efforts to establish the capacity to provide BH services that meet the CCBHC criteria.
Dr. McNelis has been identified as the Project Director and has partnered with DHS/OMHSAS on a
number of projects including on the roll-out of state-wide systems change such as Intensive Case
Management (1990), the PA Mental Illness & Substance Abuse Consortium (1997-1999), The
Co-occurring Competency Bulletin (2006-2007), Psychiatric Rehabilitation (1999-present), The
Cultural Competence Strategic Plan and Clinical /Rehabilitation Standards of Practice (2003),
Development of A Call for Change based on the New Freedom Commission (2005) and
principles and Practices for Clinicians Working with Lesbian, Gay, Bisexual, Transgender,
Questioning and Intersex Individuals (LGBTQI) (2010-2013).
A Project Coordinator hired by Drexel University (.5 FTE) will be responsible for
documentation and reporting of the agreed upon processes for the expansion of service capacity,
certification, and implementation of CCBHCs. This position will support the overall concept
development, document critical information necessary for a Pennsylvania proposal to participate
in the demonstration program, and the development of reports and guidance to the field to
support the implementation of a CCBHC demonstration program. Dr. David Bennett is being
proposed as the Project Coordinator. He has expertise in managing data, conducting data
analysis, project evaluation and developing proposals. He has received funding from NIDA,
NIMH, the Pew Charitable Trusts, the Marshall Reynolds Foundation and the State of PA
Department of Health Tobacco. He has worked in the area of substance abuse treatment and
substance abuse research. Additionally, he has extensive research and clinical work with children
with serious emotional disorders and substance abuse. He is a member of the American
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Psychological Association, Society of Clinical Child and Adolescent Psychology as well as the
Society of Pediatric Psychology. His research has increasingly focused on applying state-of-theart psychosocial interventions for people with chronic health problems, including current studies
examining brief psychotherapies for anxious children with cystic fibrosis and depressed adults
who are HIV+. He also conducts assessments and provides interventions for families and
children at a clinic at St. Christopher’s Hospital for Children.
An Administrative Coordinator (1 FTE) will be hired by Drexel University to manage all
logistical and administrative details of the planning grant. The project coordinator will be
responsible for scheduling all in person and telephone meetings, communicating with
stakeholders, taking minutes at all meetings and performing research tasks as needed. The
project coordinator will have strong organizational, communication and technical skills. The
project coordinator will also have the ability to work via videoconference with the project
director and the grant writer.
3. Discuss how key staff have demonstrated experience and are qualified to develop the
infrastructure for the population(s) to engage in activities and are familiar with their
culture(s) and language(s).
In addition to the broad expertise of the agencies and partners participating in the planning
process, several key staff bring broad experience to support the development of the infrastructure
and activities for a successful planning and implementation process. An administrative
management team will meet weekly to facilitate implementation at the state and local levels. The
administrative management team is comprised of project staff and DHS/OMHSAS,
DHS/OMAP, and DDAP staff. This team will be responsible for the overall implementation of
the project, based on the broad direction provided by the Commonwealth Steering Committee.
The following individuals will serve on the administrative management team:
Dennis Marion is the Deputy Secretary for DHS/OHMSAS. DHS/OMHSAS has responsibility
for 4.0 billion dollars in state and federal funding to meet the behavioral health service needs of
over 650,000 individuals with behavioral health service needs across the Commonwealth. Prior
to accepting the Deputy Secretary position Dennis served as Chief Operations Officer and Chief
Clerk for Cumberland County. His thirty year career with Cumberland County also included lead
roles as Human Services Administrator, Administrator of Mental Health/Intellectual &
Developmental Disabilities, County Administrator, and Executive Director of the CumberlandPerry Drug & Alcohol Commission. Marion holds a law degree from the Penn State Dickinson
School of Law.
Dale Adair, MD is Medical Director and Chief Psychiatric Officer for the DHS/OMHSAS. He
received his M.D. from the University of Pittsburgh and subsequently trained in psychiatry at
Western Psychiatric Institute and Clinic. He has worked in a variety of settings including state
hospitals, private practice, research, and has been involved in physician assistant and medical
student education; however, the majority of his career has been devoted to the care of those with
severe mental illness served by the public mental health system. He also serves as a consultant
for the Center for Medicare and Medicaid Services on hospital standards.
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David Kelly, MD is the Chief Medical Officer for DHS/OMAP. He oversees the clinical and
quality aspects of the Medical Assistance program that provides health benefits to over 2.5
million recipients. Prior to joining the Department, Dr. Kelley worked for Aetna Health Inc. as
the medical director responsible for utilization and quality management in central and
northeastern Pennsylvania. Prior to Aetna, he served as Assistant Professor and Director of
Clinical Quality Improvement at Penn State University’s College of Medicine. As the Director
for Clinical Quality Improvement, he oversaw the quality and utilization management at Penn
State’s Hershey Medical Center. Dr. Kelley received his BS degree at Elizabethtown College,
attended medical school at the University of Pittsburgh, completed his residency training at
Baylor College of Medicine in Houston, obtained his MPA at Penn State University, and is board
certified in Internal Medicine and Geriatrics. He has clinically practiced at a FQHC, private
practice, an academic practice at Penn State University, and a community-based team approach
to diabetes care in a Medicaid hospital clinic.
Kenneth J. Martz, Psy.D., MBA, CAS. is Special Assistant to the Secretary for DDAP.
Dr. Martz is a licensed psychologist with over 25 years of experience providing direct services
and administration in mental health and substance use programs. His specialty includes HIV
counseling and addictions treatment with experience in a range of settings including outpatient,
residential and inpatient services as well as special populations such as criminal justice and
gambling disorder treatment. He also serves as adjunct faculty for Argosy University, working
with Masters and Doctoral students dissertations and research efforts. His doctoral paper was on
cultural issues in addiction and depression. He has a number of publications in the addictions
field, along with presentations on the international and national levels. His work with the
Department has included project manager in the development and implementation of the
Pennsylvania Client Placement Criteria, a manual used to identify proper level and duration of
care for citizens of Pennsylvania. The manual includes special population papers on cultural
issues, LGBTQ issues, and other management of other special needs of the substance use
population. He has also served as Project Director for two SAMSHA grants; one for dually
diagnosed homeless individuals and another for substance use prevention partnerships.
Ellen S. DiDomenico, MS Ed. is Director of the Bureau of Policy Planning and Program
Development for DHS/OMHSAS. Ms. DiDomenico has over 30 years in public Human Services
providing direct services and administration in County programs including child welfare, mental
health, intellectual disabilities, substance use, and other supportive services. She has provided
prevention services and consultation and training services for schools, human service programs,
and juvenile detention centers. She has served as a part time faculty in Psychology and Sociology
at Susquehanna University. Ms. DiDomenico’s professional career has been highlighted by a
strong focus on children’s services, providing direction to a broad range of initiatives focused on
reform of the social service delivery system through planning, results based management, and
community development. She spent five years as the Executive Director of the Governor’s
Commission for Children and Families, working on a variety of cross system projects to improve
outcomes for children and families across the Commonwealth.
Section D:
Data Collection and Performance Measurement (35 points)
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1. Document the ability to collect and report on the required performance measures as
specified in Section I-2.2 of this RFA. Describe the plan for data collection,
management, analysis, and reporting of data for the program. Specify and justify any
additional measures the state plans to use for the grant project.
The DHS/OMHSAS has had extensive experience with the collection and reporting of the
required performance measures. DHS/OMHSAS currently has six active SAMHSA grants that
report specific performance measures quarterly using the Common Data Platform (CDP) web
system. A sample method of how these will be assessed is provided for each of the indicators
below. The administrative management team will develop a simple reporting mechanism that can
be used by state partners and community providers to identify infrastructure changes related to
developing and implementing required performance measures. The administrative management
team will review the information provided on a quarterly basis in order to assess if the defined
goals are being reached, and make any necessary changes to ensure attainment of all goals. Data
from all evaluation efforts will be used to develop recommendations and inform the work of the
team, the local county partners, providers, and other family and youth stakeholders across the
commonwealth.
Infrastructure Performance Measures:
o The number of organizations or communities implementing mental health/substance
use-related training programs as a result of the grant.
o Assessment Plan: DHS/OMHSAS will track the date, participants, location of,
and satisfaction with training programs held at potential CCBHC sites and within
communities.
o The number of people newly credentialed/certified to provide mental
health/substance use-related practices/activities that are consistent with the goals of
the grant.
o Assessment Plan: DHS/OMHSAS will track the number of individuals who are
newly credentialed or certified as a mental health/substance use service provider in
preparation for certification as a CCBHC.
o The number of financing policy changes completed as a result of the grant.
o Assessment Plan: DHS/OMHSAS will document and explain specific policy
changes made in BH service financing, which may include changes to the payment
system for CCBHCs, waivers provided in support of financing efforts, or
regulatory or policy changes to support the certification of CCBHCs.
o The number of communities that establish management information/information
technology system links across multiple agencies in order to share service population
and service delivery data as a result of the grant.
o Assessment Plan: DHS/OMHSAS will track the number of providers that create
information sharing arrangements, the technology required to support those
arrangements, and any mechanisms proposed to implement new crossagency/system technologies in preparation for CCBHC certification.
o The number and percentage of work group/advisory group/council members who
are consumers/family members.
o Assessment Plan: DHS/OMHSAS will ensure a strong consumer, family, and
advocacy voice throughout the project by documenting the number of
consumers/family members on the Mental Health Planning Council, the
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administrative management team for the CCBHC planning grant, and work groups
that are initiated to support the planning grant efforts.
o The number of policy changes completed as a result of the grant.
o Assessment Plan: DHS/OMHSAS will document specific policy changes that
occur regarding BH service in preparation for CCBHC certification such as the
number of waivers to regulations, changes in policy bulletins, policy clarifications,
and additional policies or programs developed at the provider level.
o The number of organizational changes made to support improvement of mental
health/substance use-related practices/activities that are consistent with the goals of
the grant.
o Assessment Plan: DHS/OMHSAS will define and document the nature and extent
of organizational changes between counties and providers that support certification
and implementation of CCBHCs. These may include Memorandums of
Understanding (MOUs), contracts, information sharing arrangements, or other
mechanisms that will support improved mental health/substance use related
services.
o The number of organizations collaborating/coordinating/sharing resources with
other organizations as a result of the grant.
o Assessment Plan: DHS/OMHSAS will document collaboration and coordination
sharing efforts between counties and providers that support the certification and
implementation of CCBHCs and improved mental health/substance use services.
2. Describe how the state will support CCBHCs as they build the performance
measurement infrastructure and implement continuous quality improvement (CQI)
processes.
The DHS/OMHSAS has substantial experience and expertise with collecting, analyzing, and
reporting of the system-wide performance measures based on claims/encounters that are Center
for Medicare and Medicaid Services (CMS) Adult Core Measures (ACM) and Children’s Health
Insurance Program Reauthorization Act (CHIPRA) measures. DHS/OMHSAS reports statewide
results of consumer outcomes based on the Mental Health Statistics Improvement Program
(MHSIP) and the Adult Consumer Survey and Youth Services Survey for Families (YSS-F). The
External Quality Review Organization (EQRO) is in a multi-year protocol of validating DHS
encounter data to build the reliability of the performance measure results that are publically
reported to DHS community stakeholders and to CMS. DHS receives interim encounter
submission reports on a monthly basis and the EQRO is currently doing an encounter data
validation study comparing the performance submissions of BH managed care organizations
(BH-MCOs) with the submitted encounter claims. This will further enhance the DHS/OMHSAS
performance measurement infrastructure.
Clearly defined, measurable, time specific performance measurement indicators will be essential
to support the CQI processes of the BHCCBHCs and the systematic review of this initiative’s
effectiveness. The individual CCBHC will have a structure supported by policies and procedures
to collect and analyze results on a quarterly basis. These results will be based on monthly reports
from local health information systems (HIS) from which individual CCBHCs will be able to
monitor and improve access for consumers receiving mental health and SUD services.
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CQI supports:
o Require the local CCBHC to create a Data Plan incorporating CQI activities and
Consumer Stakeholder value-based feedback.
o CQI Support Plan: DHS/OMHSAS will require the approval of a Data Plan that
is consistent with the CCBHC and incorporates consumer stakeholder value-based
feedback through our local quality committee meetings at the contractor level. This
will ensure that the consumers will monitor the effectiveness of the data plan.
DHS/OMHSAS plans to use our Consumer Family Satisfaction Teams to assess
the satisfaction of consumers receiving services through the CCBHCs The
technical assistance required to meet this task will be part of the quality
developmental planning in the initial year for funding.
o The identification of data elements used on the consumer’s health record.
o CQI Support Plan: All approved CCBHCs will incorporate identical data
elements into the health record using a common Data Dictionary. The CCBHC
HIS will capture and be capable of reporting monthly access data for local CCBHC
reviews, and quarterly to meet the reporting requirements under Section I-2.3,
Program Requirement 3: Care Coordination 3.b.1., Appendix A: Quality Measures
and Other Reporting Requirements, Table 1. Contracts with the BHBH-MCOs will
include quality data reporting criteria.
o CQI Support Plan: DHS/OMHSAS will create a data sharing loop with the local
CCBHC for benchmarking activities which will create a process where the
individual CCBHC knows and analyzes their performance results compared to
their CCBHC peers. This will drive the CQI process by identifying improvement
opportunities.
o Establish performance measurement loop that reports from multiple CCBHCs to
BH-MCOs and BH-MCOs to DHS/OMHSAS and then back.
o CQI Support Plan: DHS/OMHSAS will create a data sharing loop with the local
CCBHC for benchmarking activities, and provide the technical assistance
necessary to build a baseline of measures that CCBHCs can use to identify
performance patterns, trending and barriers, and opportunities for improvement.
o Build capacity of CQI knowledge and performance of consistent quality activities.
o CQI Support Plan: Assess the ability of the CCBHC staff to understand,
evaluate, and implement staffing in CCBHCs in quality and CQI concepts.
Evaluate the need for a quality vendor knowledgeable in CQI processes to build
the capacity for quality performance and quality assessment activities in CCBHC
staff.
3. Describe the plan for conducting the performance assessment as specified in Section I2.3 of this RFA and document the ability to conduct the assessment.
DHS/OMHSAS has the necessary skills, experience, and expertise in assessing and directing
multi-level system performance assessments, including evaluating effectiveness by using
comparative group analyses. DHS/OMHSAS will develop mechanisms to conduct individual
agency performance assessments that identify whether and to what extent any CCBHC is
meeting or exceeding access to quality services for adults with SMI, children with SED,
individuals with long-term and serious SUDs, veterans, and those with co-occurring disorders.
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The diagram below represents the flow of performance assessment information. The specific
performance activities listed below the diagram are within the DHS/OMHSAS. DHS/OMHSAS
anticipates that SAMHSA is part of the performance assessment flow cycle and will have an
impact on the CCBHC performance assessment results.
SAMHSA
DHS/OMHSAS
Feedback, Review,
Assessment
Feedback, Review, Assessment
MH Planning Council
BH-MCO/ BH HC
Contractors
DHS/OMHSAS
Feedback, Review,
Assessment
Feedback, Review, Assessment
CCBHC
local stakeholder
review
Performance assessment activities:
o Performance assessment activity (individual CCBHC site): During the assessment
phase, the outpatient mental health sites seeking to become a CCBHC will have a
readiness review to determine whether their existing data system capacity can capture the
required data elements and the expected frequency of capture. All approved CCBHCs will
be expected to incorporate identical data elements into the consumer’s health record using
a common Data Dictionary. The CCBHC’s Health Information Systems will link to the
consumer’s health record and be capable of reporting demographic data such as age, race,
sex, and other data including: medications ordered and diagnoses made. The HIS will link
the demographic data, a unique consumer identifier, and date and time markers for the
initial contact, screening, assessment (emergency/crisis, urgent, routine), the clinical
evaluation, and the treatment plan. The times between these benchmarks will be averaged
monthly for individual CCBHC performance assessment tracking and quarterly for
reporting to DHS/OMHSAS, SAMHSA, and back to the CCBHCs. The data element
linkages will enable CCBHCs to conduct performance assessment locally to identify
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access issues and identify process improvement opportunities. Monthly data reports will
allow faster and timelier data that will allow the CCBHCs to develop a statistical process
performance assessment earlier (in one year) than what would be possible if the individual
CCBHC reviewed data quarterly (in three years).
o Performance assessment activities (BH-Managed Care Organization): The contracted
BH-MCOs will provide the individual CCBHC and aggregated data for multiple CCBHCs
in their catchment area. In addition, they will be required to provide:
o The quarterly reporting to DHS/OMHSAS, including key quarterly reporting for
access as found in grant requirements Appendix A: Quality Measures and Other
Reporting Requirements, Table 1, and in Sections I-2.2 and I-2.3 written in the
CCBHC planning grant announcement.
o Annual reports will be developed of performance measures for consumer
outcomes/satisfaction (MHSIP consumer and family survey), and for the National
Quality Forum /HEDIS measurements found in Appendix A: Quality Measures
and Other Reporting Requirements, Table 1, and the Quality Bonus Payment
(QBP) Medicaid Adult and Core Set measures written in the CCBHC planning
grant announcement.
o BH-MCOs will audit consumer health records for scope and quality of service to
ensure fidelity to the grant’s requirements at the individual CCBHC level.
o Outpatient mental health (OP MH) clinics not participating in the CCBHC
initiative may be part of a comparison cohort. BH-MCOs will submit quarterly
data submissions of OP MH clinics within the BH-MCO’s catchment area if the
clinic becomes a selected comparison cohort.
o There will be a yearly analysis of demographic data related to access measures.
This performance assessment will, to the extent possible, make reasonable
conclusions if disparities are statistically suggested in the data.
o Performance assessment activities (DHS/OMHSAS): Establish a consistent
performance assessment processes by linking the common data plan from reporting
Managed Care Organizations to DHS/OMHSAS.
o The aggregated CCBHC quarterly reporting from DHS/OMHSAS will include key
quarterly reporting for access as found in grant requirements Appendix A: Quality
Measures and Other Reporting Requirements, Table 1, and in Sections I-2.2 and I2.3 written in the CCBHC planning grant announcement.
o There will be yearly reporting of performance measures included in the quarterly
reports for consumer outcomes/satisfaction (MHSIP consumer and family survey),
and for the National Quality Forum /HEDIS measurements found in Appendix A:
Quality Measures and Other Reporting Requirements, Table 1, and the Quality
Bonus Payment Medicaid Adult and Core Set measures written in the CCBHC
planning grant announcement.
o DHS/OMHSAS will review a sample of the BH-MCO’s audits to ensure the
review done meets the grant’s requirements related to quality and scope of
services.
o Establish comparison performance groups using established measurements to
study differences in performance measures of access, quality, and scope of
services. A yearly review of access to services related to race and ethnicity will be
part of this analysis.
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o The CCBHC aggregate performance assessment will make reasonable conclusions
given the comparison, data type, and the frequency of the data collection.
o There will be a yearly aggregate analysis of demographic data related to access
measures. This performance assessment will to the extent possible, make
reasonable conclusions if disparities are statistically suggested in the data.
o DHS/OMHSAS will aggregate results by comparison group plan, analyze findings
and report to SAMHSA, and back to the BH-MCOs and CCBHCs for
benchmarking and further local improvement opportunities.
4. Discuss the challenges that may be encountered in collecting the data required for the
national evaluation and how the state will address these challenges.
CMS encourages states to implement the voluntary “Encounter Data Validation (EDV) Protocol
“due to the need for overall valid and reliable encounter data as part of any State quality
improvement efforts”. As federal programs transition toward payment reform for demonstrated
quality of care, the validation of encounter data (ED) in the use of performance data becomes
increasingly significant. DHS/OMHSAS has worked with the EQRO contracted with
Pennsylvania to identify needed improvements to increase the reliability and transparency of the
submitted encounter data as part of their Encounter Data validation. In 2013, EQR review found
that DHS/OMHSAS needed to improve the communications to BH-MCOs about active edit
codes in the encounter submissions, improve the lag time between when CPT codes become
effective on the national level and when they become effective in encounter submissions, and
require BH-MCOs to submit all diagnosis codes received from providers on the encounters.
These larger system challenges might affect the validity of the data reporting, but it is worth
noting that this is an ongoing improvement activity.
Other challenges identified in the review are the number of the required Quality Measures in
Table 1 (17) and Table 2 (15) exceed the number of measures currently required by
DHS/OMHSAS. Many of these measures are managed care measures that do not separate their
measures based on BH or PH encounters. DHS/OMHSAS is a BH “carve out” Medicaid
managed care benefit; the DHS data systems have separate encounter submission requirements
and encounter edits. These systems are distinct by services managed in the BH system and those
services managed by the PH system, and do not share diagnoses or services that are drug or
alcohol related due to Pennsylvania laws related to confidentiality exceeding those found in the
42 CFR Part II, Subpart D regulations.
Encounter data (ED) /system plan to address identified challenges
o Plan: DHS/OMHSAS will continue the EQR validation of the encounter data and
consider future Emergency Department (ED) onsite visits to BH-MCOs based on
encounter system issues. DHS/OMHSAS will continue the quarterly meetings with
BH-MCOs to streamline data communications and system requirements.
DHS/OMHSAS will soon communicate the requirement that all diagnoses
submitted by the provider need to be submitted on the encounter for a systematic
review of utilization, access, and stratification of risk levels.
o Plan: DHS/OMHSAS will utilize the EQRO to report results across the PH and
BH encounter data system for comparison with the CCBHC cohort results in five
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selected measures. These measures are ED visits per 1,000 member months,
inpatient discharges per 1,000 member months, thirty day readmissions per 1000
member months, initiation and engagement of alcohol and other drug dependence
treatment (IET), and adherence to antipsychotic medications for individuals with
schizophrenia.
o Assessment Plan: Assess the most efficient method to build capacity with the
encounter coding to identify the cohort OP MH clinic comparison based on
demographic data and/or utilization.
o CQI and Data supports.
o Assessment Plan: DHS/OMHSAS will review the staffing requirements and
knowledge criteria needed related to CQI and quality data analysis and display at
the CCBHC provider level, and the resourcing needed for reporting and analysis at
the DHS/OMHSAS level.
5. Describe a preliminary plan on how the state will select a comparison group for an
assessment of access, quality, and scope of services available to Medicaid enrollees
served by CCBHCs compared with Medicaid enrollees who access community-based
mental health services from other providers.
The preliminary data plan is to have three levels of comparisons possible, using the same or
different measures depending on the informational goal.
Data comparisons:
o Individual CCBHC/all CCBHCs. This is a one-group comparison. The measures used
in this comparison will be measurements of access found in Table 1 of Appendix A:
Quality Measures and Other Reporting Requirements. In addition, annual comparisons
will be made with National Quality Forum (NQF) measures found in this table and the
Quality Bonus Payment (QBP) measures.
o Goal: To build the local CCBHC capability to increase quality processes in
performance management.
o Identify local CQI activities and processes for the identification of baseline
performance data, identify local barriers in accessing services, and return
benchmarking data to the CCBHC to increase the measured performance
results related to quality, scope of services, and access.
o All CCBHCs/OP MH clinics (not in CCBHC program). This is a two group
comparison, OP MH consumers receiving services and CCBHC consumers receiving
services. An OP MH data assessment will be included to determine the data available for
equivalent access measurements. After cohorts are established, DHS/OMHSAS will seek
to have the analysis done by the EQR using validated results when the performance
measure is one already required in the performance measure protocol. DHS/OMHSAS
will pull the comparison measures using the encounter data or claim submissions, when
the performance measure is not part of the EQR performance measure protocol. The
measures used in this comparison are found in Table 1 of Appendix A: Quality Measures
and Other Reporting Requirements, and in the QBP measures (Table 3) of Appendix III.
o Goal: To determine whether there are differences in consumers who access
services in the CCBHCs versus those who access services in the OP MH settings.
o Goal: To determine whether there are differences in the national performance
measure results between the CCBHCs and in the OP MH settings.
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o All CCBHCs/and DHS/OMHSAS system. This is a two group design to see if there is
an association of performance between the CCBHCs and the DHS/OMHSAS system
o Goal:. To determine whether there are associations between the national
performance measure results of consumers receiving services in the CCBHCs and
all consumers receiving services in the DHS/OMHSAS system.
6. Describe the capacity to collect data to inform the national evaluation of the
demonstration program including claims, and encounter data, patient records, chartbased/registry data, and patient experience data.
DHS/OMHSAS has the knowledge and experience in data collection using claims, encounter
data, patient records, and the consumer’s experience data at the BH-MCO and the
DHS/OMHSAS system levels. The volume and the frequency of the data reviewed, analyzed,
and displayed within the comparison groups will require the skills of a data analyst and a quality
improvement specialist in data displays and analysis. The need for this capacity will be evaluated
early in the planning year.
The term capacity in IT refers to storage, software, computing resources, disk space, and
prioritization resourcing. DHS will conduct an in-depth assessment of the IT system to build the
relationships between the Uniform Reporting System, PROMISe system (encounters), MMIS/TMSIS, pharmacy claims, and the utilization data that can be identified at the consumer level. This
will need DHS/OMHSAS prioritization. In addition, there will need to be modifiers and back
coding to identify the CCBHCs and the outpatient MH clinics in the encounters submitted for the
comparison analyses.
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