The proposed IBHS (Intensive Behavioral Health Services) regulations have been released for public comment. IBHS is intended to replace the existing Behavioral Health Rehabilitation Services (BHRS) regulations that have existed for the past 20 years or so. In the BHRS system, licensed psychologists were permitted to deliver services after enrolling in the Pennsylvania Medicaid program and submitting a Service Description (a process that I completed in 1996). The new IBHS system prevents licensed psychologists from continuing to provide the mental health treatment and behavioral health support services that I have been delivering for more than two decades, because the IBHS regulations allow only “agencies” and “facilities” to deliver IBHS. While I have received what appear to be earnest assurances from top Department of Human Services (DHS) officials that both of the private psychology practice organizations I created long ago (The Network for Behavior Change and The Children’s Behavioral Health Center) would both be eligible for licensure as IBHS provider agencies, it would be enormously reassuring if those words were added to the IBHS regulations. They haven’t been, but there is still time. A simple “grandfather clause” would permit me and other privately licensed psychologists — some who also have more than 10 years of successful experience as BHRS providers — to continue delivering the excellent treatment and advocacy services that we have been delivering as BHRS providers, after the IBHS regulations go into effect. The comment period ends on 9/4/18. I submitted several comments. Here they are:
I look forward to a future as an IBHS provider and hope that the final form of the IBHS regulations incorporates the improvements and corrections that I’m recommending.
The proposed IBHS regulations and the comments submitted so far can be viewed at this address: http://www.irrc.state.pa.us/regulations/RegSrchRslts.cfm?ID=3220
Best wishes to all.