A saying attributed to Buddha now circulating on the internet calls for a response

I recently saw something on the internet that begs a response.  Buddha is reported to have said:  “Believe nothing.  No matter where you read it, or who said it, no matter if I have said it, unless it agrees with your own reason and your own common sense.”  Whether or not Buddha said it many, many years ago, it’s bad advice now, especially for people living in America.  Here’s why:

If your ability to reason has been stunted by years of schooling that reveal only one route to truth (deductive reasoning), instead of its alternative (inductive reasoning, where truth is measured in probability, not the “certainty” offered by deductive reasoning based on the “acknowledged truthful facts” generously provided by the various authorities for your peace of mind), you can’t rely on your own “common sense” because it doesn’t EXIST anymore.  That’s the true legacy of schooling in America for the past 100 years, and especially so in the last 50.  We keep electing the leaders that our leaders want us to elect, by offering us their choices.  It’s a downward spiral.  See?  The only way out to recover from this situation is to “unflush the toilet” and that’s impossible, since there are too many people riding the spiraling stream downward.  The best we can hope for is to find a way to climb out of the bowl.  That’s what being an entrepreneur is all about – climbing out of the bowl. 

Best wishes for 2017 to all of the other entrepreneurs out there.


Has a New Era of openness & responsiveness dawned at Pennsylvania DHS?

I had a very productive meeting today with several members of the PA Department of Human Services regarding plans to transition from BHRS (wraparound) services to “Intensive Behavioral Health Services” (IBHS) over the next year or so. I was reassured that the new license that will be required for BHRS providers to become eligible providers of IBHS will be accessible to BHRS providers that currently deliver services in compliance with all existing standards, so my organizations should be able to become licensed as IBHS providers without any doubt. Continued affiliation with existing Behavioral Health Managed Care Organizations should also not be a problem, but that remains to be seen (although I’m optimistic).
It appears that DHS may be in the process of becoming more accessible and responsive, following several decades of maintaining a decidedly “different” attitude. Hopefully, the shape of things to come will continue to be positive. At least I’ve finally been allowed to receive and review the draft IBHS regulations, and have been invited to submit comments and recommendations directly to DHS authorities.

Welcome to The Issachar Project!

I created The Issachar Project in 2009 to provide parents, advocates, attorneys and practitioners with a source of information about Medicaid, the EPSDT benefit and successful behavioral intervention strategies for treating children in their homes, schools and communities.  Now, the Issachar Project is moving into high gear with the publication of my book THE ISSACHAR PROJECT set for May 25th in conjunction with my presentation at AutismOne in Chicago the following day. The Issachar Project will present questions to State Medicaid Agency personnel regarding the availability of EPSDT funding for behavioral treatment programs in all fifty US States. With the answers to these questions, it will be possible for a parent to strategically navigate the dark waters of the EPSDT system in any State in a search for honest and compassionate government employees. They do exist, but it’s really disheartening to wade through the system until you find one, especially without a map.

The mission of The Issachar Project is to provide that map, individualized for every state. It will be updated no less than once yearly and maintained in an on-line database, supported by philanthropy. With this map, parents will be able to quickly identify

•  The correct forms to fill out, how to fill them out and where to send them to enroll a child with a disability in the Medicaid system in that State.

•  If the State has implemented the “Medically Needy” category of Medicaid eligibility as a matter of State law, then virtually any child under the age of 21 who has a disability can enroll in Medicaid in that State, but the enrollment form has to be specially marked for this category.

•  The key people in the State who “know the truth” about EPSDT funding and how it is administered in that State to provide funding for Behavioral Health Rehabilitation Services (in addition to dental & lead level screenings and the other better-known portions of the EPSDT mandate).

•  The names and contact numbers for the Medicaid Managed Care Organization(s) in the family’s catchment area that will be involved in the overseeing of the child’s EPSDT funding, and the “best practice standards” that they espouse.

•  The names and contact numbers for the Medicaid Enrolled Practitioners within the family’s catchment area that are now, or could be, involved in delivering EPSDT funded Behavioral Health Rehabilitation Services to the child. We will assess their “track record” based on national standards of practice and a review of training and treatment documents, State performance assessments, audit and criminal investigation records and other material that may be submitted by parents.

•  The names and contact numbers for “licensed practitioners of the healing arts” who are not yet enrolled in Medicaid within the State who may be interested in working with The Institute for Behavior Change to create a “Medical Home” within a pediatric or family medical practice that will have a strong Behavioral Health component. With help from the Institute for Behavior Change in regard to staff recruitment, training and monitoring, it is possible for any medical practice in any State to implement Effective Treatment in a Wraparound Cup® as efficiently and successfully as The Institute for Behavior Change has done for the past 20 years.


Stanley Mrozowski leaves the PA Children’s Bureau.

The following statement was issued by the RCPA organization that has worked closely with Mrozowski for several years.  It does not offer any explanation as to why “the decision has been made to make a change” at OMHSAS that included Mrozowski’s departure from the PA Children’s Bureau which developed into the central planning and implementation point for Behavioral Health Rehabilitation Services (BHRS) throughout Pennsylvania under Mrozowski’s leadership.

On Friday (September 18), Stan Mrozowski informed RCPA staff and others that he had relinquished his position as Director of the Children’s Bureau at the Office of Mental Health and Substance Abuse Services (OMHSAS). Dr. Mrozowski noted that “there have been discussions recently in the Department of Human Services about the role of the Bureau and the decision has been made to make a change.” In his farewell message, Stan noted that “I leave with immense satisfaction about the many accomplishments over the past 12 years during which I have been the Director of the Children’s Bureau. I have very few regrets – mostly only that we did not do even more to help children and families in the Commonwealth. I also leave with appreciation for having worked with so many fine people who truly care about youth and families. I will truly miss the friendship and the collegiality that has made the work so rewarding.” RCPA will follow up with OMHSAS leadership to explore and report on any other changes that are planned for their management of children’s behavioral health services in the future.

Hopefully, desperately needed improvements in the BHRS system will now move forward.  These include streamlining the BHRS provider enrollment process to expedite the admission of qualified BHRS practitioners, establishing a standard of responsiveness to provider inquiries especially to appeals for State Medicaid/BHRS policy clarification, and the issuance of a final version of the “BHRS Draft Bulletin” that has been languishing in perpetual draft form since March of 2013.


Celebrating the start of the 20th year of operation for the Institute for Behavior Change

The Institute for Behavior Change will celebrate the start of its 20th year of operation in October. This short program describes the unique approach we have created to the training of Specialists in the Treatment, Evaluation, and Education of children with mental illness symptoms and behavioral challenges. I am proud and thankful beyond words to be associated with the terrific group of professionals we have assembled to carry on our work.



CMS-2390-P requires comments from parents, professionals and advocates

In response to my 6/25/2015 appeal for comments to CMS-2390-P (especially the section that explains how the parents of disabled children can be held financially responsible for the repayment of the cost of treatment delivered to their disabled child if they lose the final appeal of a Managed Care Organization’s denial of funding), I received the following e-mail message from an advocate.


The federal regulations have long allowed states to recoup the cost of services provided pending appeal if the family loses the appeal.  See 42 CFR 431.230.  Thankfully, Pennsylvania has never, to my knowledge, taken advantage of this provision.  The proposed regulations and commentary say that if states choose to take advantage of this long-standing provision, they should say so in the MCO contracts and be consistent between FFS and managed care. 

The proposed regulations you refer to are very lengthy (with the commentary, several hundred pages), and cover many, many, important topics.  If [our organization] submits comments on them and urges others to comment, I will let you know.

My reply

Thanks for the clarification but the CMS requested comments on 438.420 (which affirms the appropriateness of making the recipients of services financially liable if they lose the final appeal).  That’s wrong, no matter how long it’s been “on the books.”  CMS could fix 431.230 if they felt compelled to, and that’s why the comment process is so important.

Slavery was “on the books” for 87 years before it was challenged and finally repealed.  Some people still think that was a mistake.

It is wrong to hold the parents of a child who is a Medicaid recipient financially liable for the cost of the treatment services provided to their child while an appropriate, conscientious appeal of an adverse funding decision is underway.  Perhaps that’s why Pennsylvania has never done it.  They know it’s wrong.  I know it’s wrong.  The comment period is the place to express outrage over it, no matter how long it’s been “on the books.”  Evil doesn’t improve, or stay the same, with age – it gets more dangerous as time passes because it can spread.

This comment period is the time and place to put an end to the evil threat of making parents of Medicaid recipients financially liable while they are fighting for the lives of their children.  It should have been stopped, no matter which section(s) it appeared in, many years ago.  Don’t you agree?


Here is a link to the CMS-2390-P proposed rule changes.  You can see the 8 comments I’ve uploaded there so far, and the 23 comments received thus far (more than 600 comments were received the last time CMS proposed major changes to the Medicaid Act).  The present set of changes is lengthy, but it is at least as important as the set of changes that received over 400 comments by this point in the two-month comment period (which expires on July 27th).  This set of changes is flying way, WAY under the radar:


URGENT! Comments needed on proposed Medicaid policy changes that will hurt Millions of people

The rate of comment submissions regarding proposed Medicaid changes (2390-P) has increased 75% but there are still just 23 comments posted. By this point in the comment period for a previous CMS proposed rule change, there had been over 500.  This new set of rule changes is flying way, WAY below the radar, unfortunately, and millions of people are going to suffer because of it. Millions.

One esteemed Pennsylvania advocacy organization representative lamented to me “Steve, the thing is just too big — it’s over 200 pages in the Federal Register”). How could 200 pages be considered “too heavy to lift” by an advocacy organization? Here’s just one example of what is at stake; this is an excellent example of the kinds of comments that will expose awful changes that will go into effect Nationwide unless they are reformed – via the Comment process:

“This is absolutely unacceptable. I can’t believe this revision calls for “making recipients pay if they lose an appeal”. You are talking about poor people, most of whom are disabled and you want THEM to pay if they lose an appeal? This is how the rich get richer and the poor get poorer. I almost thought it was a joke when I heard this. Is this an attempt to stop all grievance filings? There is a point where the people need to realize that the government is no longer working for the people. This “revision” will hinder access to quality medical care for the disabled. How low can we go here? I am absolutely stunned by this and I hope that our system is not this far gone. We are a wealthy nation, how does it look when corporate subsidies are given out like candy and the disabled are left to beg for medical care. Just remember how this great nation was founded. The American people are growing weary of your antics.” (thanks, Sarah)

Here is a link to the CMS-2390-P proposed rule changes.  You can see the 8 comments I’ve uploaded there so far:  http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;D=CMS-2015-0068