Mental Health Outpatient (MHOP)
A Mental Health Outpatient Program (MHOP) is a nonresidential treatment setting licensed by the Office of Mental Health and Substance Abuse Services (OMHSAS). The outpatient program must offer psychiatric, psychological, social, educational, and other related services provided under medical supervision. It is designed for the evaluation and treatment of individuals with mental illness or emotional disturbance. Facilities must comply with the 5200 regulations as outlined by the Department of Human Services.
The comprehensive process by which an individual is given access to services by the service provider. Intake may involve:
- Clinical Processes – interview, evaluation, use of assessment tools, prescribing, therapeutic alliance, treatment planning, etc.
- Administrative Processes – demographic information collection, eligibility verification, signing consents and authorizations, scheduling, etc. These processes are typically not billable components of the intake.
- Documentation of clinical conclusions and diagnosis, activities completed, specific recommendations for service or treatment, and materials obtained.
Note: The established rate for outpatient services includes the above clinical processes and the administrative and documentation processes that support appropriate claims submission for a new member. See “Billable Service” below for detail.
Assessment is an interview that includes the systematic evaluation and measurement of behavioral health, medical, psychological, social, vocational, and educational factors important to the individual presenting with a possible psychological disorder. Assessment tools may include standardized questionnaires, laboratory tests, records reviews, clinical interviews, and others. Motivational interviewing is a best practice, guiding the assessment process.
Evaluation is a careful examination or overall appraisal of current symptoms and treatment, by an individual with specific training, such as a psychologist or psychiatrist. Often compares results with other points of reference and typically results in detailed in a written document or “evaluation report.”
Services billed are based on current procedural terminology (CPT) codes. The rate included in the contract and CPT code includes the service provided and the administrative work associated with each service. Codes and billing are defined as either an event or with specified time increments, following guidelines for the relevant service or CPT code. An intake assessment session, therapy session, evaluation, medication management session, and psychological testing are examples of billable services.
According to PA Title 55, Chapter 5200.41: Records:
“Under section 602 of the Mental Health and Intellectual Disability Act of 1966 (50 P.S. § 4602), and in accordance with recognized and acceptable principles of recordkeeping, the facility shall maintain a record for each individual receiving services from a psychiatric outpatient clinic. The record must include the following:
- Identifying information
- Referral source
- Assessment including presenting problems
- Appropriately signed consent forms
- Medical, social, and developmental history
- Diagnosis and evaluation
- Treatment plan and updates
- Treatment progress notes for each contact
- Medication orders
- Discharge summary
- Referrals to other agencies when indicated
- A written recommendation from an LPHA acting within the practitioner’s scope of practice for any MMHT services provided”
Additional Resources and References
- DBHIDS Network Inclusion Criteria (NIC)
- CBH Provider Manual
Please see the Compliance section, Clinical Documentation Requirements, Mental Health Psychiatric Outpatient Providers
- DHS Psychiatric Outpatient Clinics Compliance Guide (Chapter 5200)
- Title 55 PA Code: Human Services
- Code of Federal Regulations Title 42 (Public Health)
Is a comprehensive biopsychosocial evaluation (CBE) required as part of an intake?
No. A CBE is not a required part of the documentation for OP service delivery. Ongoing evaluation and assessment of individual needs, appropriate clinical notes, and a treatment plan demonstrating member involvement are required for services continuing beyond 30 days.
Is it true that member(s) must complete comprehensive biopsychosocial re-evaluation (CBR) and intake if they have not attended treatment in 90 days or more? Could records from a previous provider be accepted?
OP providers may have developed internal policies to manage continuity of care, but the CBE/CBR is not a requirement for this level of care. The unique circumstances of the individual should be considered, and efforts made to minimize the burden of administrative redundancy. A brief review of changes since last contact and confirmation that treatment goals remain relevant is advised. Documentation from other providers can be accepted with member consent and will support strong clinical collaboration and clarity in treatment planning. Frequent billing for CBE/CBR for the same member, without a clear rationale, may raise concerns of Fraud, Waste, or Abuse for regulatory bodies.
Do member(s) have the right to request a therapist change?
Yes. Members should receive support if they indicate concerns with the assigned staff and be given factual information about how a change may affect the continuity of care as well as the benefits of working through interpersonal challenges with a clinician. For members who want to change a provider for any reason, CBH will help to identify a new provider or assist with any provider concerns. Members may be asked to call CBH Member Services at 1-888-545-2600 for help. If the request is related to a concern of ethical or compliance breaches, appropriate reporting is required.
Is it acceptable for members to receive medication without ongoing therapy?
Psychotherapy can be useful in combination with medication to treat mental health conditions through supporting skill development and resolving trauma responses. However, a member has the right to choose if they would like to participate in psychotherapy. Prescribers should clearly explain the provider policy on how often members are expected to have a clinical consult or re-evaluation to support ongoing medication management.
Are members discharged from the justice system or an inpatient/residential treatment facility provided with a 30-day supply of medication?
This varies significantly. Ideally, yes, a member would step down from a more restrictive setting to the community with an ample supply of medication to afford adequate time to connect to community-based care and ongoing medication access. However, we know that medication access barriers exist, and at times members will request expedited access to OP care when they have a 7- or 14-day supply and no scheduled refills. Care coordination with probation officers and case managers, as well as the review of discharge paperwork, can support more effective warm handoffs. Pharmacies are an important resource for care coordination and support the appropriate use of the PA Medicaid formulary.
Resource: DBHiDS Behavioral Health and Justice Division – Clinical Unit
CBH may be able to provide information when a member experiences an unplanned discharge and subsequently seeks care. CBH does not pay for medication. Medications, including those taken for behavioral health, are covered by Physical Health Managed Care Organizations (PH-MCO). Please refer to a member’s PH-MCO to find out which medications are covered and recently prescribed.
Who can consent to treatment?
The individual receiving services must provide informed consent to participate in any services, including utilizing telehealth communication. The individual (including the parent/guardian for any child under 14 years of age) has the right to choose the form of service delivery, which includes the right to refuse telehealth services, without jeopardizing access to other available services within the agency. The members must also be made aware of any alternatives available and any challenges that such alternatives will pose, including delays in service, need to travel, service verification methods, etc. Additional Telehealth considerations are discussed below.
For adolescents aged 14-17, PA Act 65 of 2020 (which supersedes Act 147 of 2004) details the parameters for consent to treatment.
Can providers share information about a member’s presentation/admission to an acute facility (crisis response center, inpatient or residential program admission) with an outpatient provider, case manager, or any mental health entities?
Records concerning persons receiving or having received treatment must be kept confidential and should not be released nor their information disclosed without the consent of a person given under § 5100.34 (relating to consensual release to third parties), except that relevant portions or summaries may be released or copied as follows:
- To those actively engaged in treating the individual, or to persons at other facilities, including professional treatment staff of State Correctional Institutions and county prisons, when the person is being referred to that facility and a summary or portion of the record is necessary to provide for continuity of proper care and treatment.
- To third-party payors, both those operated and financed in whole or in part by any governmental agency and their agents or intermediaries or identified as payors or co-payors for services and who require information to verify that services were provided. Information to be released without consent or court order under this subsection is limited to the staff names, the dates, types, and costs of therapies or services, and a short description of the general purpose of each treatment session or service.
Do CBH members have to present to a crisis response center to access/receive acute services?
Crisis services are for anyone, anywhere, and anytime. Crisis services include:
- crisis lines accepting all calls and dispatching support based on the assessed need of the caller
- mobile crisis teams are dispatched to wherever the need is in the community (not hospital emergency departments)
- crisis receiving and stabilization facilities that serve everyone that comes through their doors from all referral sources
Outpatient facilities may complete assessments and recommend acute care. Support is available through the Provider Emergency Services (PES) hotline at 215-413-7171.
MHOP Clinic Open Access Pilot Program
Access to timely behavioral health services is critical to providing quality services. Many MHOP clinics struggle to achieve the HealthChoices access standard, so CBH has extended the MHOP Clinic Open Access pilot program for its new and established members from July 1, 2023, to December 31, 2023.
Questions or Resources?
Have additional questions or resources to share regarding the MHOP Clinic Open Access Pilot Program? Please contact CBH to help us understand your needs by completing this brief Smartsheet form.
MHOP Learning Collaborative
Consider participating in the MHOP Learning Collaborative! The Mental Health Outpatient Learning Collaborative (MHOP–LC) is a peer-led thought partnership among administrators and practitioners who provide services and programming for the outpatient level of care. The collaborative seeks to provide a supportive space for learning, planning, and evaluating the unique and nuanced set of challenges that arise in the outpatient level of care. Contact CBH’s Provider Training and Development Team for details.