Sunday, April 7, 2019

Right to Know Law Request to PA Department of Human Services re: 15 minute minimum for a brief medication visit

March 31, 2019

Department of Human Services
Health and Welfare Building, Room 234
Harrisburg, Pennsylvania 17120
Attention: Andrea Bankes

Your § 5200.48, from Your Regulation § 1153.52 (c) (1). Payment conditions for various services. “Psychiatric clinic medication visits shall be a minimum duration of 15 minutes.”

I request the following information about the above regulation. Please, provide it in electronic form. Do not make any paper copies.
1) All communications about the justification for such a rule, including internal DHS communications, the record of all outside commentary about the rule, and whether and how all other requirements of the Pennsylvania Administrative Procedure Act (“Act”) found in Title 2, Chapter 1, 5 and 7 of the Pennsylvania Annotated Statutes were followed;
2) the payment for each such visit by PA Medicaid, and by its managed care providers;
3) the total number of such visits in 2016, 2017, 2018;
4) the total number of such visits in the three years prior to the adoption of this regulation and the total payment for those visits;
5) the total number of payments for such visits denied by PA Medicaid managed care because they were shorter than 15 minutes, for 2016, 2017, 2018;
6) any internal legal analysis justifying such denials, since a service was rendered;
7) any internal legal analysis as to the legal nature of such managed care companies, are they private contractors, are they quasi-governmental organizations with police powers to deny payments, to punish people out of compliance with a PA regulation?

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