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Authors Posts by Fady Sahhar

Fady Sahhar

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Fady is responsible for policy and regulatory matters related to Physical Disabilities and Aging, with primary focus on personal assistance, employment services, and service coordination. Emphasis is placed on engaging the Office of Long-Term Living and the Community HealthChoices Managed Care Organizations, coordination of care with Behavioral HealthChoices MCOs, and collaborations with other advocacy and provider associations. Fady is also the President / CEO of ProVantaCare, an RCPA-affiliated company focused on contracting with MCOs, and is the President of XtraGlobex, a consulting firm focused on Value-Based Payment contracting. He brings extensive experience in the advocacy and operations of human services providers in physical disabilities and aging, from his role at Liberty Resources, Inc., and his service with a number of nonprofit services providers. He earned an MBA in Marketing from The University of Tennessee and a PhD in Organizational Leadership from Capella University.

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The United States Department of Agriculture (USDA) is recognizing National Rural Health Day today to applaud the many contributions of rural communities and address the unique challenges that they face in accessing and delivering healthcare services. To celebrate, we are highlighting ways that we are working with rural leaders and our partners to increase access to critical healthcare across rural America. Learn more below.

USDA Leadership Discusses Rural Healthcare:

Real Stories of Small Towns Undergoing Big Changes:

Do you need help accessing rural healthcare funding opportunities?

For more information about National Rural Health Day, visit this webpage.

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Electronic Visit Verification (EVV) for Personal Care Services (PCS) Bulletin 07-20-04, 54-20-04, 59-20-04,00-20-03 outlines compliance requirements when manual edits are required to correct EVV visit data. The bulletin includes the following language addressing documentation for manual corrections:

  1. Visit Corrections and Documentation for Manual Corrections
  • If EVV visits require manual corrections or edits due to missing or incorrect data elements, providers must maintain hard copy documentation of the manual corrections for auditing purposes. Hard copy documentation is a paper copy.
  • Providers are to establish policy on documentation required to meet auditing requirements and standards as well as organization needs.

The intent of this requirement is to ensure that providers are prepared to provide physical documentation (hard copy) of the reason for manual corrections if requested during an on-site audit. Providers have flexibility in how to implement this requirement as long as physical documentation can be provided upon request. This statement does not dictate that providers must use paper time sheets; however, that is one option to satisfy this requirement. If documentation is kept electronically, such as in the provider’s EVV system, providers must be capable of producing hard copies of this documentation as requested.

Questions on the bulletin or this bulletin clarification should be directed here.

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Governor Wolf signed Act 24 of 2020, which allocates funding from the Federal Coronavirus Aid, Relief, and Economic Security Act – also known as the CARES Act – to assist providers with COVID-19 related costs. Funding from Act 24 must be used to cover necessary COVID-19 related costs incurred between March 1, 2020 and November 30, 2020 that have not been otherwise reimbursed by Federal, State, or other sources of funding. To qualify for the one-time payment, a person or entity must have been in operation as of March 31, 2020. Under Act 24, $457 million of COVID-19 relief funds were allocated to providers of long-term living programs.

Any person or entity accepting a COVID-19 payment must provide documentation to the Department of Human Services (DHS) upon request for purposes of determining compliance with Act 24 requirements. Providers were previously advised to keep documentation to demonstrate how the funds were used for a response to the COVID-19 pandemic in case of an audit.

DHS has developed the attached reporting forms to collect information about the use of Act 24 funding. The reporting forms capture provider information; COVID-19 utilization related data; COVID-19 related staffing, expenditures, and revenue losses; and COVID-19 related revenue to determine the net impact. Providers are advised to review guidance for eligible COVID-19 costs on the US Department of Treasury website:

DHS is requesting the following two reports from the Office of Long-Term Living (OLTL) providers:

  1. An interim report, which identifies the total COVID-19 related costs each provider projects to incur by November 30, 2020. This interim report is due by November 6, 2020. To assist providers in projecting eligible costs, DHS recommends using the cost report attached and reporting costs that appear in cells H120 and H165. Providers must report the projected costs through a web-based portal.
  1. Providers are required to complete a final cost report and upload it through the web-based portal by no later than December 21, 2020. Providers must keep all documentation related to the costs reported in the final cost report for a minimum of five years.

Cost Reporting Forms:

In advance of the reports’ due date, DHS recommends that providers review the attached cost-reporting form and instructions and begin compiling the required information. Information on how to access the web-based reporting portal will be sent through a separate email.

Thank you for your ongoing assistance during these trying times. Please submit any questions about OLTL Act 24 expense reporting via email.

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Senior Woman Being Served Meal By Carer

This communication is to provide notice to Nursing Home Transition (NHT) Coordination Agencies (NHTCAs) of a proposed change to NHT Tenant-Based Rental Assistance (TBRA). It will also provide an opportunity to offer comments or feedback. Please review this brief notice and offer any comments or questions by the close of business on Wednesday, October 28, 2020.

Earlier this year, the rules for NHT one-time TBRA were modified to allow that, in the event that a landlord cannot or does not wish to provide the information necessary to make the payment via direct deposit, the payment may be directed to the NHTCA assisting with the application. The NHTCA would then be responsible for providing the payment to the landlord.

 

A change has been proposed, which would require each application and payment to be handled as described above. The one-time TBRA payment would be directed to the NHT Coordination Agency instead of the landlord. The NHTCA then would be responsible for providing the payment to the landlord. This change is expected to make the application and payment process faster and more efficient.

 

Please note that this change would apply only to one-time TBRA payments. Any payments still going to landlords through the now discontinued bridge TBRA payment would continue to be made to those existing landlords for up to 24 months.

If you have any questions, comments, or feedback about this proposed change, including the feasibility of this arrangement for your agency or concerns about any negative outcomes this change might cause, please email your feedback to Rachel Sink no later than the close of business on Wednesday, October 28, 2020.

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If providers have not already started implementing Electronic Visit Verification (EVV), providers are at risk at being out of compliance on January 1, 2021.

All claims and encounters for personal care services (PCS) subject to EVV requirements for dates of service on or after January 1, 2021 must have a corresponding EVV visit or claims payment will be impacted. Manual editing compliance rates will also go into effect on January 1, 2021. Please reference the recently released Electronic Visit Verification (EVV) for Personal Care Services bulletin and Electronic Visit Verification for Personal Care Services Provided in the Fee-for-Service Delivery System bulletin for additional details.

Alternate/Third Party EVV Systems

Fee-For-Service providers using an Alternate EVV system who have not already reached out to begin the Aggregator Certification process must contact Sandata Alternate EVV support team by phone at 855-705-2407 or by email as soon as possible to begin this process. Providers must receive their production credentials and confirm their EVV data is viewable in the Aggregator Portal to complete the certification process.

Community HealthChoices (CHC) Providers

All CHC providers must be actively working with the CHC-Managed Care Organizations (MCOs) to ensure they are in compliance with all EVV requirements. If your agency has not already started collecting EVV data and sending the appropriate data to each contracted MCO, please reach out to the MCOs as soon as possible to begin this process.

Providers Electing to use the Department of Human Services (DHS) Sandata EVV System

Providers electing to use the DHS Sandata EVV system must complete Sandata’s “Pennsylvania DHS – Electronic Visit Verification (EVV) Self-Paced Training for Agency Providers” training in order to receive credentials to use the system for OBRA, Act 150, and Offices of Developmental Programs and Medical Assistance Programs fee-for-service participants. Please begin this process as soon as possible by completing the sign-up form.

Upon completing the self-paced training, providers will be issued a Welcome Kit, including their agency’s production credentials. Providers must setup their agency and direct care workers in the EVV Provider Portal and train the rest of their staff on how to use the system, including the Sandata Mobile Connect™ application and telephonic visit verification (TVV) visit capture modalities to their direct care workers.

If you have any questions, please email them here.

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The Electronic Visit Verification (EVV) public meeting scheduled for tomorrow, October 23, 2020, has been canceled. An email communication with EVV updates will be sent next week via the EVV Listserv.

The next EVV public meeting will be held on November 20, 2020, from 2:00 pm to 4:00 pm. You can register for this meeting on the EVV Public Meetings Registration site.

Any questions about this communication should be sent to this email.

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We are pleased to announce the Medicaid Management Information System (MMIS) 2020 Platform Project website is now live! The direct link to the MMIS 2020 homepage is: https://www.dhs.pa.gov/MMIS/Pages/default.aspx.

You may have also noticed the previous MMIS 2020 webpage link, located within the Providers > Sort by Industry section of the Department of Human Services (DHS) website, now appears as “*New* MMIS 2020.” This link will now take you to the new MMIS 2020 website.

What’s New?

Within the new MMIS 2020 website, you will find the following pages which contain topic-specific information related to the project:

  • About MMIS – Overview of the MMIS 2020 Platform Project
  • Our Team – Information about the MMIS 2020 employees and contractors, such as the Information Technology Consulting/Quality Assurance (ITC/QA), System Integrator/Data Hub (SI/DH), and Electronic Data Interchange (EDI) contractors
  • Key Dates – MMIS 2020 Procurement Dates
  • News – Recent MMIS 2020 Platform news and events, such as Release A updates
  • Development – Information detailing the process of developing a replacement MMIS
  • Managing Change – Information on Organization Change Management
  • MMIS FAQ – Frequently Asked Questions about the MMIS 2020 Platform Project
  • Contact MMIS – Contact information for general MMIS questions/inquiries, procurement questions, and website/technical issues

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New recoupment terms allow providers and suppliers one additional year to start loan payments.

CMS announced amended terms for payments issued under the Accelerated and Advance Payment (AAP) Program as required by recent action by President Trump and Congress. This Medicare loan program allows CMS to make advance payments to providers, which are typically used in emergency situations. Under the Continuing Appropriations Act, 2021 and Other Extensions Act, repayment will now begin one year from the issuance date of each provider or supplier’s accelerated or advance payment. CMS issued $106 billion in payments to providers and suppliers in order to alleviate the financial burden health care providers faced while experiencing cash flow issues in the early stages of combating the Coronavirus Disease 2019 (COVID-19) public health emergency.

“In the throes of an unprecedented pandemic, providers and suppliers on the frontlines needed a lifeline to help keep them afloat,” said CMS Administrator Seema Verma. “CMS’ advanced payments were loans given to providers and suppliers to avoid having to close their doors and potentially causing a disruption in service for seniors. While we are seeing patients return to hospitals and doctors providing care we are not yet back to normal,” she added.

CMS expanded the AAP Program on March 28, 2020, and gave these loans to health care providers and suppliers in order to combat the financial burden of the pandemic. CMS successfully paid more than 22,000 Part A providers, totaling more than $98 billion in accelerated payments. This included payments to Part A providers for Part B items and services they furnished. In addition, more than 28,000 Part B suppliers, including doctors, non-physician practitioners, and durable medical equipment suppliers received advance payments totaling more than $8.5 billion.

Providers were required to make payments starting in August of this year, but with this action, repayment will be delayed until one year after payment was issued. After that first year, Medicare will automatically recoup 25% of Medicare payments otherwise owed to the provider or supplier for 11 months. At the end of the 11-month period, recoupment will increase to 50% for another 6 months. If the provider or supplier is unable to repay the total amount of the AAP during this time-period (a total of 29 months), CMS will issue letters requiring repayment of any outstanding balance, subject to an interest rate of 4%.

The letter also provides guidance on how to request an Extended Repayment Schedule (ERS) for providers and suppliers who are experiencing financial hardships. An ERS is a debt installment payment plan that allows a provider or supplier to pay debts over the course of 3 years, or, up to 5 years in the case of extreme hardship. Providers and suppliers are encouraged to contact their MAC for information on how to request an ERS. To allow even more flexibility in paying back the loans, the $175 billion issued in Provider Relief funds can be used towards repayment of these Medicare loans. CMS will be communicating with each provider and supplier in the coming weeks as to the repayment terms and amounts owed as applicable for any accelerated or advance payment issued.

For More Information:

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