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Authors Posts by Melissa Dehoff

Melissa Dehoff

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Melissa Dehoff is responsible for all medical rehabilitation and brain injury service issues. Ms. Dehoff attends multiple state-level meetings to advocate on behalf of members on brain injury and rehabilitation issues and is a member of the Department of Health Traumatic Brain Injury Advisory Board.

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The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2024 inpatient rehabilitation facility (IRF) prospective payment system (PPS) final rule in the August 2, 2023, Federal Register. Some of the key provisions contained in the final rule include:

Payment and Coverage Provisions

  • FY 2024 Market Basket Update and Productivity Adjustment: For the FY 2024 IRF PPS payment adjustments, CMS estimates that ‎IRFs will see a 4.0 percent increase in total payments (totaling an increase of $355 million) ‎relative to FY 2023. This update is a result of a 3.6 percent market basket update, minus a ‎‎0.2 percent productivity adjustment.
  • 2021-Based IRF Market Basket: The final rule rebases and revises the IRF market ‎basket to reflect a 2021 base year (which reflects more recent data). ‎Moving forward, CMS says that it will “continue to monitor the Medicare cost report ‎data as they become available” and consider updates to the IRF market basket in future ‎rulemaking.‎
  • Case Mix Groups: Consistent with the proposed rule, CMS estimates that the vast ‎majority of cases will be in case mix groups (CMGs) and tiers that will see a ‎change of less than 5 percent in FY 2024. ‎
  • Outlier Threshold: CMS is finalizing the outlier threshold amount of $10,423, which is estimated to be ‎approximately 3 percent of the total estimated aggregate IRF payments in 2024. CMS also ‎notes that finalized changes in the Average Length of Stay (ALOS) values for FY 2024, ‎compared with FY 2023 ALOS values, are small and do not show any particular trends ‎in IRF length of stay patterns.
  • Wage Adjustments and Labor-Related Share: CMS finalized proposals to update the ‎wage index adjustments using the same methodology and factors as previous updates. ‎Based on forecasts, the total labor-related share for FY ‎‎2024 is 74.1 percent (the sum of 70.3 percent for operating costs and 3.8 percent for the labor-related share ‎of Capital-Related costs).
  • Impact Estimate: Overall, the estimated payments per discharge for IRFs in FY 2024 ‎are projected to increase by 4.0 percent, compared with the estimated payments in FY 2023. ‎IRF payments per discharge are estimated to increase by 4.0 percent in urban areas and 3.6 percent ‎in rural areas, compared with estimated FY 2023 payments. Payments per discharge to ‎rehabilitation units are estimated to increase 4.5 percent in urban areas and 3.9 percent in rural ‎areas. Payments per discharge to freestanding rehabilitation hospitals are estimated to ‎increase 3.7 percent in urban areas and 2.8 percent in rural areas.‎
  • Modifications for Excluded IRF Units: Consistent with the proposed rule, CMS is ‎finalizing new flexibilities for rehabilitation units that are seeking to be excluded from ‎the acute inpatient PPS and paid under the IRF PPS for the first time. Hospitals will now ‎be allowed to open a new IRF unit (and get paid as such) at any time within the cost ‎reporting year, instead of being limited to only the beginning of a cost reporting period. ‎The hospital must notify the CMS Regional Office and Medicare Administrative ‎Contractor (MAC) in writing at least 30 days before the change. If a unit becomes ‎excluded during a cost reporting year, that change must remain in effect at least through ‎the rest of that cost reporting period. ‎

Quality Reporting Program (QRP) Provisions: ‎CMS finalized all of the proposed changes related to quality measures for the IRF QRP put forth in the proposed ‎rule. The following changes have been finalized for the IRF QRP:

  • Implementation of the New COVID-19 Vaccine for Patients: Data collection for the ‎‎“Percent of Patients/Residents Who Are Up-to-Date” will be placed on an updated IRF-‎Patient Assessment Instrument (PAI) and begin with discharges on or after October 1, 2024, for use in the FY 2026 IRF ‎QRP.‎
  • Update of the COVID-19 Vaccination Measure for Healthcare Personnel: CMS ‎finalized its proposed modification of the COVID-19 Vaccination Coverage among‎ ‎Healthcare Personnel (HCP COVID-19 Vaccine) measure‎ to include the CDC “up-to-‎date” consideration for reporting purposes. Data collection for this modification is to ‎begin October 1, 2023, for use in the FY 2025 IRF QRP.‎
  • Implementation of the New Discharge Function Score Measure: No new data ‎collection is required, but the calculations and reporting of this measure will begin with ‎discharges on or after October 1, 2023, for use in the FY 2025 IRF QRP.‎
  • Measure Removal: Three measures have been removed from the IRF QRP and will no ‎longer require the collection of certain data elements for discharges on or after October ‎‎1, 2023:‎
    • Application of Percent of Long-Term Care Hospital Patients with an Admission ‎and Discharge Functional Assessment and a Care Plan That Addresses Function;
    • IRF Functional Outcome Measure: Change in Self-Care Score for Medical ‎Rehabilitation Patients (CBE #2633)‎; and
    • IRF Functional Outcome Measure: Change in Mobility Score for Medical ‎Rehabilitation Patients (CBE #2634)‎.
  • New Public Reporting: CMS announced the start of public reporting for the following ‎measures:‎
    • Transfer of Health (TOH) Information to the Provider — Post-Acute Care (PAC) ‎Measure (TOH-Provider) beginning with September 2025 Care Compare refresh ‎‎(even though proposed rule and other language in final rule stated September ‎‎2024 Care Compare refresh)‎. CMS staff has been alerted to this discrepancy.
    • TOH Information to the Patient — PAC Measure (TOH-Patient) beginning with ‎September 2025 Care Compare refresh (even though proposed rule and other ‎language in final rule stated September 2024 Care Compare refresh)‎.
    • Discharge Function Score Measure — Beginning with the September 2024 Care ‎Compare refresh or as soon as technically feasible.‎
    • COVID-19 Vaccine: Percent of Patients/Residents Who Are Up-to-Date Measure — Beginning with the September 2025 Care Compare refresh or as soon as ‎technically feasible.‎

CMS also released a fact sheet on the final rule. The data files associated with the final rule, including the wage index tables, the rate setting data for each IRF, and the ‎final tables for case-mix groups, relative weights, and average lengths of stay are also available. Unless otherwise ‎noted above, the provisions in the final rule will take effect on October 1, 2023. ‎

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Caregiver supporting sick elderly man in the wheelchair during stay in the hospice

The U.S. Department of Health and Human Services (HHS), through the Centers for Medicare and Medicaid Services (CMS), announced the new Guiding an Improved Dementia Experience (GUIDE) Model. The purpose and goal of this model is to improve the quality of life for people living with dementia, reduce strain on unpaid caregivers, and help people remain in their homes and communities through a package of care coordination and management, caregiver education and support, and respite services.

Through the GUIDE Model, CMS will test an alternative payment for participants who deliver key supportive services to people with dementia, including comprehensive, person-centered assessments and care plans, care coordination, and 24/7 access to a support line. Under the model, people with dementia and their caregivers will have access to a care navigator, who will help them access services and supports, including clinical services and non-clinical services such as meals and transportation through community-based organizations.

The GUIDE model supports President Biden’s Executive Order that directed HHS to develop a new health care payment and service delivery model focused on dementia care that would include family caregiver supports.

There is a web page that has been created specific to this care model that provides additional information, including a link to a webinar that will provide an overview of this care model scheduled for August 10, 2023:

CMS will release the application for GUIDE, a voluntary, nationwide model, in the fall of 2023. Prior to the application release, interested organizations are encouraged to submit Letters of Intent to CMS by September 15, 2023. The model will run for eight years beginning July 1, 2024.

If you are interested in receiving additional information, updates or have questions about the GUIDE model, please send an email to the GUIDE Model team’s inbox.

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The next Managed Long-Term Services and Supports (MLTSS) Subcommittee is scheduled for August 2, 2023, from 10:00 am – 1:00 pm. The meeting will be held in the Honors Suite, 1st Floor, 333 Market St., Harrisburg, PA 17126. Participation is also available by conference call, via webinar, or through remote streaming. Please see the information below:

Conference Line:
Bridge Number: 1-213-929-4212
PIN: 445023599#
Webinar Link
Remote Streaming Link

View the agenda for the August 2 meeting here. Questions about the meeting should be sent in via email.

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The Americans with Disabilities (ADA) Act passed in 1990. As the country celebrates the upcoming 33rd anniversary of the ADA, the Federal Emergency Management Agency (FEMA), with the guidance of the ADA, has committed to improving services and programs to be uniformly available to individuals with disabilities and others with access and functional needs.

To support the disability community, FEMA made equity in emergency management one of the top goals in its 2022–2026 Strategic Plan. In support of this plan, the agency has:

  • Improved the survivor registration intake process nationwide, expanding disability-related questions and making it easier for people with disabilities impacted by disasters to get the assistance they need.
  • Continued updating the FEMA App, available in English and Spanish, so that it is now more accessible to people with disabilities. The app is screen reader compatible on iOS (11.0 and later) and Android (5.0) devices. The user interface has also been redesigned to fit a wider variety of screen sizes, making it easier for users to interact with it on their preferred device.
  • Worked extensively with state, local, tribal and territorial officials, and nongovernmental and private sector partners and stakeholders to facilitate ADA compliance. This includes removing physical, communication, and programmatic barriers that people with disabilities could face.
  • Designed programs, services, policies, and procedures to include the needs of people with disabilities before disasters happen, rather than solely reacting to barriers that are identified during response and recovery.

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Governor Shapiro’s office published a list of regulations being considered by the state agencies in the Pennsylvania Bulletin on July 22, 2023. The document lists regulations being drafted by state agencies that cover a wide variety of activities under oversight of the state government. Under Executive Order 1996-1, all agencies under the jurisdiction of the Governor must submit for publication semi-annually an agenda of regulations under development or consideration. This list is current as of July 15, 2023.

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Photo by Markus Winkler on Unsplash

RCPA has received notification from PA Health & Wellness (PHW) regarding an update to the prior authorization process for Residential and Structured Day Habilitation services. The updates included in the notice are effective starting August 1, 2023.

Questions regarding this update should be directed to PHW’s Provider Services at 844-626-6813 or to Provider Relations via email.

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The Centers for Medicare and Medicaid Services (CMS) released a revised Medicare Learning Network (MLN) fact sheet on telehealth services. A number of changes have been made due to the end of the public health emergency (PHE), including the following items:

  • Information on the end of the COVID-19 public health emergency as well as CY 2023 and telehealth policies.
  • Status of Ongoing Flexibilities:
    • Through December 31, 2024, all patients can get telehealth wherever they are located. They do not need to be at an originating site, and there are no geographic restrictions.
    • Through December 31, 2024, all providers who are eligible to bill Medicare for professional services can provide distant site telehealth.
    • For behavioral or mental health telehealth, you may use 2-way, interactive, audio-only technology. This is also part of the PA Telehealth Statute under Act 98.
  • Additional Resources Provided:
    • Chapter 12, Section 190 of the Medicare Claims Processing Manual
    • Telehealth Policy Changes After the COVID-19 PHE
    • Tips for Telehealth Success
  • Added information on:
    • New G-codes. Starting January 1, 2023, you may voluntarily report the use of telehealth technology in providing home health (HH) services on HH payment claims. See MLN Matters Article MM12805 for more information.
    • Consent for care management and virtual communication services.

Providers are encouraged to review this document closely and bookmark it for future reference.

As RCPA continues its efforts to expand access via telehealth in Pennsylvania, we will be submitting comments on the new Calendar Year (CY) 2024 Physician Fee Schedule (PFS). RCPA will be sending out a communication on this in the coming days.

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The Centers for Medicare and Medicaid Services (CMS) has released a number of additional and updated documents related to the inpatient rehabilitation facility (IRF) review choice demonstration (RCD). Included in these documents are:

  • An updated and revised Operational Guide — Clarifies key programmatic details regarding the different review choices and other facets of the demonstration.
  • Frequently Asked Questions Document — The FAQ focuses on major areas of confusion on the choice selection and submission processes, the Pre-Claim Review Track, and medical necessity determinations.
  • Transcript and Recording — From the June 27, 2023, special open-door forum on the IRF RCD.

Additional information about the IRF RCD can be found on the CMS IRF RCD web page.

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Temple University Harrisburg will be offering some no-cost training options that are approved to meet Personal Care Home (PCH) and Assisted Living Residence (ALR) Administrator annual training requirements. The training sessions that will be offered in the fall include:

Interested individuals need only to register for one session for each topic. Please read the training announcements in full before registering to ensure you can meet the participation requirements.

Please only register for these sessions if you are sure you will be able to complete them, as participation is limited for each course. If you register and later discover you are unable to participate, please cancel your registration to create space for other participants.

If you have any questions about these trainings or if you require assistance with registration, you can email Temple University. If you would like information about additional trainings available for PCH and ALR administrators, please contact the Bureau of Human Services Licensing Operator Support Hotline via email.

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