What is Second Impact Syndrome? Heubel Lawsuit Shines Light on Brain Injury
Melissa Dehoff
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.
CMS Issues FY 2024 IRF PPS Proposed Rule
Late yesterday, the Centers for Medicare and Medicaid Services (CMS) issued the fiscal year (FY) 2024 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.
The proposed rule includes a 3.7 percent payment increase, compared to the 3.9 percent payment update that CMS finalized for FY 2023. This payment update reflects the effects of the proposed IRF market basket update for FY 2024 of 3.0 percent, which is based on the proposed IRF market basket increase factor (3.2 percent), productivity adjustment (0.2 percent), and outlier payment increase (0.7 percent).
** Please note that these figures are subject to change in the final rule if updated forecasts become available, which typically occurs.
CMS is making a number of changes to the Quality Reporting Program (QRP), including the future addition of a discharge function score measure and patient-level COVID vaccination measure as well as a modification of the current healthcare personnel COVID-19 vaccination measure to reflect the latest vaccination recommendations.
In addition, CMS is proposing to allow hospitals to open a new IRF unit and begin being paid under the IRF PPS at any time during the cost reporting period (rather than the current restrictive enrollment rules). The proposed rule does not address any of the COVID-19 PHE waivers, including the three-hour rule and virtual team conferences, nor does it include any further discussion of the expanded transfer policy (to include certain discharges under the care of home health) that was the subject of a Request for Information (RFI) in last year’s rule.
A more detailed and extensive summary of the proposed rule will be forthcoming.
The proposed rule will be published in the Federal Register for April 7, 2023. Comments on the proposed rule will be considered until 5:00 pm on June 2, 2023. For additional information, CMS also released a fact sheet.
Transition Plans Released to Phase Out Temporary Changes to CHC Waiver, OBRA, and Act 150
The Office of Long-Term Living (OLTL) has released the transition plans that outline how the Appendix K flexibilities will be phased out on May 11, 2023, with the end of the Public Health Emergency. The transition plans apply to the Community HealthChoices (CHC) Waiver, OBRA Waiver, and Act 150 program.
Since March 6, 2020, the Office of Long-Term Living (OLTL) has been operating under an Appendix K Emergency Preparedness and Response amendment that was approved by the Centers for Medicare & Medicaid Services (CMS). Appendix K allowed temporary changes to the CHC Waiver, OBRA waiver, and Act 150 waiver in response to the COVID-19 Public Health Emergency.
Effective May 11, 2023, OLTL is discontinuing the emergency flexibilities noted in the attached guidance and is returning to pre-emergency operations. Providers should make any changes that are necessary to resume normal operations and be in compliance by May 11, 2023. Service Coordinators have been instructed to work with participants and providers to ensure a seamless transition to normal operations.
The transition plans have been updated to reflect the new expiration date for the flexibilities. In addition, as a general note, resuming pre-emergency waiver operations means the following:
- All assessments, including the comprehensive needs assessments and reassessments, must be conducted face-to-face;
- Service Coordinators must monitor participants and Individual Services Plans (ISPs) through face-to-face contacts; and
- ISP meetings and development must be conducted face-to-face.
Questions about this information should be directed to the OLTL Provider Helpline at 800-932-0939.
CMS Approves OLTL’s OBRA Waiver Amendment
The Centers for Medicare and Medicaid Services (CMS) has approved the Office of Long-Term Living’s (OLTL) OBRA Waiver Amendment. Changes in the approved OBRA Waiver Amendment include:
- Revised the Benefits Counseling service definition;
- Amended the responsibilities of the Fiscal/Employer Agent;
- Updated Appendix H Quality Improvement Strategy to the current process; and
- Removed performance measure AA-6, as the data in AA-6 is being collected by AA-5.
The current approved OBRA Waiver document can be viewed here. If you have any questions, please contact the OLTL Bureau of Policy Development and Communications Management at (717) 857-3280.
CMS Creates Post-Acute Care QRP Videos & Patient Cue Cards
The Centers for Medicare and Medicaid Services (CMS) has created short videos and developed patient cue cards to assist providers with learning how to code patient assessment instruments for the following Post-Acute Care (PAC) Quality Reporting Programs (QRP):
- Long-Term Care Hospital (LTCH), Inpatient Rehabilitation Facility (IRF), Home Health (HH), and Skilled Nursing Facility (SNF): GG0170C. Lying to Sitting on Side of Bed
- LTCH & IRF: Transfer of Health Items
- LTCH: GG0170L. Walking 10 Feet on Uneven Surfaces and GG0170P. Picking Up Object
Help LTCH, IRF, and HH patients select responses by showing them the new cue cards for:
See LTCH, IRF, HH, and SNF Quality Reporting Program Training for more information.
CMS Releases Updated IRF Provider Preview Reports
The Centers for Medicare and Medicaid Services (CMS) has released the updated inpatient rehabilitation facility (IRF) provider preview reports. These reports contain provider performance scores for quality measures and contain IRF-Patient Assessment Instrument (PAI) data submitted by IRFs from Quarter 4 2021 through Quarter 3 2022, as well as Centers for Disease Control and Prevention (CDC) Clostridium Difficile (CDI) and Catheter-Associated Urinary Tract Infections (CAUTI) measures from Quarter 4 2021 through Quarter 1 2022 and Quarter 4 2021 through Quarter 1 2022 of the Healthcare Personnel (HCP) Influenza measure. The HCP COVID-19 Vaccination Coverage measure data for Quarter 3 2022 is also included.
Providers have until April 14, 2023, to review their performance data. Providers can request CMS review their data during the preview period if they believe the scores are inaccurate. The final reports will be published on Care Compare and Provider Data Catalog (PDC) during the June 2023 refresh of the website. For additional information, visit the CMS IRF QRP Public Reporting website.
BIAPA Clinical Forum Presents “Applied Behavior Analysis for Brain Injury Professionals” Webinar on April 25
Presentation From March 24 EVV Public Meeting Available
On March 24, 2023, the Department of Human Services (DHS) conducted a public meeting on Electronic Visit Verification (EVV). The PowerPoint presentation from this public meeting is available. You can view the PowerPoint here.
April 5 MLTSS Subcommittee Meeting Agenda & Registration
The agenda for the April 5, 2023, Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting has been released from the Department of Human Services (DHS) Office of Long-Term Living (OLTL). The meeting is scheduled for 10:00 am – 1:00 pm at the Department of Education’s Honors Suite, 1st Floor, 333 Market St. Harrisburg, PA 17126. The meeting will also be held via webinar and remote streaming.
Included in this meeting will be Dr. Val Arkoosh, Acting Secretary of DHS, who will provide an update on the 2023 DHS priorities.
If you haven’t registered to participate in this meeting, the links and information are below:
Conference line:
Bridge Number: 1-415-930-5321 PIN: 224944600#
Webinar Link
Remote Streaming Link
Annual Review Process in HCSIS Instructions Released
The Office of Long-Term Living (OLTL) has released the fiscal year (FY) 2023/24 annual review instructions for the Home and Community Services Information System (HCSIS). Also included in this reminder for Service Coordination Entities (SCEs) are the procedures, the waiver transfer tip sheet, and the annual review tip sheet. SCEs are reminded that this annual review process is a good time to review their caseloads and finalize any disenrollments or inactive service plans.
If you have any additional questions or wish to receive the attached forms in an alternate format, please contact Brian Lester at (717) 346-0716 or via email.
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