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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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On September 23, 2025, the Centers for Medicare and Medicaid Services (CMS) issued a policy clarification related to the qualifications for speech-language pathologists (SLP) when furnishing Part B outpatient therapy services.

These Part B services include speech-language pathology services that:

  1. Are furnished by SLPs in private practice (SLPPPs) who submit professional claims; and
  2. Are furnished and billed by providers of outpatient therapy services as defined at 42CFR489.2.

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The agenda for the October 1, 2025, virtual Long-Term Services and Supports (LTSS) Subcommittee meeting has been released. The meeting will be held from 10:00 am – 1:00 pm. Information specific to this meeting is below:

Comments and questions should be sent electronically.

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On September 24, 2025, WellSky will be conducting a webinar on the fiscal year (FY) 2026 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was released by the Centers for Medicare and Medicaid Services (CMS) in early August. The webinar will begin at 12:00 pm. There is no cost to participate in this webinar.

Topics will include:

  • The key changes in the 2026 IRF Final Rule impacting reimbursement;
  • The technical changes and their indirect effects on your program;
  • The amendments to the QRP and the appeal process; and
  • The latest concerns about potential IRF reimbursement denials.

To participate in the webinar, register here.

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Due to budget constraints, the Office of Long-Term Living (OLTL) has announced a change to the upcoming Long-Term Services and Supports (LTSS) Subcommittee meeting. The next LTSS Subcommittee meeting on Wednesday, October 1, will be held as a webinar with remote streaming only, from 10:00 am to 1:00 pm. To register for the webinar, please use this webinar registration link. After registering, you will receive a confirmation email containing information about joining the webinar.

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Replay icon on wooden cubes on smart grey background and copy space. Recap business, meeting summary, business review concept.

The Long-Term Services and Supports (LTSS) Subcommittee meeting was recently held on September 3, 2025. During the meeting, a number of presentations were given. In addition to the presentations, the agenda and a document that provided follow-up items from the August 6, 2025, LTSS Subcommittee meeting were provided.

Members should take time to review the PowerPoint presentation from the meeting below:

The next LTSS Subcommittee meeting is scheduled for Wednesday, October 1, 2025. The meeting will be held from 10:00 am – 1:00 pm in the Forest Room at the Commonwealth Keystone Building, which is located at 400 North Street in Harrisburg, PA.

The option to participate virtually is also available. If attending virtually, please register here. After registering, you will receive a confirmation email containing information about joining the webinar. The option to call in is also available by dialing 562-247-8321; Access code: 930-608-721#.

Remote captioning and streaming services will be provided: Remote Captioning and Streaming Link.

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The Centers for Medicare and Medicaid Services (CMS) finalized the fiscal year (FY) 2026 inpatient rehabilitation facility (IRF) payment rule and published it in today’s Federal Register.

The final rule is a fairly straightforward payment and coverage rule, similar to the April 2025 proposed rule. The payment and IRF Quality Reporting Program (IRF QRP) updates are outlined below.

Payment: CMS expects an aggregate increase of $340 million in payments to IRFs across the PPS. This reflects an increase of approximately 2.6% in estimated payments, including all relevant adjustments.

Quality Reporting Program (QRP):

  • CMS finalized the removal of two quality measures: (1) the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, beginning with the FY 2026 IRF QRP, and (2) the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure, beginning with the FY 2028 IRF QRP. IRFs will continue to have the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure data collection item in the IRF-PAI until October 1, 2026, with CMS making the data collection voluntary and removing Q4 2025 data for this measure from the FY 2027 IRF QRP Compliance Determinations. CMS took similar action in other recently finalized payment rules. CMS also finalized their proposals to end the public display of these measures following the September 2025 Care Compare refresh.
  • CMS finalized the removal of four Standardized Patient Assessment Data Elements (SPADEs) under the Social Determinant of Health (SDOH) category with the FY 2028 IRF QRP, specifically: Living Situation (R0310), Food (R0320A and R0320B), and Utilities (R0330).
  • CMS finalized its procedural and review-focused changes to the IRF QRP reconsideration process. First, CMS will permit IRFs to request, and CMS to grant, an extension to file a request for reconsideration of a non-compliance determination if, during the 30-day period to request a reconsideration, the IRF was affected by an extraordinary circumstance beyond the control of the IRF (for example, a natural or man-made disaster). Second, CMS is finalizing its proposed updates to the bases on which CMS can grant a reconsideration request, providing that CMS will grant a timely request for reconsideration, and reverse an initial finding of non-compliance, only if CMS determines that the IRF was in full compliance with the IRF QRP requirements for the applicable program year.
  • CMS noted that it received extensive feedback on its Requests for Information (RFI) in four separate domains: (1) future measure concepts for the IRF QRP; (2) potential revisions to the IRF Patient Assessment Instrument (IRF-PAI); (3) potential revisions to the data submission deadlines for assessment data collected for the IRF QRP; and (4) advancing digital quality measurement in IRFs.

Requests for Information:
The rule included four dedicated Requests for Information (RFI) related to the IRF QRP and IRF-PAI. The final rule summarized the comments they received on these topics but did not offer any commentary on what CMS plans to do in future work in these areas.

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