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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) 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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Included in the July 7, 2025, Pennsylvania Bulletin was a notice from the State Board of Physical Therapy (PT) regarding the final-form rulemaking that allows physical therapist students and physical therapist assistant (PTA) students to sit for requisite examinations up to 90 days prior to graduation from their respective programs. It also allows PTs and PTAs to receive a limited amount of continuing education credit for providing clinical instruction to student PTs and student PTAs at clinical facilities affiliated with accredited programs.

In addition, this final-form regulation allows applicants to directly register for the national examination with the examination provider by removing the requirement that the applicant first seek the Board’s permission, and it allows applicants to sit for a third or successive examination, after two failures, without first seeking the Board’s permission.

This final-form regulation became effective on July 7, 2025.

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On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.

If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:

Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.

RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:

Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the ‎reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.

Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following ‎information:‎

  • A copy of the CMS non-compliance letter;
  • A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of ‎calendar year 2024; and
  • If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the ‎monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract ‎Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among ‎Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.

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The Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS/ASC) proposed rule in the July 17, 2025, Federal Register.

The rule outlines new proposed payment rates and related policies for a wide variety of Medicare providers, including not only physicians but other individual Medicare clinicians, such as physical and occupational therapists, speech-language pathologists, nurse practitioners, and physician assistants.

The proposed CY 2026 OPPS/ASC would implement a 2.4% increase to OPPS payment rates that reflects a market basket update of 3.2%, reduced by a productivity adjustment of 0.8 percentage points.

RCPA will provide a more detailed analysis of the OPPS/ASC proposed rule with a focus on the implications for rehabilitation providers. Additional information can be provided on this OPPS fact sheet.

Comments on the proposed rule are due by September 15, 2025. Members are encouraged to share comments and concerns to Melissa Dehoff by September 8, 2025, to include in RCPA’s comment letter.

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The Brain Injury Association of America (BIAA) has announced the webinar Acquired Brain Injury (ABI): A Transdisciplinary Approach to Inpatient Rehabilitation, which is scheduled for July 24, 2025, at 3:00 pm.

During this live webinar, a team from the Sheltering Arms Institute will share the inner workings of their transdisciplinary system of care. As it becomes more important than ever for clinicians to work as a transdisciplinary team to provide the best care for patients, the close coordination of care between therapy, nursing, medical staff, psychology, and case management is necessary in order to make the greatest impact.

The live webinar has a fee of $50.00. Those interested can register here.

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The Long-Term Services and Supports (LTSS) Subcommittee meeting was recently held on July 2, 2025. During the meeting, a number of presentations were given. In addition to the presentations, the agenda and a document that provided follow-up information from the June 4, 2025, LTSS Subcommittee meeting were provided.

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

The next LTSS Subcommittee meeting is scheduled for August 6, 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: (631) 992-3221; Access code: 625-783-611#.

Remote captioning and streaming services will be provided. If you require these services, please visit this remote captioning and streaming link.

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The National Association of State Head Injury Administrators (NASHIA) will be conducting a free webinar, “Addressing the Intersection of Brain Injury, Aging, and Behavioral Health,” on July 16, 2025, from 12:00 pm – 1:15 pm. Register here.

As the population ages, the overall rate of brain injury in older adults in the US is increasing, and the intersection of brain injury and behavioral health becomes an increasingly critical topic. Brain injury can have long-lasting cognitive, behavioral, and emotional effects for older adults. Certain predisposing factors can make it more likely for an older adult to experience behavioral health challenges after a BI, including sleep problems, anxiety, substance use disorders, low income, negative thinking, and poor social functioning. A brain injury can increase the symptoms of a pre-existing behavioral health disorder. Secondary factors can complicate behavioral health conditions, such as loss of employment, inability to drive, sleep issues, relationship problems, and social isolation.

This webinar will provide an overview on the relationship between aging, brain injury, and behavioral health, highlighting the unique challenges older adults face and the strategies that can improve their quality of life. A brief introduction to the Aging and Behavioral Health Guide will be given, and attendees will learn more about tools and interventions that can support their work. National organizations who conduct work with the Aging Network and Mental Health Systems will provide tips for initiating or improving partnerships within both state aging networks and behavioral health systems.

Attendees do not need to be a member of NASHIA, and the webinar is free of charge (unless applying for a certificate of attendance or social work CEs).

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The Office of Long-Term Living (OLTL) released a communication that focused on the update to the Health and Welfare Performance Measure #8 (HW-8) that was included in the OBRA Waiver amendment that was approved by the Centers for Medicare and Medicaid Services (CMS) and took effect on January 1, 2025. The update includes:

Number and percent of incidents for waiver participants each month with more than three reported incidents within the past 12 months where results of trend analysis were addressed by the Service Coordinator (SC). Numerator: Total number of incidents for waiver participants each month with more than three reported incidents within the past 12 months where results of trend analysis were addressed by the SC. Denominator: Total number of incidents for waiver participants with reported incidents within the past 12 months where a trend analysis was performed.

In accordance with this requirement, for any participant with more than three critical incidents within a 12-month period, the Service Coordinator (SC) must perform an analysis (trend analysis) and take action as necessary to prevent or mitigate further incidents. The SC must commence the analysis and implement the actions to address potential issues related to the health and welfare of the Participant within the 30-day investigation period. If additional time is needed to investigate and to implement any necessary actions to address potential issues related to the health and welfare of the Participant, the SC must document an extension in Enterprise Incident Management (EIM). The trend analysis document must be provided to a Critical Incident Management Unit (CIMU) team member for review upon request and subsequently uploaded to the respective EIM entry upon completion and submission of the critical incident report’s final section. If necessary, OLTL’s CIMU staff will provide additional feedback to the SC via the State Management Review in EIM.

For any questions regarding this change, please contact the CIMU via the resource account. Additionally, questions related to critical incidents may be emailed to the CIMU team member identified in any case-specific communication.

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The House Energy & Commerce Committee will hold a hearing on June 24, 2025, regarding the Department of Health and Human Services’ (HHS) fiscal year (FY) 2026 budget. The hearing will begin at 10:00 am, and Secretary of HHS Robert F. Kennedy, Jr. is expected to serve as witness and provide testimony on the President’s proposed budget.

The hearing is open to the public and will be livestreamed online using the link above.

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