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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 & Medicaid Services (CMS), in partnership with the Department of Labor and the Department of the Treasury (the Departments), included major updates to the health care price transparency rules established during President Trump’s first term in a proposed rule published in today’s Federal Register. The proposed rule is in line with Executive Order 14221, which ensures health care pricing data is not only public but impactful and actionable.

Key improvements include:

  • Requiring plans and issuers to exclude from the In-network Rate Files certain data for services providers would be unlikely to perform.
  • Reorganizing In-network Rate Files by provider network rather than by plan, cutting redundancy, and aligning with how most hospitals report data pursuant to the Hospital Price Transparency requirements.
  • Requiring Change-log and Utilization Files so users can easily identify what has changed from one In-network Rate File to the next and have clear information on which in-network providers are actively furnishing which items and services.
  • Reducing reporting cadence for In-network Rate and Allowed Amount Files from monthly to quarterly, significantly reducing burden while maintaining meaningful transparency.
  • Increasing the amount of out-of-network pricing information reported by reorganizing Allowed Amount files by health insurance market type, reducing the claims threshold to 11 or more claims, and increasing the reporting period from 90 days to 6 months and the lookback period of data from 180 days to 9 months.

The Departments are proposing these changes to open the door for more organizations, including those with fewer technical resources, to analyze pricing data, build consumer-friendly tools, and drive competition across the health care industry.

Under the proposal, group health plans and health insurance issuers would be required to provide the same detailed cost-sharing information whether viewed online, or in print or provided by telephone, upon request. This modernization would ensure that transparency is not limited by internet access or digital literacy. Further, updated disclosures will take into account new federal protections against balance billing under the No Surprises Act. These disclosures would ensure patients understand their rights and potential financial responsibilities before they seek care.

Additional information is provided on the CMS fact sheet. Feedback and comments on the proposed rule will be accepted until February 23, 2026.

The agenda and link to join the January 7, 2026, Long-Term Services and Supports (LTSS) Subcommittee meeting have been released. The call on January 7, 2026, will be held via webinar and remote streaming only and will take place from 10:00 am – 1:00 pm.

A few of the key agenda topics, in addition to an update from the Office of Long-Term Living’s (OLTL) Deputy Security, include information being shared by OLTL on the 2026 OBRA Waiver renewal and the Community HealthChoices (CHC) Waiver amendment. Additionally, there will be a presentation from OLTL’s Enrollment Unit on enrollment and redeterminations/data requests.

To participate in the meeting, the information is below:
Conference line — Bridge Number: 1 (415) 655-0052 PIN: 571-523-182#
Webinar Link
Remote Streaming Link

Comments and questions may be sent electronically.

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The Centers for Medicare and Medicaid Services (CMS) recently published an errata document to the inpatient rehabilitation facility patient assessment instrument (IRF-PAI) Manual, Version 4.2, related to the coding of items J1750, J1800, and J1900. This errata document was issued to update guidance related to the Falls with Major Injury (FMI) measure in the IRF Quality Reporting Program (QRP), which is effective on January 1, 2026. Specifically, the guidance related to item J1900 Number of Falls Since Admission item has revisions to the definition of Injury (except Major) and Major Injury.

CMS also released the official Technical Specification Report for the Falls with Major Injury (FMI) measure. This report incorporates feedback received during the cross-setting Technical Expert Panel (TEP) held in May 2025. The report provides an overview of the measure, a high-level summary of the key features of the re-specified measure, a description of the methodology used to construct the FMI measure, and an overview of measure testing results. Additional guidance and related updates to the IRF-PAI Manual, Quality Measure Calculations and Reporting User’s Manual, and public reporting timelines will be provided at a future date. The report is available in the Downloads section on the IRF QRP Measures Information web page.

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At the December 4, 2025, Medicare Payment Advisory Commission (MedPAC) annual session on payment adequacy for Medicare providers, draft fiscal year (FY) 2027 payment recommendations were issued. The recommendations, “Assessing Payment Adequacy and Updating Payments: Inpatient Rehabilitation Facility (IRF) Services,” were shared. Included in their presentation were their findings on admissions, financial performance by IRF provider type, quality metrics, and other relevant data points. In addition to the payment-focused sessions, the meeting included a general session on post-acute care trends and “key issues,” which compared various patient- and payment-focused data across IRFs, skilled nursing facilities (SNF), and home health agencies (HHA).

During the IRF payment session, MedPAC advanced a draft recommendation calling for Congress to reduce the 2026 Medicare base payment rate for IRFs by 7 percent in FY 2027. This draft recommendation is identical to last year’s recommendation and marks an increase over the FY 2025 recommendation (a 5% cut to the Medicare base payment rate) and the FY 2024 finalized recommendation (3% cut).

MedPAC’s recommendations are advisory in nature, and most of MedPAC’s work can only be implemented via Congressional action. RCPA will monitor the status of these recommendations through close collaboration with the American Medical Rehabilitation Providers Association (AMRPA).

Legislation. Wooden gavel and books in background. Law and justice concept

Representative John Schlegel has introduced a co-sponsorship memo regarding House Bill 2070, Clarifying Dry Needling as an Acceptable Practice within Physical Therapy (PT).

The American Physical Therapy Association (APTA) recognizes dry needling as being within the physical therapist scope of practice. However, Pennsylvania’s Physical Therapy Practice Act (Act 110 of 1975) does not explicitly allow or deny the performance of this type of therapy. This creates a legal gray area and causes uncertainty among licensed physical therapists. Due to the current law’s silence on this treatment technique, legislative clarification is needed.

Dry needling (sometimes referred to as “trigger point dry needling” or “intramuscular manual therapy”) is a treatment method used to relieve muscle pain and stiffness and to improve range of motion. It is important to note that dry needling and acupuncture are not the same, though both are considered needle-based therapies. These procedures have different medical origins, needle placement and application techniques, and serve different purposes.

HB 2070 clarifies that licensed physical therapists may perform dry needling therapy given certain education and training requirements are met and will further specify that dry needling does not include the practice of acupuncture.

A majority of states acknowledge that dry needling is within the scope of practice for physical therapists, including our neighboring states of Delaware, Maryland, New Jersey, Ohio, and West Virginia.

The bill was referred to the House professional licensure committee on December 3, 2025.

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The Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2026 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) final payment system rule. The final rule not only includes policies and payment rates for CY 2026 but also updates CMS’ existing Hospital Price Transparency requirements. Hospitals and ASCs that meet their quality reporting requirements will see a 2.6% increase in their OPPS rates. CMS also finalized proposals to eliminate the Inpatient Only list over a three-year period, beginning with the removal of nearly 300 musculoskeletal procedures from the list in CY 2026.

For additional information, members are encouraged to review CMS’ press release on the rule as well as the fact sheet.