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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 Brain Injury Association of America (BIAA) recently shared information on a live Question & Answer (Q&A) session with the Brain Injury Specialists who manage the National Brain Injury Information Center (NBIIC) on September 13, 2024, at 1:00 pm. Greg Ayotte, CBIST, and Heather Matty, CBIS, will discuss the latest developments in brain injury research, how you can participate in research studies, and more.

If you have a question about brain injury research that you would like to have answered during this event, members are encouraged to submit it here, followed by filling out the form on the page.

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The Centers for Medicare and Medicaid Services (CMS) has released an informational bulletin, as well as a slide presentation, that are related to continuity of coverage for individuals receiving home and community-based services (HCBS). The purpose of the bulletin is to highlight the federal renewal requirements and available flexibilities to promote continuity of coverage.

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

An Elder Boom is Coming, Are We Ready to Care for the Aged?
Geoff Gross, Philadelphia, founder and CEO of Medical Guardian

Aging adults are at the center of many strategic conversations lately and I hope that continues. According to the Pennsylvania Department of Aging, the population of Pennsylvanians aged 60 and over is projected to surpass 3.8 million by 2030 — the fifth highest in the country — accounting for one in three Pennsylvanians. Soon, older Pennsylvanians are expected to outnumber every other age group which is unprecedented in U.S. history, according to the Population Reference Bureau (PRB).

This dramatic demographic shift impacts strategic planning and product development in all industries from housing, to health care, and beyond. How older adults are living is also shifting. Instead of slowing down, aging adults are demonstrating that aging can be an exciting period of growth, reinvention and maintained independence. This shift in lifestyle also requires a deep rethinking of how to support older adults.

Fortunately for Pennsylvanians, Governor Shapiro’s strategic plan for older adults, Aging Our Way, proposes strategies to bring together services and investments from 29 different commonwealth agencies in new ways that address the shifting needs of this growing population. But we can’t stop with a plan; it needs funding, voices and ambassadors to ensure it goes into action so that Pennsylvania’s largest population is taken care of.

I encourage you to reach out to your legislators and ask them to support funding, planning and programming for our older adults. It is time to invest in those who got us through some of the most challenging times in our country’s history. It is time that we care for, engage with and uplift Pennsylvania’s — and all — older Americans.

Read the full article here.

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Novitas Solutions, Medicare Administrative Contractor (MAC) for Pennsylvania, continues to release inpatient rehabilitation facility review choice demonstration (IRF RCD) program updates, resources, upcoming educational opportunities, and important deadlines as IRFs in PA go through this implementation process.

Included in their most recent updates is:

  • Updated Frequently Asked Questions (FAQs)
  • An upcoming educational opportunity
    IRF RCD: Cycle 1 Progress — October 2, 2024, 1:00 pm – 2:30 pm
    Registration will be released soon and will be available here.

IRF RCD was initially implemented in Alabama in 2023, with the second round being implemented in Pennsylvania on June 17, 2024. The Centers for Medicare and Medicaid Services (CMS) created this process to ensure Medicare coverage and documentation requirements are likely met. This program reduces the number of Medicare appeals, improves provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.

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The meeting documents from the August 7 Long-Term Services and Supports (LTSS) Subcommittee meeting are now available. These documents include the transcript and PowerPoint presentations. You can view them below:

The next LTSS Subcommittee meeting is scheduled for September 4, 2024, from 10:00 am – 1:00 pm in the PA Department of Education’s Honors Suite at 333 Market St. in Harrisburg, PA. The option to participate via webinar is also available.

To participate in the meeting via webinar, please register here. After registering, you will receive a confirmation email containing information about joining the webinar. If you plan to participate via phone, the dial-in number is: 613-992-3221; Access Code: 953 985 828#.

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The Office of Long-Term Living (OLTL) has announced they will be hosting Transportation Summit 3 (via Zoom) on September 17, 2024, from 9:00 am – 12:00 pm.

The Transportation Summit is an open forum for anyone interested in discussing transportation-related issues in the Community HealthChoices (CHC) Program. There will be staff from various programs on the call, including the managed care organizations (MCO) and transportation brokers, Medical Assistance Transportation Program (MATP), and the Pennsylvania Department of Transportation (PennDOT). They will be on the call to listen to feedback and answer questions as they can.

During the webinar, there will be three ways for individuals to ask questions.

  1. You can submit your questions to OLTL in advance by emailing Cortney Alvord.
  2. They can be read during the meeting, where you will use the “Raise Hand” feature during the meeting, be unmuted, and ask your question.
  3. You can type your question into the “Chat” box located on the right side of your screen during the meeting.

To participate in the Transportation Summit, please register using this registration link. After registering, you will receive a confirmation email containing information about joining the meeting.

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The Centers for Medicare and Medicaid Services (CMS) released and published the fiscal year (FY) 2025 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule in the August 6, 2024, Federal Register. Some of the key provisions contained in the provider rule are noted below.

Payment Updates

CMS estimates aggregate payments to IRFs will increase by 2.8 percent in FY 2025, compared to the 4.0 percent payment update that CMS finalized for FY 2024. This update is the result of an annual market basket update, reduced by a productivity adjustment, budget neutrality adjustments for changes to CMG weights and labor/wage changes, and adjustments to the outlier case threshold.

As in previous years, CMS will adopt new delineations for the Core-Based Statistical Areas (CBSA) as identified by the Office of Management and Budget (OMB). [Additional and more detailed information on these new CBSAs can be found in OMB Bulletin No. 23-01] These changes will result in certain counties being reclassified from urban to rural and vice-versa, as well as some counties shifting to different CBSAs. As a result, CMS projects that approximately 10 percent of providers will have a higher wage index, but 16 percent will face a decrease in wage index values (primarily for those reclassified as urban, thus losing the rural adjustment). Thus, CMS finalized a transitional “phase-out” policy for those negatively impacted, such that IRFs set to lose their rural adjustment will retain two-thirds of the adjustment in FY 2025, one-third of the adjustment in FY 2026, and fully “lose” the rural adjustment in FY 2027. CMS estimates that 8 IRFs would be reclassified as urban and thus lose the 14.9 percent rural adjustment.

CMS increased the outlier threshold amount from $10,423 for FY 2024 to $12,043 for FY 2025 (slightly lower than the proposed rule’s projection). This change will account for an estimated 0.2 percent decrease to aggregate payments across the IRF PPS in FY 2025.

Quality Reporting Program (QRP) Updates

CMS finalized its proposal to adopt four new items as Standardized Patient Assessment Data Elements (SPADE) under the social determinants of health (SDOH) category beginning with the FY 2028 IRF QRP: one Living Situation item; two Food items; and one Utilities item. CMS notes that these new SPADES are intended to assist IRFs in “better addressing those identified needs with the patient, their caregivers, and community partners during the discharge planning process, if indicated.”

Transportation Item Modification Finalized Beginning with the FY 2028 IRF QRP (October 1, 2026 Implementation)

Consistent with the AHC HRSN Screening Tool, CMS finalized a proposal to modify the A1250. Transportation item currently collected in the IRF–PAI in two ways: (1) revise the look-back period for when the patient experienced lack of reliable transportation; and (2) simplify the response options.

  • A1250. Transportation currently collected in the IRF-PAI asks: “Has lack of transportation kept you from medical appointments, meetings, work, or from getting things needed for daily living?” The response options are: (A) Yes, it has kept me from medical appointments or from getting my medications; (B) Yes, it has kept me from non-medical meetings, appointments, work, or from getting things that I need; (C) No; (X) Patient unable to respond; and (Y) Patient declines to respond.
  • The finalized Transportation item asks, “In the past 12 months, has a lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?” The final response options are: (0) Yes; (1) No; (7) Patient declines to respond; and (8) Patient unable to respond.

Finalized Proposal to Remove the Admission Class Item From the IRF-PAI Beginning October 1, 2026, with Minor Modification

  • CMS asserts that the Admission Class Item is currently not used in the calculation of quality measures already adopted in the IRF QRP. It further notes that it is not used for previously established purposes unrelated to the IRF QRP, such as payment, survey, or care planning. This removal will be effective beginning with the FY 2028 IRF QRP (beginning with patients admitted on October 1, 2026); however, IRFs will not be required to collect this item beginning with patients admitted on October 1, 2024.

For additional information, CMS published a fact sheet that provides an overview of the provisions contained in the final rule.

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The Centers for Medicare and Medicaid Services (CMS) has recognized traumatic brain injury (TBI) as a chronic health condition. TBI has been added to CMS’ list of chronic conditions for chronic special needs plans (C-SNPs) through its Medicare Advantage program, effective for the January 2025 plan year.

The addition of TBI to the list of chronic conditions was included in a final rule published by CMS in the June 2024 Federal Register, which will become effective on January 1, 2025. Obtaining official recognition of TBI as a chronic condition from CMS is a significant step forward and provides validation that brain injury should be more broadly recognized as a chronic condition.

In March 2024, the Brain Injury Association of America (BIAA) published a position paper requesting CMS, along with the Centers for Disease Control and Prevention (CDC), to designate brain injury as a chronic condition. Formal recognition, the paper states, has the potential to provide several advantages for people with brain injury, including the allocation of additional public health resources to focus on the lifelong effects of brain injury as well as health insurance plans, primarily Medicare and Medicaid, providing additional benefits and other supports as they do for other chronic health conditions. The greatest benefit, however, would be an increase in public awareness of the long-term effects of brain injury that affect the estimated 5 million Americans with a brain injury-related disability.

BIAA will be hosting a live Question and Answer (Q&A) session in the near future to discuss these changes and future tools and resources to assist survivors and their loved ones advocate for further expanding coverage.

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