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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) recently released a Request for Information (RFI) requesting public comments on the Medicare Advantage program. CMS is asking for input on ways to achieve the agency’s vision so that all parts of Medicare are working towards a future where people with Medicare receive more equitable, high quality, and person-centered care that is affordable and sustainable, essentially asking for ways to strengthen this program.

CMS’s intent is to better align the Medical Assistance (MA) program with the agency’s vision for Medicare and the CMS Strategic Pillars. CMS is strongly emphasizing the importance of stakeholder comments for this process. This openness to feedback presents MA plans, providers, and other stakeholders an opportunity to inform the agency’s early thinking as it considers potential regulatory actions impacting supplemental benefits, value-based contracting arrangements, risk adjustment, prior authorization, and marketing among other issues.

CMS will accept comments on the RFI until August 31, 2022.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2023 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was published in today’s Federal Register. Some of the key provisions contained in the final rule are provided below:

Final FY 2023 Payment Updates
CMS estimates overall payments to IRFs will increase by 3.2 percent compared to FY 2022 levels (higher than the 2 percent estimated in the proposed rule). This update is the result of a 4.2 percent update to the IRF market basket reduced by a 0.3 percent productivity adjustment, which is required by law. As a result of this market basket increase and a few small budget neutrality adjustments, the standard payment conversion factor will increase from $17,240 to $17,878. ‎CMS is also adjusting the outlier threshold, which it says will reduce overall payments by 0.6 percent. CMS says the 3.2 percent overall increase will result in $275 million in increased payments to IRFs compared to 2022.

Proposed Expansion of IRF Transfer Policy to Include Home Health Services
CMS issued a Request for Information (RFI) in the proposed rule regarding the potential expansion of the current IRF transfer payment policy to include home health services. For background, IRFs receive a reduced case mix group (CMG) payment rate under the IRF transfer policy when the patient’s discharge occurs earlier than the average length of stay (for that respective CMG and tier) and the patient is discharged to a certain setting (an IRF, acute-care hospital, LTCH, nursing home that takes Medicare and Medicaid payment). The policy currently does not apply to home health.

The RFI in this year’s rule followed a December 2021 Office of Inspector General (OIG) report finding that Medicare could have saved over $993 million had the IRF transfer policy been expanded to include home health services (based on 2017 and 2018 data). The OIG therefore recommends that CMS explore ways to capture early discharges to home health care in the current policy, which CMS referenced in the proposed rule. Following a review of concern cited in stakeholder comments, CMS is not moving forward with any changes to the transfer policy at this time.

IRF Quality Reporting Program Changes & Requests for Information All-Payer IRF-PAI Reporting Proposal
CMS proposed to require collection of the IRF-PAI for all IRF patients, including those without Medicare, beginning with the FY 2025 IRF QRP (with data collection to begin on October 1, 2023). Currently the IRF-PAI is only required to be collected for Medicare Part A (fee-for-service) and Part C (Medicare Advantage) beneficiaries. In response to comments, CMS opted to finalize the proposal but with a revised implementation date. IRFs will now be required to collect IRF-PAIs on all patients, regardless of payer, for the FY 2026 IRF QRP (data collection to begin on October 1, 2024).

RFI on Future QRP Measure Expansions
CMS had issued a Request for Information (RFI) related to measures/concepts for use in the QRP in future years in the proposed rule. The agency specifically requested information on a cross-setting function measure that would include self-care and mobility items, and development of a patient-level COVID-19 vaccination measure. CMS referenced several of AMRPA’s comments, including concerns that IRF stays are typically not long enough to adequately capture COVID-19 vaccination for patients. CMS did not provide a response to comments but affirmed the agency would use the stakeholder feedback to inform future rulemaking.

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On July 13, 2022, the Centers for Medicare and Medicaid Services’ (CMS) Medicare Administrative Contractors (MACs) distributed notifications to inpatient rehabilitation facilities (IRFs) that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for calendar year (CY) 2021, which will affect their FY 2023 Annual Payment Update (APU). Non-compliance notifications were placed into facilities’ “Certification and Survey Provider Enhance Reports” (CASPER) folders in the Quality Improvement and Evaluation System (QIES) for hospice and skilled nursing facilities (SNFs), and into facilities’ “My Reports” folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs and long-term care hospitals (LTCHs). If a facility received a letter of non-compliance, it may submit a request for reconsideration to CMS via email. The submission deadline is 11:59 pm on August 11, 2022. View the full details and instructions for submission here.

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The next Financial Management Services (FMS) Stakeholder meeting has been scheduled for August 5, 2022, from 1:00 pm – 2:30 pm.

This public meeting is being held to discuss upcoming changes for the administration of FMS under the Community HealthChoices (CHC), OBRA Waiver, and Act 150 Programs. Representatives from the Office of Long-Term Living (OLTL) and Community HealthChoices Managed Care Organizations (CHC MCOs) will be in attendance to discuss upcoming changes.

Please register using this registration link. After registering, you will receive a confirmation email containing information about joining the webinar.

If you choose to use your phone to call in, please use the numbers below:
Dial in: (415) 930-5321
Access Code: 264854023#
Audio PIN: shown after joining the webinar

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On July 7, 2022, the Centers for Medicare and Medicaid Services (CMS) released the proposed Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2023. In this proposed rule, CMS is proposing an approximately 4 percent reduction to the base payment factor for all services for 2023. The specific level of adjustment providers may see will depend on changes CMS finalizes to other factors. CMS is also proposing to expand the list of codes that can be provided via telehealth through 2023 to include some therapy codes. Modifications to the Quality Payment Program (QPP), which includes the Merit-Based Incentive Payment System (MIPS), to allow for additional pathways for participation for certain specialties is also being proposed. The proposed rule will appear in the July 29 Federal Register.

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Information and registration for the August Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting was recently released by the Office of Long-Term Living (OLTL). The meeting will be held on August 3, 2022, from 10:00 am – 1:00 pm. Attendees can participate via webinar or in person at the PA Department of Education Building’s Honors Suite at 333 Market Street in Harrisburg.

To participate in the meeting via webinar, please register via the link below. Those participating by webinar are encouraged to register early. When registering, please verify that you entered your email address correctly. You will receive a confirmation email containing information about joining the webinar if you registered correctly.

Webinar Registration Link
If you have trouble accessing the webinar registration through the Internet Explorer or Safari web browsers, please try accessing it through a different web browser such as Chrome or Edge.

Dial In Number:
The dial-in number is:  (415) 655-0052
Access Code: 205870515#

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The Centers for Medicare & Medicaid Services (CMS) has approved the Office of Long-Term Living’s (OLTL) Community HealthChoices (CHC) Waiver amendment that transfers oversight of Financial Management Services (FMS) from an OLTL-held contract to an administrative function of the CHC-MCOs and revises waiver performance measure AA-5. The amendment became effective on July 1, 2022.

The current approved CHC 1915(c) Waiver document with the FMS amendment can be viewed here. The link can be found under the heading “Community HealthChoices 1915(b) Managed Care and 1915(c) Home and Community-Based Waivers.”

Questions about the CHC Waiver amendment should be sent via email.

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Image by Shotkitimages from Pixabay

Temple University Harrisburg recently announced their fall 2022 online training that is approved to meet the personal care home (PCH) and assisted living residence (ALR) annual training requirements.

Information about the online training sessions (including registration links) are provided below:

Those interested in participating only need to register for one session for each topic. Please read the training announcements in full before registering to ensure you are able to meet the participation requirements. Participation is limited for each course. If you register and later discover you are unable to participate, please cancel your registration to create space for other participants.

Questions about the online trainings or assistance with registration should be sent via email. If you would like information about additional trainings available for PCH and ALR administrators, please contact the Bureau of Human Services Licensing Operator Support Hotline.

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The Office of Long-Term Living (OLTL) will be presenting a live, interactive webinar series on housing issues. This five-session series will be offered twice (see schedule below). The webinars will include targeted content, including question and answer (Q&A) sessions with housing experts and OLTL staff. Each session is scheduled for 90 minutes to allow for interaction and Q&A segments.

The webinar series targets Service Coordinators, Managed Care Organizations, and Service Coordination Entity support staff who assist program participants in securing and maintaining affordable, accessible housing. This series builds on information already provided in the Online Housing Training Modules and the Self-Determination Housing of Pennsylvania (SDHP)/Inglis’s Prepared Renter Program (PREP) curriculum.

This series of webinars is designed to be taken in order. The content in each session builds on prior content. Participants will get the most out of the program by taking all the sessions in order. Although individuals are not required to complete the sessions in order, to keep the sessions focused, the webinar leader may opt to table questions that were covered in prior sessions.

The series will be presented twice:

  • August 16 – September 13 (every Tuesday) from 1:30 pm – 3:00 pm
  • September 21 – October 19 (every Wednesday) from 9:00 am – 10:30 am

2022 OLTL Housing Series Curriculum

Webinar 1: Understanding and Navigating Housing Nuances

  • 10 Housing-Sector Nuances
  • 3 Main Pathways to Housing Resources

Webinar 2: Recommended Relationships and Resources in the Housing Sector

  • 5 Key Partnerships to Cultivate
  • Top 6 Housing Resources

Webinar 3: Funding Sources and Clarifying Affordability Frequently Asked Questions (FAQs)

  • 6 Kinds of Funding Sources
  • 3 Concepts to Understand About Affordability and Income-based Eligibility

Webinar 4: Legal Issues Related to Housing

  • Criminal Justice System Involvement
  • Fair Housing and Reasonable Accommodation

Webinar 5: Keeping Participants Housed and Landlord Engagement Techniques

  • 6 Key Concepts in Keeping Participants Housed
  • Landlord Engagement Techniques and Resources

To register for the Housing Webinar Series, please go to the OLTL Housing Webinars registration page.

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The Centers for Medicare and Medicaid Services (CMS) recently issued updates associated with the inpatient rehabilitation facility (IRF) provider preview reports and the IRF Patient Assessment Instrument (PAI).

CMS has released the updated IRF Provider Preview Reports, which contain provider performance scores for quality measures and contain IRF-PAI data submitted by IRFs from Quarter 1 (Q1) 2021 through Quarter 4 (Q4) 2021, as well as CDC Clostridium Difficile (CDI) and Catheter-Associated Urinary Tract Infections (CAUTI) measures from Quarter 4 (Q4) 2020 through Quarter 3 (Q3) 2021, and Q4 2018 through Q1 2019 of the Healthcare Personnel (HCP) Influenza measure. The new HCP COVID-19 Vaccination Coverage measure will also be publicly reported on Care Compare in the September 2022 release and will reflect Q4 2021 data. Unlike prior September Care Compare refreshes, CMS will not be preforming the annual update to IRF claims-based measures, due to CMS only resuming the reporting of claims-based measures during the June 2022 refresh.

Providers have until July 15, 2022, 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 during the September 2022 refresh of the website. Additional information is on the CMS IRF Quality Reporting Program (QRP) public reporting website.

CMS also published the IRF-PAI Quarterly Questions & Answers (Q&A) document that provides clarification to existing guidelines.

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