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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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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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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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