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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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On April 29, 2021, the Centers for Medicare and Medicaid Services (CMS) released the final rule that extends and makes changes to the Comprehensive Care for Joint Replacement (CJR) model. This final rule revises the episode definition, payment methodology, and makes other modifications to the model to adapt the CJR model to changes in practice and fee-for-service (FFS) payment occurring over the past several years. The final rule provides the time needed to test modifications to the model by extending the CJR model for an additional three performance years through December 31, 2024 for certain participant hospitals.

For background purposes, the CJR model is a Medicare Part A and B payment model test, led by the CMS Innovation Center and implemented under section 1115A of the Social Security Act. In this model, all providers and suppliers are paid under the usual payment system rules and procedures of the Medicare program throughout the year for episodes of care for lower extremity joint replacement or reattachment of a lower extremity (referred to as LEJR). At the end of a model performance year, actual spending for the episode (total expenditures for related services under Medicare Parts A and B) is compared to the Medicare target episode price for the responsible hospital. Depending on the participant hospital’s quality and episode spending performance, the hospital may receive an additional payment from Medicare or be required to repay Medicare for a portion of the episode spending.

Some of the key provisions contained in the final rule include:

  • Revision to definition of a CJR episode to now include lower extremity joint replacement procedures performed in the hospital outpatient department;
  • Changes to target price calculation from three years of claims data to one year of claims data;
  • Changes to the reconciliation process;
  • Addition of an episode-level risk adjustment; and
  • Finalized the proposal to exclude rural and low-volume hospitals in the 34 mandatory Metropolitan Statistical Areas (MSAs) and any voluntary hospitals in the 33 voluntary MSAs that had opted into the model for performance years 3 through 5.

There is additional information located on the CJR model page on the CMS’ website. The final rule will be published in the May 5, 2021 Federal Register.

On Tuesday, April 27, 2021, the Centers for Medicare and Medicaid Services (CMS) issued a revised guidance for COVID-19 long-term care (LTC) facility testing requirements for both staff and residents. These revisions apply to the original guidance that was issued on August 25, 2020 and focus primarily on testing and vaccinations. CMS also revised the nursing home visitation guidance during the COVID-19 public health emergency (PHE), which includes the impact of the COVID-19 vaccination.

Based on these recent revisions, the Department of Human Services (DHS) encourages all personal care homes (PCHs) and Assisted Living Residences to implement the policies contained in these revised guidances immediately. DHS will issue updated guidance in the near future. Questions about these revisions should be directed to ARL Headquarters.

The Council on Brain Injury (CoBI) has announced their next lecture in their clinical forum series. This upcoming lecture, “Telehealth & Brain Injury Rehabilitation,” is scheduled for Wednesday, May 12, 2021 from 3:30 pm–5:00 pm and will present a review of the literature and specific case examples regarding delivering services to individuals with brain injury via telehealth. The results of a nationwide telehealth survey, developed by staff from Centre for Neuro Skills (CNS) and the Brain Injury Association of America (BIAA), for post-acute brain injury rehabilitation providers will be presented.

A live question and answer session will follow the presentation. The lecture is free of charge; however, registration is required. Questions should be directed to MJ Schmidt.

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Novitas Solutions has released their draft agenda for the upcoming Medicare training for RCPA’s brain injury providers. The training has been scheduled for Tuesday, May 25, 2021 from 9:00 am–3:00 pm and will be conducted via Webex. A finalized agenda and Webex link will be sent to members who will be participating in the training within the next week.

Please send an email to Melissa Dehoff by Tuesday, May 4, 2021 (noting “Medicare Training” in the subject line) to register for this training. Each organization should send one email and include the list of names and contact information (name, title, email, and telephone number) for those individuals that will be participating.

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The Centers for Medicare and Medicaid Services (CMS) has announced the date for the next hospital/quality initiative open door forum. The open door forum has been scheduled for Wednesday, April 28, 2021 from 2:00 pm–3:00 pm. Agenda topics include: fiscal year (FY) 2022 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule overview; FY 2022 inpatient psychiatric facility (IPF) PPS proposed rule; the inpatient prospective payment system (IPPS) wage index timeline reminder; and open question and answer.

To participate in the open door forum, dial 888-455-1397 and reference passcode 8604468. Instant replay will also be available beginning one hour after the call has ended (and expires after Friday, April 30, 2021). To listen to the replay, dial 800-391-9852. No passcode is needed.

The next Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting is planned for Tuesday, May 4, 2021 via webinar from 10:00 am–1:00 pm. To participate in this meeting, registration is required. Following the completion of the registration, a confirmation email will be sent containing information about joining the webinar.

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Bids are now being accepted for the Acquired Brain Injury (ABI) and Opioid Training Request for Approval (RFA) that was posted today on the state’s eMarketplace website. The description for this RFA reads: Acquired Brain Injury and Opioid Use training for professionals who work with individuals with an ABI or opioid use problem. The duration of the program is January 1, 2022 through June 30, 2024. Bids must be submitted by May 19, 2021.

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As has been discussed in the RCPA Brain Injury Committee meetings regarding becoming Medicare certified, a full-day training has been scheduled for May 25, 2021 from 9:00 am–3:00 pm. The training will be conducted by Novitas Solutions, Inc., Medicare Administrative Contractor (MAC) for Jurisdiction L, which includes Pennsylvania.

Additional information will be shared, including the agenda, in the very near future. Please mark your calendars!

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2022 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule, along with a detailed fact sheet. The proposed rule is scheduled to be published in the Federal Register on April 12, 2021.

Some of the key provisions and proposed policy changes include:

  • Increase in net payments of 1.8 percent (or $160 million), relative to FY 2021 payments (CMS is also requesting feedback on whether FY 2019 claims data or FY 2020 claims data should be utilized to update payment rates due to the COVID-19 public health emergency).
  • Input requested on a number of potential new quality reporting program (QRP) measures.
  • Addition of a new IRF QRP measure: COVID-19 Vaccination Coverage Among Healthcare Personnel beginning in FY 2023 under the IRF QRP.
  • Revision to the data for public reporting/use on Care Compare to account for the 2020 QRP reporting waivers.
  • Outlier Threshold: CMS proposes to update the outlier threshold amount from $7,906 for FY 2021 to $9,192 for FY 2022.
  • Requesting information on revising the measure development and standardized patient ‎assessment data elements (SPADEs) collection to “address gaps in health equity in the IRF ‎QRP.”
  • Requesting information on future plans to define digital quality measures for the IRF QRP.

RCPA will review and discuss the proposed rule in the upcoming Outpatient Rehabilitation Committee and Medical Rehabilitation Committee meetings and utilize the feedback in developing comments on this proposed rule. Comments on this proposed rule are due by June 7, 2021.

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The Centers for Medicare and Medicaid Services (CMS) recently updated the list of telehealth codes to be covered under the Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2021 through the end of the public health emergency (PHE). Included in this updated list are services provided by speech-language pathologists and audiologists. The entire list of all currently permitted telehealth services under the CY 2021 MPFS are located here.