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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 Department of Health and Human Services (HHS) recently released and publicly posted the July 2020 through December 2020 COVID-19 testing plans from all states. These testing plans serve as a roadmap developed in partnership with the Federal government for each jurisdiction’s monthly 2020 testing strategy for SARS-CoV-2 (the virus that causes COVID-19). The plans include details on responding to surges in cases and reaching vulnerable populations including minorities, immunocompromised individuals, and older adults.

Each state plan is required to include details of critical parameters for state testing strategies, including target numbers of tests per month, as outlined in the Centers for Disease Control and Prevention’s (CDC’s) Epidemiology and Laboratory Capacity for Prevention and Control of Emerging Infectious Diseases (ELC) guidance document.

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The Centers for Medicare and Medicaid Services (CMS) recently notified providers in a COVID-19 Frequently Asked Questions (FAQ) document that, beginning August 17, 2020, Medicare Administrative Contractors (MACs) will be resuming Medicare fee-for-service (FFS) medical review activities and audits. These audits had been placed on hold since March when the COVID-19 public health emergency (PHE) went into effect. The MACs will only be reviewing claims from before March 1, 2020 and will not be conducting Target, Probe, and Educate (TPE) audits (which consist of multiple rounds). Instead, single-phase audits will be conducted.

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The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2021 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule. The provisions contained in this final rule will go into effect on October 1, 2020 and will be published in the August 10, 2020 Federal Register.

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

Increased Flexibility for Physicians
CMS significantly scaled back its proposal to allow non-physician practitioners (NPPs) to perform certain IRF services that are currently required to be performed by a rehabilitation physician, such as completing the pre-admission screening, developing the individual overall plan of care (IOPC), performing three face-to-face visits per week, and leading interdisciplinary team meetings. CMS noted that the role and judgment of the rehabilitation physicians are key to the successful outcomes complex IRF patients.

IRF Coverage Requirements
CMS finalized certain changes to the regulations that codifies existing documentation instructions and guidance that improves clarity and reduces administrative burden on both the IRF providers and the Medicare Administrative Contractors (MACs).

Post-Admission Physician Evaluation
IRF’s are required to conduct a post-admission physician evaluation (PAPE) within the first 24 hours of the patient’s admission to the IRF to confirm that no changes have occurred since the preadmission screening and that the patient is still appropriate for IRF admission. The PAPE requirement was temporarily waived as an IRF coverage requirement under the April 6, 2020 interim final rule in response to the COVID-19 public health emergency (PHE). In the proposed rule, CMS stated that it intended to utilize the temporary removal of the PAPE to gauge the impact of permanently removing this documentation requirement. This proposal to make permanent this temporary removal of the PAPE was finalized in this rule.

Intensity of Therapy
CMS clarifies that a “week” will be defined as a period of 7 consecutive calendar days beginning with the date of admission to the IRF; thereby, clarifying for purposes of compliance with the so-called “3 hour rule.”

Quality Reporting Program (QPP)
CMS finalized the method for applying the 2 percentage point reduction (i.e., penalty) to the FY 2021 IRF increase factor for IRFs that fail to meet Quality Reporting Program (QRP) requirements. This is the only provision impacting the QRP in the FY 2021 rule.

Updates to IRF Payment Rates
For FY 2021, CMS is updating the IRF PPS payment rates by 2.4 percent (reflecting a 2.4 percent IRF market basket reduced by a 0.0 percentage point multifactor productivity adjustment). An additional 0.4 percent increase to aggregate payments due to updating the outlier threshold to maintain estimated outlier payments at 3.0 percent of total payments results in an overall update of 2.8 percent (or $260 million) for FY 2021, relative to payments in FY 2020. The recent Office of Management and Budget (OMB) statistical area delineations and applying a 5 percent cap on wage index decreases from FY 2020 to FY 2021 are also being adopted. The wage index files are available on the CMS website.

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Today, the Department of Human Services (DHS) issued a Request for Application (RFA) seeking an enrollment broker/vendor to provide enrollment services, choice counseling, and beneficiary support services for older Pennsylvanians and adults with physical disabilities who need long-term services and supports (LTSS) through the Office of Long-Term Living (OLTL).

This enrollment broker will assist and serve individuals who need access to LTSS, including the Community HealthChoices (CHC) program, the Living Independence for the Elderly (LIFE) program, and other home and community-based long-term care programs, such as the OBRA Waiver and Act 150 program. Enrollment brokers assist enrollees with navigating the enrollment process and understand their rights as a health care consumer, their options for a managed care organization (MCO) and care providers, and their ability to make their own choices about their health care and LTSS.

The RFA will be active until October 2, 2020. Interested applicants are encouraged to review the RFA and submit an application.

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On July 31, it was announced by the Department of Health and Human Services (HHS) that they will be extending the application deadline for the Medicaid/Children’s Health Insurance Program (CHIP) until August 28, 2020. This extension is included as a part of an ongoing effort to provide financial relief to healthcare providers impacted by the coronavirus disease 2019 (COVID-19).

In addition, HHS also plans to allow certain Medicare providers who experienced challenges in the Phase 1 Medicare General Distribution application period a second opportunity to receive funding. It is expected that HHS will reopen the Medicare distribution portal beginning the week of August 10, 2020. It is HHS’ intent to ensure eligible healthcare providers receive the balance of their additional funding to equal approximately 2 percent of gross receipts from patient care regardless of payer mix through the Provider Relief Fund.

Both groups will have until the August 28, 2020 deadline to apply. For updated information and data, visit the Provider Relief Fund web page.

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The Centers for Disease Control and Prevention (CDC) Clinician Outreach and Communication Activity (COCA) has announced a call, COVID-19 & Telehealth Implementation: Stories From the Field, for Tuesday, August 4, 2020 from 2:00 pm – 3:30 pm. During this call, presenters will discuss the CDC’s telehealth guidance and telehealth benefits and challenges during and after the COVID-19 pandemic. They will also share their experiences implementing telehealth across diverse healthcare settings and address considerations for its future use. The registration link and call information is located on the COCA call web page.

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Today, the Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC) announced that reimbursement is available to physicians and health care providers to use toward counseling patients, at the time of COVID-19 testing, about the importance of self-isolation after they are tested and prior to the onset of symptoms. This is extremely important as studies have shown that the transmission of COVID-19 occurs from both symptomatic, pre-symptomatic, and asymptomatic individuals emphasizing the importance of education on self-isolation as the spread of the virus can be reduced significantly by having patients isolated earlier, while waiting for test results or the onset of symptoms.

Provider counseling to patients, at the time of their COVID-19 testing, will include the discussion of immediate need for isolation, even before results are available, the importance to inform their immediate household that they too should be tested for COVID-19, and the review of signs and symptoms and services available to them to aid in isolating at home. Additionally, they will be counseled that if they test positive, to wear a mask at all times and they will be contacted by public health authorities and asked to provide information for contact tracing and to tell their immediate household and recent contacts in case it is appropriate for these individuals to be tested for the virus and to self-isolate as well.

CMS will use existing evaluation and management (E/M) payment codes to reimburse providers who are eligible to bill CMS for counseling services no matter where a test is administered, including doctor’s offices, urgent care clinics, hospitals, and community drive-thru or pharmacy testing sites.

Additional information and resource links are included in the counseling checklist.

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a memo is on the keyboard of a computer as a reminder: meeting

The agenda for the Wednesday, August 5, 2020 Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting/webinar has been released. The webinar will be held from 10:00 am – 1:00 pm. Key agenda topics for members to be aware of include: evaluation of racial disparities in the Office of Long-Term Living (OLTL) programs; the 2021 Community HealthChoices (CHC) waiver amendment and public comment period; and updates on COVID-19. Members are encouraged to participate in the webinar by utilizing one of the following formats:

Bridge Number: 1-415-655-0052 PIN: 653-589-644
Webinar link
Remote streaming link

Comments and questions may be submitted via email.

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The July 25, 2020 issue of the Pennsylvania Bulletin contained the public notice, Availability of Amendment to the Office of Long-Term Living’s Home and Community-Based Community Health Choices Waiver, which announces the amendments to the Community HealthChoices (CHC) waiver.

The Department of Human Services (DHS) Office of Long-Term Living (OLTL) will be submitting amendments for the CHC 1915(c) Home and Community-Based waiver to the Centers for Medicare and Medicaid Services (CMS) in October 2020. OLTL has made available a side-by-side comparison of the current and revised language, as well as copies of the amendments in their entirety on the 2021 Community HealthChoices Waiver Amendment page of the OLTL Waiver Amendment, Renewals, and Accompanying Home and Community-Based Services (HCBS) Transition Plans website.

OLTL is requesting public comment on the proposed CHC Waiver Amendments. Written comments should be sent to: Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: CHC 2021 Waiver Amendment, PO Box 8025, Harrisburg, PA 17105-8025. Comments can also be sent via email, using the comment form OLTL has provided. Please use “CHC 2021 Waiver Amendment” as the subject line. A Word version of the comment form can be downloaded via the link found at the bottom of the 2021 Community HealthChoices (CHC) Waiver Amendment page of the OLTL Waiver Amendment, Renewals, and Accompanying HCBS Transition Plans website. The public comment period ends on August 24, 2020. Comments must be submitted by this date to be reviewed and considered for revisions to the proposed waiver amendments.

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The Department of Human Services (DHS) and Department of Health (DOH), in coordination with the Pennsylvania Emergency Management Agency (PEMA) and the Centers for Disease Control and Prevention (CDC), have developed the Regional Response Health Collaboration Program (RRHCP). This program is designed to directly support COVID-19 readiness and response in long-term residential care facilities, including long-term care nursing facilities, personal care homes, and assisted living residences. The program also provides assistance to other DHS-licensed facilities, Adult Living Centers and State Veterans Homes. In addition, the program was developed to improve infection prevention and facilitate continuity of care and other services provided by long-term care facilities in a manner that mitigates risk of spread of COVID-19 to staff and residents.

The RRHCP is a collaboration between DHS and nine regional health collaboratives consisting of health care systems and academic medical centers. The RRHCP is divided into six regions, with a health collaborative responsible for all or a portion of the long-term care facility census in each region which includes:

  • Southeast Region:
    1. Thomas Jefferson University in partnership with Mainline Health and Lehigh Valley Health Network
    2. University of Pennsylvania in partnership with Temple University Hospital, Inc.
  • Northeast Region:
    1. Geisinger Clinic
    2. Lehigh Valley Hospital, Inc.
  • Southcentral Region:
    1. The Pennsylvania State University
  • Northcentral Region:
    1. Geisinger Clinic
  • Southwest Region:
    1. UPMC Community Provider Services in partnership with Allegheny Health Network, the Jewish Healthcare Foundation, and the Hospital Council of Western Pennsylvania
  • Northwest Region:
    1. LECOM Health
    2. UPMC Community Provider Services in partnership with Allegheny Health Network, the Jewish Healthcare Foundation, and the Hospital Council of Western Pennsylvania

The RRHCP will provide operational and administrative support to protect residents in long-term care facilities from COVID-19.  It will help facilities implement best practices in infection control, implement contact tracing programs in facilities, support clinical care through on-site and telemedicine services, provide remote monitoring and consultation with physicians, and enhance testing capability for both individuals in care and staff at facilities.

The RRHCP will also assist in identifying alternate care arrangements for hospitalized COVID-19 patients until they are considered no longer infectious and can return to their long-term care residential facilities. Services and assistance offered by the RRHCP include, but are not limited to:

  • Establishing a call center with 24/7 access for providers to access clinical consultation and technical assistance;
  • Assisting with universal testing;
  • Providing expertise in infection control;
  • Deploying rapid response teams in case of emergency in conjunction with DOH, DHS and PEMA;
  • Assessing the facility’s capability and capacity to prevent and to respond to a COVID-19 outbreak, including review of policies and procedures to prevent introduction of COVID-19 into the facility, fundamental infection control practices, and its readiness to respond to an outbreak of COVID-19;
  • Assisting facilities with ensuring hazard response plans are in place;
  • Reviewing the process for behavioral health assessments;
  • Providing emergency preparedness for personal protective equipment assessment and coordination;
  • Establishing a statewide educational support resource for providers to have access to state and national resources;
  • Assisting providers with staff augmentation when needed;
  • Working with DOH and DHS to conduct contact tracing;
  • Assisting providers in developing and implementing plans for alternate care settings for residents if outbreaks of COVID-19 occur at their facility; and
  • Providing software and technical support to facilities to support two-way communication between residents and their families.

The RRHCP is based on the Educational Support and Clinical Coaching Program (ESCCP), a learning network that provided technical assistance and educational support to long-term care facilities in light of the current pandemic.

An introductory webinar has been scheduled for Friday, July 24, 2020 from 9:00 am – 10:00 am. The webinar, “Support for Long-Term Care Nursing Homes, Personal Care and Assisted Living Facilities, is open to all provider types and all members are encouraged to participate to learn more about this program. The webinar information is provided below:

Login: Webex Link
Password: DHS2020
Call-in: 1-844-621-3956
Event Number and Access Code: 145 274 9024

Please contact this email for DOH questions or use this email for DHS questions.

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