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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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Late this afternoon, the Centers for Medicare and Medicaid Services (CMS) issued new guidance to inpatient rehabilitation facilities (IRFs) that provides additional clarification on flexibilities being afforded in response to the COVID-19 pandemic and also confirms that team meetings can be performed virtually. CMS will allow all forms of social distancing precautions when holding interdisciplinary team meetings and stressed electronic or virtual team meetings would be the safest during this pandemic.

In addition to CMS exercising their regulatory flexibility to waive the 60 percent rule, they are also waiving IRF coverage and classification requirements if the following criteria are satisfied:

  • Patient is admitted to a freestanding IRF to alleviate acute care hospital bed capacity issues
  • IRF is located in an area that is in Phase 1 or has not entered Phase 1 as noted in Guidelines: Opening Up America Again

CMS also provides additional information on the codes that should be used when IRFs are utilizing flexibilities that CMS has issued. CMS directs IRFs to add the following letters at the end of the unique hospital patient identification number (or medical record number in the IRF) to identify the patients eligible for each waiver:

  • D – 60 percent rule
  • DS – Coverage and classification requirements
  • DDS – Both 60 percent rule and coverage and classification requirements

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 The Centers for Medicare and Medicaid Services (CMS) will conduct weekly calls that focus on COVID-19 and lessons from the front lines. Two calls have been scheduled for May 1 and May 8 (from 12:30 pm – 2:00 pm) and are a joint effort between CMS Administrator, Seema Verma; Food and Drug Administration (FDA) Commissioner, Stephen Hahn, MD; and the White House Coronavirus Task Force, along with physicians and other clinicians. Participants will be encouraged to share their experiences, ideas, strategies, and insights related to your COVID-19 response. There will also be an opportunity to ask questions.

To Participate on May 1:

  • Conference lines are limited, so we encourage you to join via audio webcast, either on your computer or smartphone web browser
  • Or, call 877-251-0301; Access Code: 9545128

To Participate on May 8:

  • Conference lines are limited, so we encourage you to join via audio webcast, either on your computer or smartphone web browser
  • Or, call 877-251-0301; Access Code: 9146779

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The Centers for Medicare and Medicaid Services (CMS) and the Assistant Secretary of Preparedness and Response (ASPR) released a new COVID-19 Healthcare Workforce toolkit. The toolkit includes a variety of resources and tools for decision-makers managing health care challenges associated with the COVID-19 pandemic. The toolkit builds on the steps that CMS has taken to ensure health care facilities are fully staffed and equipped to treat COVID-19 patients as efficiently as possible. It also provides up-to-date best practices so that state and local health care decision makers have a resource to know what’s been implemented in the field and to find out how it’s working. The toolkit includes an assistance center, information exchange of case studies, and additional peer-to-peer communications.

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The Brain injury Association of America (BIAA) will release one free webinar available each week of the month of April that focus on Traumatic Brain Injuries (TBI). While we are in mid-April, there are still three remaining webinars, listed below. Please use the codes next to the title of the webinar when downloading the webinar to bypass the fee.

If there are any issues with downloading the webinars, please contact BIAA.

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Today, the Centers for Medicare and Medicaid Services (CMS) issued new recommendations that are targeted specifically to communities that are in Phase 1 of the Guidelines for President Trump’s Opening Up America Again with low and stable incidence of COVID-19 cases. These guidelines recommend a gradual transition and encourage health care providers to coordinate with local and state public health officials, as well as reviewing the availability of personal protective equipment (PPE), workforce availability, facility readiness, and testing capability to factor into the decision making process to re-start or increase in-person care.

These recommendations update earlier guidance that was issued by CMS on limiting non-essential surgeries and medical procedures. Health care facilities and providers that are in areas still seeing higher numbers of COVID-19 cases are encouraged to continue following the recommendations made by CMS last month. These were issued to expand capacity to care for patients with COVID-19, to reduce the risks of transmission and exposure to patients, and to conserve adequate supplies (especially PPE) and manpower, during the public health emergency.

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The Centers for Medicare and Medicaid Services released the inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule for fiscal year (FY) 2021. Due to the COVID-19 public health emergency and the demands that have been placed on the healthcare industry, CMS limited the rulemaking to essential policies and proposals to reduce provider burden and assist IRF’s, especially in the COVID-19 response. Some of the proposals include:

  • Payment: CMS proposes to implement its annual updates to the weights and average lengths of stays for the IRF PPS Case Mix Groups (CMGs), update the standard payment conversion factor due to growth in the IRF market basket, and increase the labor-related share. Overall, CMS estimates payments to IRFs will increase by 2.9 percent.
  • IRF Coverage Requirements: CMS proposes to amend the IRF coverage requirements to remove the post-admission physician evaluation (PAPE) requirement.
  • Non-Physician Practitioners: CMS proposes to modify the IRF coverage requirements to allow non-physician practitioners (NPP) to perform certain services that are currently required to be performed by a rehabilitation physician. Some of these services include the pre-admission screening, developing the individual plan of care, performing three face-to-face visits per week, and leading interdisciplinary team meetings
  • Documentation: CMS proposes to codify existing documentation instructions and guidance to ensure uniformity between the Medicare Benefit Policy Manual and regulations that are applicable.
  • Definition of a Week: CMS clarifies that, for the purposes of the intensity of therapy requirement, a “week” would be defined as a period of seven consecutive calendar days beginning with the date of admission to the IRF.
  • Quality Reporting Program (QRP): The only provision impacting the QRP in the proposed rule is a two percent reduction to the applicable FY 2021 market basket increase factor for IRFs that fail to comply with quality data submission requirements.
  • Outlier Threshold: CMS proposes to update the outlier threshold amount from $9,300 for FY 2020 to $8,102 for FY 2021 ensure outlier payments account for 3 percent of total payments. CMS estimates there will be a $40 million increase in aggregate payments to IRFs due to this proposed change. The outlier threshold is used to determine when an IRF is entitled to an outlier payment. CMS attempts to set the outlier threshold each year so that 3 percent of total payments are outliers.

The proposed rule will be published in the April 21, 2020 edition of the Federal Register. A more in-depth analysis will be forthcoming following the publication. A fact sheet is also available for members to obtain additional information.

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Members are encouraged to participate in a CMS Lessons From the Front Lines: COVID-19 call on April 17, 2020 from 12:30 pm – 2:00 pm. The call is being hosted by the Centers for Medicare and Medicaid Services (CMS) Administrator, Seema Verma, FDA Commissioner Stephen Hahn, MD, and the White House Coronavirus Task Force. These are weekly calls and provide everyone with the opportunity to hear physicians and other clinical leaders share their experiences, best practices, strategies, and insights related to COVID-19.

To participate:
877-251-0301 / Access Code: 8672948

Webcast Streaming

Conference lines are limited, so members are encouraged to join via audio webcast, either on your computer or smartphone web browser.

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The Centers for Medicare and Medicaid Services (CMS) released a revised inpatient rehabilitation facility prospective payment system (IRF PPS) booklet. This booklet includes helpful information on IRF PPS, such as the many elements that make up IRF PPS, including the rates, facility characteristics, classification criteria, compliance percentage, and reasonable and necessary criteria; payment updates; quality reporting measures required for the fiscal year (FY) 2020 annual update; and resources.

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