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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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During the September 5–6, 2019 Medicare Payment Advisory Commission (MedPAC) public meeting, the agenda included a presentation that focused on a value incentive program (VIP) for post-acute care (PAC) providers. During the presentation, MedPAC reviewed their intention to develop this PAC-VIP over the coming months, which will tie providers’ payments under a unified PAC prospective payment system (PPS) to their performance on uniform cross-setting metrics. MedPAC feels PAC-VIP is essential to incentivize provider improvement. Some of the proposed measures to be included:

  • All-condition hospitalization within the PAC stay;
  • Successful discharge to the community; and
  • Medicare-spending per beneficiary (MSPB).

Performance will be scored using absolute, prospectively set targets, and a five percent withhold will fund the incentive payments, which is consistent with Medicare’s existing value-based programs. In addition, because there is variation in performance across settings, there will be an initial need to score within each setting.

Next steps include modeling the PAC-VIP based on the Commission’s feedback and presenting their results in the spring. MedPAC also seeks feedback on the design of the PAC-VIP, such as measure set, scoring methodology, and size of the withhold. Contact RCPA Director of Rehabilitation Services, Melissa Dehoff, with questions.

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The Office of Long-Term Living (OLTL) will conduct the next Community HealthChoices (CHC) Third Thursday webinar on September 19, 2019 at 1:30 pm. During this webinar, OLTL’s Deputy Secretary, Kevin Hancock, will provide updates on the CHC program. Registration is required to participate in the webinar. Once registered, you will receive a confirmation email containing information about joining the webinar.

Reminder: All CHC related information can be found here. Comments can be submitted electronically via email. If you have any questions, please contact the OLTL Bureau of Policy Development and Communications Management at 717-857-3280.

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In preparation for the roll-out of Phase III of Community HealthChoices (CHC), it was announced today that registration is now open for the upcoming Fall Educational Provider Sessions for the regions in Phase III. The locations for each region are included on the registration form.

The agenda for each session includes:

  • Registration: 8:30 am – 9:30 am
  • CHC Overview Presentation: 9:30 am – 12:00 pm
  • Lunch/MCO Meet and Greet: 12:00 pm – 1:30 pm
  • Breakout sessions: 1:30 pm – 3:30 pm

Leading up to the summits, emails will be sent to attendees regarding schedule, parking, and event location on each campus. If you encounter problems with registering, please notify this email with your necessary information, and they can register on your behalf.

Questions about CHC? The CHC Questions and Answers Document can be found on both the Participant and Provider sections of the CHC website.

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Beginning today, an update has been made to the Home and Community-Based Services (HCBS) application process completed by the Pennsylvania Independent Enrollment Broker (IEB) that will include the IEB scheduling the Intake Visit Assessment (IVA) as the first step of the enrollment process.

As a result of this update, the following changes will take place:

  • Upon initial contact with the applicant, the PA IEB will schedule an in-home visit, which includes an IVA within seven days, unless otherwise requested by the applicant.
  • The HCBS application will start on the day of the in-home visit, or upon receipt of a Commonwealth of Pennsylvania Application for Social Services (COMPASS) application, whichever occurs first.
  • At the in-home visit, the PA IEB will:
  • Review the enrollment process and give the applicant and others present at the IVA an overview of what they can expect;
  • Assist the applicant with completing the HCBS application and collecting all supporting documents available at the time of the IVA;
  • Answer questions and assist with HCBS information and choice counseling to make their Managed Care Organization (MCO) selection.

The goal of this change is to alleviate some challenges applicants encounter while trying to navigate the eligibility and enrollment process. Questions regarding this update should be directed to the Office of Long-Term Living (OLTL) Participant Enrollment Unit at 800-757-5042 or by email.

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The Centers for Medicare and Medicaid Services (CMS) recently announced the availability of a revised inpatient rehabilitation facility prospective payment system (IRF PPS) Medicare Learning Network (MLN) booklet. Topics in the booklet include: IRF PPS Elements (including rates, classification criterion, compliance percentage, and reasonable and necessary criteria); payment updates; IRF quality reporting program (QRP) measures for annual payment update; and many resources.

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Included in the August 24, 2019 Pennsylvania Bulletin was a notice from the Department of Human Services (DHS) about a change in the fee schedule rates for Personal Assistance Services (PAS) procedure codes (W1793, W1793TT, W1792, and W1792TU), and for Residential Habilitation procedure codes W0100 and W0102 in the Medical Assistance OBRA Waiver. The changes in the fee schedule rates for these services will be effective on January 1, 2020.

The existing fee schedule rates for PAS (Agency) and PAS (CSLA), procedure codes W1793 and W1793 TT, are increased by 2%. The intent of the increase is to provide for a wage increase for direct care workers providing agency-directed personal assistance services. DHS is also increasing the PAS (Consumer) and PAS (Consumer Overtime) rates, procedure codes W1792, and W1792 TU, to maintain equity in all the PAS rates in the OBRA waiver.

In addition, the existing fee schedule rates for Residential Habilitation procedure codes W0100 and W0102 are increased to include a 3 percent vacancy factor. A vacancy factor had not previously been included in the rate methodology; however, the Department recognizes that providers may not always deliver services to participants at full capacity. Therefore, a 3 percent vacancy factor will be applied to adjust the rates to account for the days the residential provider did not provide services to the participant. The provider cannot bill for days the participant did not receive services, but rather is paid a higher rate for days the participant received services. A vacancy factor of 3 percent was applied to reflect payment to providers for an average number of vacant days.

The fee schedule rates are available in the notice. Written comments regarding these fee schedule rates will be accepted through close of business on Monday, September 23, 2019 and should be sent to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: Marilyn Yocum, PO Box 8025, Harrisburg, PA 17105-8025. Comments may also be submitted to the Department via email. Comments received within 30 days will be considered in subsequent revisions to the fee schedule.

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The Department of Human Services (DHS) has released the Office of Long-Term Living’s (OLTL’s) proposed OBRA waiver amendments for public review and comment in the August 24, 2019 Pennsylvania Bulletin.

DHS proposes the following substantive changes to the OBRA waiver effective January 1, 2020:

  • Revise the Residential Habilitation service definition by modifying the number of hours that are defined as a day unit from a minimum of 12 hours to 8 hours.
  • To the service definitions of Job Finding, Job Coaching, Employment Skills Development, Career Assessment, and Benefits Counseling, add language that Office of Vocational Rehabilitation (OVR) services are considered not to be available if OVR has not made an eligibility determination within 120 days; and add language to address when employment services through the OBRA waiver can be provided should OVR close the order of selection, thereby creating a waiting list for OVR services.

In addition, DHS proposes to make the following technical edits:

  • Update Appendix C-2.b., Abuse Registry Screening, to reflect that the Department utilizes IDEMIA as the data system to process fingerprint-based Federal Bureau of Investigation (FBI) criminal record checks as well as other minor editorial changes to the section.

The proposed amendments and a summary of all of the revisions are available for review here.

Written comments regarding these proposed waiver amendments will be accepted through close of business on Monday, September 23, 2019 and should be sent to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: OBRA Waiver Amendments, PO Box 8025, Harrisburg, PA 17105-8025. Comments may also be submitted to the Department via email. Please use OBRA Waiver Amendments as the subject line.

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The Department of Human Services (DHS) has released the Office of Long-Term Living’s (OLTL’s) proposed Community HealthChoices (CHC) waiver renewal for public review and comment in the August 17, 2019 Pennsylvania Bulletin.  DHS proposes to renew the CHC waiver with an effective date of January 1, 2020 in order to be aligned with the calendar year.

Some of the proposed changes to the CHC waiver include:

  • Revise the Residential Habilitation service definition by modifying the number of hours that are defined as a day unit from a minimum of 12 hours to a minimum of 8 hours.
  • To the service definitions of Job Finding, Job Coaching, Employment Skills Development, Career Assessment and Benefits Counseling, add language that Office of Vocational Rehabilitation (OVR) services are considered to not be available if OVR has not made an eligibility determination within 120 days; and add language to address when employment services through the CHC waiver can be provided should OVR close the order of selection, thereby creating a waiting list for OVR services.
  • Modify the qualifications for Service Coordinators and Service Coordinator supervisors.
  • Clarify that, if a CHC Managed Care Organization (MCO) identifies that a participant has not been receiving services for 5 or more days, and if the suspension of services was not pre-planned, then the CHC-MCO must communicate with the participant to determine the reason for the service suspension within 24 hours. If the participant’s health status or needs have changed, then the CHC-MCO must conduct a comprehensive needs reassessment of the participant’s needs within 14 days of identifying the issue.
  • Add that an emergency back-up plan must be included in the Person-Centered Service Plan.
  • Remove and modify language to reflect that the CHC waiver will be fully operational Statewide as of January 1, 2020.
  • Update language to reflect that the Department utilizes IDEMIA as the data system to process fingerprint-based Federal Bureau of Investigation criminal record checks.
  • Update the OLTL bureau names and responsibilities.

The proposed CHC waiver renewal and a summary of all revisions are available for review here. Written comments regarding these proposed revisions will be accepted through close of business on September 16, 2019 and should be sent to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: CHC Waiver Renewal, P.O. Box 8025, Harrisburg, PA 17105-8025. Comments may also be submitted to the Department at RA-waiverstandard@pa.gov.

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On August 9, 2019, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2020 outpatient prospective payment system (OPPS) proposed rule. In addition to the proposed changes to the amounts used to determine the Medicare payment rates, this proposed rule updates and refines the requirements for the hospital outpatient quality reporting program. Included in this proposed rule is a provision that would require inpatient rehabilitation facilities (IRFs) and other hospitals to post certain payment information, which seeks to increase price transparency by requiring all hospitals in the United States to make hospital standard charges available to the public. It would also publish patients’ out-of-pocket costs for scheduled health care services. The rule also proposes to implement site-neutral payment rates for outpatient hospital physician visits that would align the payment amount for non-hospital physician visits. Comments on this proposed rule will be accepted through September 27, 2019. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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