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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 Centers for Medicare and Medicaid Services (CMS) has published a new “Outpatient Rehabilitation Therapy Services: Complying with Medicare Billing Requirements” booklet. Outpatient rehabilitation therapy services include physical therapy (PT), occupational therapy (OT), and speech-language pathology (SLP) services.

The booklet describes common outpatient rehabilitation therapy services Comprehensive Error Rate Testing (CERT) program errors, how CMS calculates improper payment rates, the necessary documentation to support billed Medicare Part B claims; and managing potential overpayments. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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The Centers for Medicare and Medicaid Services (CMS) identified a typographical error in the publication of the fiscal year (FY) 2020 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule that was published in the April 24, 2019 Federal Register. The error was in the calculation of the estimated burden for the IRF quality reporting program (QRP).

On page 17329 of the proposed rule it states, “Specifically, we believe that there will be an addition of 7.4 minutes on admission, and 11.1 minutes on discharge, for a total of 8.9 minutes of additional clinical staff time to report data per patient stay.” This sentence should have stated, “Specifically, we believe that there will be an addition of 7.8 minutes on admission, and 11.1 minutes on discharge, for a total of 18.9 minutes of additional clinical staff time to report data per patient stay.”

The final values and the overall burden proposed in the rule are correct despite these minor typographical errors. CMS will correct the figures in the final rule. A technical correction will not be issued due to the nature of the errors.

Contact Melissa Dehoff, RCPA Rehabilitation Services Division Director, with questions.

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The United States Senate Committee on Finance will conduct a full committee hearing (Medicare Physician Payment Reform After Two Years: Examining MACRA Implementation and the Road Ahead) on Wednesday, May 8, 2019 at 10:15 am. The purpose of the hearing will be to assess if the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 has been successful in reforming physician payments. Witnesses scheduled to present information during the hearing include individuals from: American Medical Association, American Academy of Family Physicians, American College of Surgeons, American Medical Group Association, and Brookings Institution.

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The Centers for Medicare and Medicaid Services (CMS) recently announced the Primary Cares Initiative, which includes a new set of payment models that will transform primary care to deliver better value for patients throughout the health care system. The initiative will seek to reduce administrative burdens and empower primary care providers to spend more time caring for patients while reducing overall health care costs. The initiative will be administered through the Center for Medicare and Medicaid Innovation (CMMI) under two paths: Primary Care First (PCF) and Direct Contracting (DC). The PCF payment models are focused on individual primary care providers, while the DC payment model options target a wider range of organizations that are capable of tending to larger patient populations and are experienced in handling financial risk, such as Medicaid managed care organizations, accountable care organizations, and Medicare Advantage plans.

The PCF models will be tested for five years and are currently scheduled to begin in January 2020. The DC models are expected to launch for a performance period in January 2021. CMS is seeking public comment on the DC model with comments being accepted until May 23, 2019.

Additional information is provided on the CMS website, including dates/times for webinars for interested stakeholders.

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The Office of Long-Term Living (OLTL) has scheduled and will be presenting webinars to Service Coordinators (SCs) to provide information about how the implementation of Community HealthChoices (CHC) will impact Attendant Care and Independence Waiver participants under the age of 21.

The implementation of CHC will change the way that Attendant Care and Independence Waiver participants who are under 21 years of age receive their Medicaid waiver services. All Attendant and Independence Waiver participants who live in Phase 3, and are not yet eligible for CHC because they are under 21 years of age, will transition to the OBRA Waiver until they become eligible for CHC.

All Phase 3 (Lehigh/Capital, Northwest, and Northeast counties) SCs serving participants who are under 21 years of age should plan to participate in this webinar.

Please register for one of the following dates:

After registering, you will receive a confirmation email containing information about joining the webinar.

If you have any questions regarding this communication, please contact the OLTL Participant Helpline Monday through Friday at 800-757-5042 from 9:00 am – 12:00 pm and 1:00 pm – 4:00 pm or via email at any time.

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The Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the inpatient rehabilitation facility prospective payment system (IRF PPS) for fiscal year (FY) 2020.

Some of the key proposals in the rule include:

  • Net Payments: Net payments for IRF’s would increase by 2.3 percent, including a 3.0 percent market basket update, offset by a statutorily mandated cut of 0.5 percentage points for productivity, and a 0.2 percent decrease in outlier payments. This update reflects the proposed revision and rebasing of the market basket using data from 2016 as the base year instead of 2012.
  • Case-Mix Revisions: The Functional Independence Measure (FIM) and Functional Modifier items were removed from the IRF Patient Assessment Instrument (PAI) as finalized in the FY 2019 IRF PPS final rule. CMS also indicated that the FY 2020 case-mix groups (CMGs) would be based on a patient’s motor function, age, memory function, and communication function. However, in this proposed rule CMS made the decision not to include the communication and memory scores because their inclusion in the CMG definitions resulted in lower payments for patients with cognitive deficits (based on their analysis of two years of data).
  • Outlier Threshold and Cost-to-Charge Ratio: CMS proposes to update the outlier threshold amount from $9,402 for FY 2019 to $9,935 for FY 2020 to ensure outlier payments account for 3 percent of total payments, as they did for FY 2019. CMS notes that its initial analysis showed that outlier payments would be 3.2 percent and made the above proposed adjustment to maintain it at 3 percent.
  • Rehabilitation Physician Definition: CMS proposes to clarify that compliance with the regulatory definition of “rehabilitation physician” (a licensed physician with specialized training and experience in inpatient rehabilitation) will be determined by the IRF. Currently, the regulations do not specify the level or type of training or experience that are required to satisfy this criteria.
  • Proposed Changes to IRF Quality Reporting Program (QRP): CMS proposes to adopt two measures to the IRF QRP with data collection for discharges beginning October 1, 2020.
  • Transfer of Health Information to the Provider
  • Transfer of Health Information to the Patient

Transfer of Health Information is a required domain of the IMPACT Act and CMS has been developing these measures since 2016. The measures are process-based measures that assess if a “current reconciled medication list” is given to either the subsequent provider or to the patient/family/caregiver when the patient is discharged or transferred from his or her current PAC setting. CMS proposes to start collecting the measure via the IRF-PAI for discharges beginning October 1, 2020.

  • Proposed Revision to Discharge to Community Measure: CMS proposes to revise the Discharge to Community post-acute care measure to exclude baseline nursing facility (NF) residents from the measures beginning with the FY 2020 IRF QRP due to stakeholder recommendations.

CMS proposes to define baseline NF residents as those who had a long-term NF stay in the 180 days preceding their hospitalization and IRF stay.

  • Proposed Standard Patient Assessment Data Elements (SPADEs): This proposal is slated for reporting beginning in October 2020. In line with the IMPACT Act, CMS is required to develop and collect standardized patient assessment data in PAC settings. In this rule, CMS proposes to adopt ”many of” the standardized patient assessment data elements (SPADEs) it had previously proposed in the FY 2018 IRF PPS proposed rule, as well adopt new SPADEs on social determinants of health. Some proposed items, such as the Brief Interview of Mental Status (BIMS), are currently on the IRF-PAI, in which case CMS is proposing to formally adopt them as SPADEs. However, most of the proposed items would entail adding new, additional reporting elements to the IRF-PAI.
  • Proposal to Collect All-Payer IRF PAI Data: CMS proposes to expand the reporting of the IRF-PAI data to include data on all patients, regardless of their payer, beginning with patients discharged on or after October 1, 2020.

The proposed rule will be published in the April 24, 2019 edition of the Federal Register. Comments on the provisions contained in the proposed rule will be accepted until June 17, 2019. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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The next Community HealthChoices (CHC) Third Thursday webinar has been scheduled for April 18, 2019 at 1:30 pm.

The agenda for this webinar will include Office of Long-Term Living (OLTL) Deputy Secretary Kevin Hancock providing updates on the CHC launch, with a special focus on monitoring report data from both the Southwest and Southeast regions.

If you wish to participate in the webinar, you must register using this link. After registering, you will receive a confirmation email containing information about joining the webinar.

If you require captioning services, please use this link and use the following login information:
Username: OLL  Password: OLL

Reminder: All CHC related information can be found online here. Comments can be submitted electronically via email.

If you have any questions, please contact the OLTL Bureau of Policy and Regulatory Management at 717-857-3280.

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Registration is now open for the upcoming Community HealthChoices (CHC) Educational Provider Sessions for Phase three regions of the state. The locations for each region are available on the RSVP pages through the links below.

Additionally, one day-long transportation summit will be held in each region. RSVP for this summit here.

The agenda for each summit is as follows:

  • 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

Prior to the summit meetings, emails will be sent to attendees regarding schedule, parking, and event location on each campus. Additionally, there is a CHC Questions and Answers (Q&A) document on the CHC website as a resource for additional questions.

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The Office of Long-Term Living (OLTL) issued a bulletin today that explains the Functional Eligibility Determination (FED) process, which is used to determine clinical eligibility for Medical Assistance Long-Term Services and Supports (LTSS). Previously, the assessors had used the level of care determination (LCD) tool.

Effective today, OLTL will use the FED process to determine and redetermine whether an individual is nursing facility clinically eligible (NFCE) or nursing facility ineligible (NFI). The FED process is a multi-step process that begins with an assessment and concludes with translating the assessment scores into a determination whether an individual is NFCE.

The bulletin includes details about the various sections of the FED tool itself and provides information on how the assessor enters the information and scores from the FED tool into the Pennsylvania Individualized Assessments (PIA).

Once the assessor enters the scores for an individual into the PIA, the PIA automated program translates the scores into a finding of NFCE or NFI. The bulletin includes a matrix that shows how the scores are translated and also includes examples.

Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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