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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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President Trump recently signed the Executive Order on Advancing American Kidney Health. The purpose of this Executive Order (EO) is to improve kidney health and promoting increased treatment options for Americans suffering from kidney disease. The kidney health initiative seeks to prevent kidney failure through better diagnosis, treatment, and preventative care; increase affordable alternative treatment options, educate patients on treatment alternatives, and encourage the development of artificial kidneys; and increase access to kidney transplants by modernizing the transplant system and updating counterproductive regulations. Under the executive order, Medicare will test adjusting payment incentives to encourage preventative kidney care and the use of home dialysis and kidney transplants.

Following the issuance of this EO, the Centers for Medicare and Medicaid Services (CMS) announced in a press release five new CMS Center for Medicare and Medicaid Innovation (CMMI) payment models that aim to transform kidney care in order for patients with chronic kidney disease to have access to high quality, coordinated care. One of the models, the proposed End-Stage Renal Disease Treatment Choices (ETC) Model, would encourage greater use of home dialysis and kidney transplants for Medicare beneficiaries with end-stage renal disease (ESRD) in order to enhance their quality of care while reducing Medicare expenditures. Under the proposed ETC Model, CMS would make certain payment adjustments that would encourage participating ESRD facilities and Managing Clinicians to ensure that ESRD beneficiaries have access to, and receive education about, their kidney disease treatment options. CMS would positively adjust certain Medicare payments to participating ESRD facilities and Managing Clinicians for the first three years of the model for home dialysis and dialysis-related services. The payment adjustments under the proposed ETC model would begin January 1, 2020, and end June 30, 2026.

The other optional models announced by CMS are the Kidney Care First (KCF) Model and the Comprehensive Kidney Care Contracting (CKCC), which includes the Graduated, CKCC Professional, and Global models that are designed to help health care providers reduce the cost and improve the quality of care for patients with late-stage chronic kidney disease and ESRD. These models also aim to delay the need for dialysis and encourage kidney transplantation. The final model announced by CMS is the Radiation Oncology (RO) model aimed at improving the quality of care for cancer patients receiving radiotherapy treatment. This model, which would involve required participation, would test whether prospective site neutral, episode-based payments to physician group practices (PGPs), hospital outpatient departments (HOPD), and freestanding radiation therapy centers for radiotherapy (RT) episodes of care would reduce Medicare expenditures while preserving or enhancing the quality of care for Medicare beneficiaries.

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

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The Centers for Medicare and Medicaid Services (CMS) recently announced an upcoming in person inpatient rehabilitation facility quality reporting program (IRF QRP) training. This two-day “train-the-trainer” event for providers is scheduled for August 15–16, 2019 at the Four Seasons Hotel, 200 International Drive, Baltimore, MD 21202.

The primary focus of this training, which is open to all IRF providers, associations, and organizations,  will be to provide those responsible for training staff at IRFs with information about IRF QRP changes and updates to the IRF Patient Assessment Instrument (PAI) v.3.0, which will become effective on October 1, 2019. Topics will include, but are not limited to:

  • An overview of the changes between the IRF-PAI v.2.0 and v.3.0;
  • Updated training materials for Section GG, which will include videos of patient scenarios; and
  • An interactive session on the use of reports to identify opportunities for process improvement and utilize information contained in reports available via the Certification and Survey Provider Enhanced Reports (CASPER) system, which will be used to develop quality improvement plans.

A full agenda is available for both days of the training. Registration is limited to 100 people on a first-come, first-served basis. Questions or additional information requests should be sent to the PAC Training mailbox.

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The Department of Human Services (DHS) has released a Request for Information (RFI) to gather input from vendors and other stakeholders on the specific measures it may undertake to improve the quality, consistency and effectiveness of the Office of Long-Term Living’s (OLTL’s) Independent Enrollment Broker’s (IEB’s) services.

This RFI will gather input and information concerning the application and enrollment services and support services for the beneficiaries of two Medical Assistance (MA) managed care programs, one 1915(c) MA home and community-based services (HCBS) waiver program and a state-funded program, all administered by the DHS OLTL. Through these programs, eligible beneficiaries receive long-term services and supports (LTSS) and other benefits, depending on the particular program.

Specifically, DHS issued this RFI to solicit input on its potential strategies and solutions to improve the LTSS application and enrollment services and beneficiary support services provided by the OLTL’s IEB to individuals who apply for and enroll in the Community HealthChoices (CHC) Program, the Pennsylvania Living Independence for the Elderly Program (LIFE), the OBRA Waiver and the state-funded Act 150 Attendant Care Program.

DHS is requesting that all responses to the RFI be submitted by 12:00 p.m. on July 29, 2019. Responses must be submitted electronically to the following email account with “OLTL Application and Enrollment Services RFI” in the email subject line: RA-PWRFICOMMENTS@PA.GOV.

DHS does not intend to respond to questions or clarifications during the RFI response period; however, respondents may submit questions related to the RFI electronically to: RA-PWRFICOMMENTS@PA.GOV using “OLTL Application and Enrollment Services RFI question” in the email subject line. DHS may or may not respond based on the nature of the question.

If you have any questions regarding this email please contact Michael Hale, Bureau Director, Fee for Service Programs at mhale@pa.gov.

RCPA will be scheduling teleconference calls in the coming weeks to review this RFI and obtain feedback from members.

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On June 30, 2019, the continuity of care period for long-term services and supports (LTSS) for Phase II (southeast region) ended. As a result, Community HealthChoices (CHC) is now live in this region of the state. Providers should be aware of questions this may generate from CHC participants, such as a change to their service coordinator or a change they may experience with the services they receive (amount, duration, or frequency).

A CHC Managed Care Organization (MCO) must notify the Office of Long-Term Living (OLTL) in writing of its intent to terminate contracts with a provider, and services that a provider offers, 90 days before the termination’s effective date. Procedures to address the termination’s impact on participants should be in place and participants must be notified in writing 45 days before the effective date.

OLTL will continue to monitor notification requirements, service plan changes, service denial notices, complaints, and grievances despite the continuity of care period ending. CHC-MCOs will be held accountable for meeting notification requirements to ensure participants are properly informed and continue to receive necessary services without unexpected disruption.

Participants with questions or concerns about changes to services or service delivery should contact their CHC-MCO. If questions remain after talking with their CHC-MCO, participants can contact OLTL at 800-757-5042.

There are resources available to answer questions, etc. including a fact sheet, a question and answer document, and online training.

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The Office of Long-Term Living (OLTL) will conduct their next Community HealthChoices (CHC) Third Thursday webinar on Thursday, June 20, 2019 at 1:30 pm. During the webinar, OLTL Chief of Staff, Jill Vovakes, will provide updates on the CHC program.

  • Register here for the webinar. 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 login information:
    Username: OLL /  Password: OLL

Reminder: All CHC related information can be found online. Comments can be submitted 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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Today, the following important notice was issued by the American Medical Rehabilitation Providers Association (AMRPA) regarding a historic appeal settlement that they, along with the FAIR Fund and the Federation of American Hospitals, reached with the Centers for Medicare and Medicaid Services (CMS) that will allow inpatient rehabilitation facilities (IRFs) to settle their pending Medicare appeals.

Today CMS, AMRPA, the FAIR Fund, and the Federation of American Hospitals announced that an agreement has been reached with CMS which will allow IRFs to settle their pending Medicare appeals. For most pending claims, providers will be able to settle their pending appeals for 69% of the net payable amount of the claim. This is the highest percentage global settlement CMS has ever agreed to. In addition, some claims, such as those denied for failing to justify the use of group therapy, can be settled at 100% of the net payable amount. Here are some of the key things AMRPA members should know:

  • The settlement is voluntary. Providers can choose whether to settle their claims or continue to exercise their appeal rights.
  • Providers choosing to settle claims will receive 69% of the net payable amount (Medicare approved amount, less any applicable deductible or co-insurance).
  • Claims denied solely on the basis of threshold of therapy time not being met (3-hour or 15-hour rule), where the claim did not undergo further review for medical necessity, will be paid at 100% of the net payable amount. Claims denied solely because justification for group therapy was not documented will also be paid at 100% of the net payable amount.
  • If participating in the settlement, providers must settle all currently pending appeals. Providers cannot choose only select claims to settle.
  • To be eligible for settlement, the claim must have been denied in full, and the denial must have been appealed on or before August 31, 2018. The appeal must also still currently be pending at any level of appeal, and appeal rights must not have been exhausted at time of settlement.

Providers should read the entire template agreement for additional important details. CMS has provided instructions for how providers can participate in the settlement on its website.

This settlement was reached due to the diligent efforts of AMRPA’s sister organization, the FAIR Fund, in collaboration with AMRPA and the Federation of American Hospitals. AMRPA would especially like to thank longtime counsel to AMRPA and the FAIR Fund, Peter Thomas and Ron Connelly of Powers Law Firm, whose dedication to the rehabilitation field led to this historic settlement.

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

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The Centers for Medicare and Medicaid Services (CMS) has issued a press release with a Request for Information (RFI) seeking new ideas from the public on how to continue progress of the Patients Over Paperwork Initiative to be published in the June 11, 2019 Federal Register. The initiative was originally launched in the fall of 2017. Since that time, CMS estimates that through regulatory reform alone, the health care system will save an estimated 40 million hours and $5.7 billion through 2021. These estimated savings come from both final and proposed rules.

This RFI invites patients and their families, the medical community, and other health care stakeholders to recommend further changes to rules, policies, and procedures that would shift more of clinicians’ time — and our health care system’s resources — from needless paperwork to high quality care that improves patient health. CMS is especially seeking innovative ideas that broaden perspectives on potential solutions to relieve burden and ways to improve:

  • Reporting and documentation requirements;
  • Coding and documentation requirements for Medicare or Medicaid payment;
  • Prior authorization procedures;
  • Policies and requirements for rural providers, clinicians, and beneficiaries;
  • Policies and requirements for dually enrolled (i.e., Medicare and Medicaid) beneficiaries;
  • Beneficiary enrollment and eligibility determination; and
  • CMS processes for issuing regulations and policies.

Comments on this initiative must be submitted by August 12, 2019. For additional information, visit the Patients over Paperwork page on the CMS website.

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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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