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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 Office of Long-Term Living (OLTL) will conduct the next Community HealthChoices (CHC) Third Thursday webinar on Thursday, February 15, 2018, 1:30 pm – 3:00 pm. Providing updates during the webinar will be OLTL’s Acting Deputy Secretary, Kevin Hancock, and representatives from the three managed care organizations (MCOs): Pennsylvania Health and Wellness, AmeriHealth Caritas, and UPMC For You. Tentative agenda topics include CHC updates and launch indicators and transportation.

To register for the webinar, please use 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 login information: Username: OLL / Password: OLL.

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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The Department of Human Services’ (DHS) Office of Long-Term Living (OLTL) has updated the list of Frequently Asked Questions (FAQ) related to Community HealthChoices (CHC). Many of the FAQs have been generated through their Third Thursday CHC webinars, as well as questions received at the Southwest Participant Education meetings. The FAQs are separated by Provider FAQs and Participant FAQs.

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During the January 2018 Medicare Payment Advisory Commission (MedPAC) public meeting, the agenda included the topic of the Merit-based Incentive Payment System (MIPS). MedPAC members voted in favor of recommending Congress eliminate this system, stating the program was burdensome and complex. The presentation also cited that the program “Replicates flaws of prior value-based purchasing programs.” It was recommended that MIPS be replaced with a new model known as the voluntary value program (VVP). The VVP would include an across-the-board withhold for all fee schedule payments, and performance would be assessed using uniform measures across three categories, which include clinical quality, patient experience, and value. Those in favor of the new program indicated it would better prepare physicians to participate in the Medicare Access and CHIP Reauthorization Act’s (MACRA) Advanced Alternative Payment models.

The agenda included many additional topics of interest, some of which referenced increasing the equity of Medicare’s payments within each setting, mandated report on telehealth services and the Medicare program, and a status report on Medicare Accountable Care Organizations.

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On January 9, 2018, the Centers for Medicare and Medicaid Services (CMS) announced their launch of a new voluntary bundled payment model called the Bundled Payments for Care Improvement (BPCI) Advanced. BPCI Advanced will test a new iteration of bundled payments for 32 clinical episodes initially (29 Inpatient Clinical Episodes and 3 Outpatient Clinical Episodes) and will qualify as an advanced alternative payment model (APM) under the quality payment program (QPP). Participants can earn additional payment if all expenditures for a beneficiary’s episode of care are under a spending target that factors in quality.

The Model Performance Period for BPCI Advanced begins on October 1, 2018, and runs through December 31, 2023. For additional information about the model, including the Request for Applications document, application template, etc., visit the BPCI Advanced web page. Applications must be submitted via the application portal. The application portal will close on March 12, 2018.

An open door forum, BPCI Advanced – Model Overview and Application Process, has been scheduled for Tuesday, January 30, 2018, from 12:00 pm – 1:00 pm EST. Registration is now open.

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The Department of Defense (DoD) published the final rule, TRICARE; Reimbursement of Long Term Care Hospitals and Inpatient Rehabilitation Facilities, in the December 29, 2017 Federal Register. This final rule finalizes the changes in the inpatient rehabilitation facility (IRF) payments from the proposed rule that was published back in 2016 and establishes TRICARE inpatient care reimbursement methodologies and rates similar to Medicare. Currently, IRFs are exempted from the TRICARE diagnosis related group (DRG) based payment system and paid by TRICARE at the lower of a negotiated rate or billed charges.

 

To reduce the burden from sudden significant reductions on the IRFs, the final rule includes a gradual transition from TRICARE’s current policy of allowing 100 percent of allowable charges (either the billed charge or voluntary negotiated rate), by phasing-in the Medicare IRF prospective payment system (PPS) rates as follows:

  • Allowing 135 percent of Medicare IRF PPS amounts in the first 12-month period after implementation (estimated reduction of $24M);
  • 115 percent in the second 12-month period after implementation (an estimated reduction of $41M); and
  • 100 percent in the third 12-month period after implementation (an estimated $57M).

The DoD will apply the FY 2019 IRF PPS for purposes of the 12-month period beginning on October 1, 2018, and follow any changes adopted by the Medicare IRF PPS for subsequent years. The provisions in the final rule become effective on March 5, 2018.

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On December 11, 2017, the Centers for Medicare and Medicaid Services (CMS) issued Medicare Learning Network (MLN) Matters Article, SE17036, which provides information about new instructions recently issued to Medicare medical review contractors. The guidance also provides the standards to use when reviewing claims for compliance with the intensity of therapy requirements for inpatient rehabilitation facility (IRF) claims.

If you have any questions, please contact your MAC at their toll-free number, available online.

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The Centers for Medicare and Medicaid Services (CMS) published a final rule and interim final rule with comment period that cancels the Episode Payment Models (EPM) and Cardiac Rehabilitation (CR) Incentive Payment Model and rescinds the regulations governing these models in the December 1, 2017 Federal Register. It also implements certain revisions to the Comprehensive Care for Joint Replacement (CJR) model. Some of these revisions include:

  • Allowing certain hospitals selected for participation in the CJR model a one-time option to choose whether to continue their participation in the model;
  • Technical refinements and clarifications for certain payment, reconciliation, and quality provisions; and
  • Change to increase the pool of eligible clinicians that qualify as affiliated practitioners under the Advanced Alternative Payment Model (APM) track.

An interim final rule with comment period is also being issued in conjunction with the final rule in order to address the need for a policy to provide some flexibility in the determination of episode costs for providers located in areas impacted by extreme and uncontrollable circumstances.

Comments will be accepted on the interim final rule with comment period until January 30, 2018. The final and interim final regulations become effective on January 1, 2018.

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On November 13, 2017, the Centers for Medicare and Medicaid Services (CMS) began to post a list of potential audits for Recovery Audit Contractors (RACs) to review. The topics will be listed, on a monthly basis, on the Provider Resources page of the CMS website. The topics currently proposed include: review of pre-admission screening, post-admission examination, and other requirements for inpatient rehabilitation facility (IRF) stays. The review type is identified as a “complex review.” Comments or questions should be submitted via email.

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