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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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It has been reported that the Centers for Medicare and Medicaid Services (CMS) has issued letters of non-compliance to Inpatient Rehabilitation Facilities (IRFs) specific to the IRF quality reporting program (QRP) requirements for the data collection period affecting federal fiscal year (FFY) 2019 reimbursement. IRFs that did not meet the IRF QRP reporting requirements will receive a two percent payment reduction on their IRF prospective payment system (PPS) annual increase factor in FY 2019.

IRFs found to be non-compliant should have received notification from their Medicare Administrative Contractor (MAC) and are also expected to receive a letter in their provider Certification and Survey Provider Enhanced Reporting (CASPER) folder with specific details regarding the missing quality reporting data. Additional information on the data collections requirements and submission timeframes for FY 2019 compliance determination can be found in the CMS Data Collection & Final Submissions table posted on the CMS website, as well as the CMS IRF QRP website.

IRFs that feel they have received a non-compliance notification letter in error may request CMS reconsideration of the decision. Providers have 30 days to file a reconsideration request. Detailed filing instructions can be found on the IRF Quality Reporting Reconsideration and Exception & Extension web page.

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The June 2018 Medicaid and CHIP Payment and Access Commission (MACPAC) Report to Congress included a chapter on Managed Long-Term Services and Supports (MLTSS). The chapter provides an overview of MLTSS, the growing role of managed care in long-term services and supports, reviews the results of MACPAC’s initial work in this area, and identifies gaps in our knowledge about what drives     success in MLTSS programs. It also includes highlights of reports describing state MLTSS programs and program outcomes. In addition, the report focuses on operational issues and the future of MLTSS.

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The Centers for Medicare and Medicaid Services (CMS) recently announced the launch of their first Data Element Library (DEL). The DEL is the centralized resource for CMS assessment instrument data elements (e.g. questions and responses) and their associated health information technology standards. This free centralized resource will allow the public, for the first time, to view the specific types of data that CMS requires post-acute care facilities (such as inpatient rehabilitation facilities) to collect as part of the health assessment of their patients. Standardized and interoperable data support health information exchange across health care settings to facilitate care coordination, improved health outcomes, and reduced provider burden through the reuse of appropriate health care data.

The assessment items included in the DEL originate from the following:

  • Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI);
  • Long-Term Care Hospital Continuity Assessment Record & Evaluation (CARE) Data Set;
  • Resident Assessment Instrument (RAI) Minimum Data Set (MDS);
  • Outcome and Assessment Information Set (OASIS);
  • Hospice Item Set (HIS); and
  • Functional Assessment Standardized Items (FASI) (In Progress).

Contact Melissa Dehoff with any questions.

The Office of Long-Term Living (OLTL) released the following notice to Service Coordination Entities (SCEs) regarding a procedure code change for Cognitive Rehabilitation Therapy (CRT) Services.

This notice is to advise all SCEs that due to 2018 Healthcare Common Procedure Coding System (HCPCS) updates, the procedure code for Cognitive Rehabilitation in the Independence and OBRA Waivers will change effective 7/1/18. The service procedure code 97532 SE will be end-dated as of 6/30/2018. The new service procedure code for Cognitive Rehabilitation is 97127 and will be effective 7/1/18. The service definition and units of service remain the same. OLTL requires the attention and assistance of SCEs in order to update the service procedure code for HCSIS Fiscal Year (FY) 2018-2019 service plans.

OLTL is systemically removing the service procedure code of 97532 SE from any impacted HCSIS FY 2018-2019 service plans in order to end-date service contracts and offerings as of 6/30/18 for providers enrolled to render the service. A system update must be completed prior to making the new service procedure code of 97127 available for selection onto service plans.  A data fix is scheduled to occur in HCSIS on 6/21/18 to remove the remaining impacted 97532 SE service lines from FY 2018-2019 service plans. Please do not add the service 97532 SE to any additional FY 2018-2019 service plans as this will impact the success of the data fix. The new service procedure code of 97127 will be added to HCSIS and available for selection onto service plans as of 6/25/18. Service Coordinators (SCs) will be required to add the new service code for impacted FY 2018-2019 service plans.

Once the service is available for selection onto FY 2018-2019 service plans, SCs will then submit a Critical Revision to OLTL for review and approval for the addition of the new service procedure code 97127. OLTL’s Service Plan Review Team within the Bureau of Participant Operations will be communicating with SCEs that are directly impacted by this service procedure code change. A separate email communication will be sent to impacted SCEs to provide additional detail and guidance.

If you have any questions regarding the necessary service plan updates, please contact the Bureau of Participant Operations or Stacey Griffiths with the Bureau of Participant Operations at: 717-724-6547.

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The Centers for Medicare and Medicaid Services (CMS) has scheduled a call on Thursday, June 21, 2018 at 2:00 pm that will focus on and provide additional information about the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. During the call, CMS will answer frequently asked questions (FAQs) on quality measures, standardized data elements, the CMS data element library, and future directions of the IMPACT Act. Members that wish to participate in the call must register. Send any questions or request assistance with registration via email.

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The Pennsylvania Department of Health (DOH), Bureau of Family Health (BFH) has been awarded the Administration for Community Living (ACL) Traumatic Brain Injury (TBI) State Partnership Program Mentor Grant. This funding opportunity will allow for the BFH to develop a NeuroResource Facilitation Program. The program will connect families and individuals with TBI to services and resources through case management. The BFH will also fund brain injury education and training to increase knowledge of TBI with a focus on TBI screening in the juvenile justice and the older adult population. The overall project aim is to help maximize the health, independence, and well-being of persons with TBI and their families in Pennsylvania. Through the Mentor Grant Program, the BFH will also mentor other states to assist with enhancing their programming, and will collaborate with ACL and other Mentor States to build on the overall TBI infrastructure. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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As a result of the many Community HealthChoices (CHC) stakeholder events, the Department of Human Services (DHS) has added frequently asked questions (FAQ) documents to the CHC website for providers and participants.

To assist stakeholders in finding answers to questions more quickly, DHS recently consolidated all FAQs into a single CHC Questions and Answers document. This new document is in a searchable pdf format and contains a table of contents that allows the user to easily move to different sections within the document.

For more information, visit the DHS CHC web page.

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The Centers for Medicare and Medicaid Services (CMS) has posted a number of various inpatient rehabilitation facility patient assessment instrument (IRF PAI) resources to their website, including the RTI International Report on patient assessment data elements.

Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Proposed Rule for FY 2019: Reminder: Comments are due by June 26, 2018. See May 4, 2018 RCPA Info for additional information on the proposed provisions.

PROPOSED IRF-PAI Version 3.0: The proposed assessment tool indicates an effective date of October 1, 2019. However, the fiscal year (FY) 2019 IRF prospective payment system (PPS) proposed rule indicates it will be effective in FY 2020.

Change Table: Proposed IRF-PAI Version 3.0 – Effective October 1, 2019 (FY 2020) – Changes from Version 2.0 to 3.0: This table highlights the differences between the IRF PAI Version 3.0 and IRF PAI Version 2.0.

RTI International Report: Analyses to Inform the Potential Use of Standardized Patient Assessment Data Elements in the Inpatient Rehabilitation Facility Prospective Payment System: This report includes a summary by RTI on the use of  assessment data in the current IRF PPS and describes the process used to substitute data from the quality indicators sections of the IRF PA into the IRF PPS. The report also presents the case-mix groups (CMGs) and payment weights based on those elements that CMS proposes for FY 2020.

Contact Melissa Dehoff with questions.

On May 11, 2018, the US Department of Veterans Affairs (VA) announced a new federal rule that will allow VA doctors, nurses, and other health care providers to administer care to Veterans using telehealth, regardless of where in the United States the provider or Veteran is located. This includes across state lines and outside of a VA facility.

Previously, it was unclear whether VA providers could furnish care to Veterans in other states through telehealth because of licensing restrictions or state-specific telehealth laws. This new rule exercises federal preemption to override those state restrictions, paving the way for VA to expand care to Veterans using telehealth.

The Office of Long-Term Living (OLTL) recently announced that they will be offering an “Opioid 101” webinar on Wednesday, May 30, 2018 at 1:00 pm.

This webinar will discuss the basics of opioid medications; what they are, how they work, and how substance use disorder is identified and treated. Additionally, the discussion will include current safe prescribing guidelines and alternative methods for managing chronic pain, information on how to recognize and respond to an overdose, how naloxone works, and how individuals can obtain it.

The webinar presenters include: Jordan Lewis, PhD, Public Policy Research Analyst, William Penn Fellow, Pennsylvania Department of Drug and Alcohol Programs; Mr. Tim Rader, Chief, Training Section, Pennsylvania Department of Drug and Alcohol Programs; Ms. Sarah Boateng, Executive Deputy Secretary, Pennsylvania Department of Health; Mr. Jeff Geibel, Chief, Treatment Division, Pennsylvania Department of Drug and Alcohol Programs.

To participate in this webinar, individuals are required to register using this link. A confirmation email will be sent that includes additional information about the webinar.

Questions regarding this webinar should be directed to Edward Butler via email or phone at 717-214-3718.