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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) released the display copy of the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

Key highlights from the proposed rule:

  • Proposed Removal of FIM: Being the most significant proposal, CMS proposes to remove the Functional Independence Measure (FIM) instrument, as well as the associated Functional Modifiers, from the IRF Patient Assessment Instrument (PAI).
  • Changes to the IRF Coverage Requirements: There are several proposed changes to the coverage requirements:
    • Post-Admission Physician Evaluation: CMS is proposing allowing the post-admission physician evaluation to count towards one of the required three weekly face-to-face physician visits.
    • Physician Attendance at Interdisciplinary Team Meeting: CMS is proposing to amend the regulations to allow the rehabilitation physician leading the required interdisciplinary team meeting to attend the meeting remotely (via video conference or teleconference).
    • Admission Order Documentation Requirement: CMS is proposing to remove the requirement that there be a physician order for inpatient care when the patient is admitted since this requirement is included under the Medicare Conditions of Participation (CoPs) regulations.
    • Requests for Information on Physician Requirements: CMS is seeking information on specific areas where they can alleviate burden through changes to requirements pertaining to physician supervision in an IRF. CMS is also seeking information on the use of non-physician practitioners (NPPs) in IRFs.
  • Proposed Changes to IRF QRP – CMS is proposing to remove two measures from the IRF Quality Reporting Program (QRP):
    • National Healthcare Safety Network (NHSN) Facility-wide Inpatient Hospital-onset Methicillin-resistant Staphylococcus Aureus (MRSA) Bacteremia Outcome Measure (NQF #1716); and
    • Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short Stay) (NQF #0680).
  • Display of Functional Outcomes Measures Data on IRF Compare: CMS proposes to begin publicly displaying data on the following assessment-based measures in calendar year (CY) 2020 on IRF Compare:
    • Change in Self-Care (NQF: #2633);
    • Change in Mobility Score (NQF: #2634);
    • Discharge Self-Care Score (NQF: #2635); and
    • Discharge Mobility Score (NQF: #2636)

CMS has published a fact sheet that provides additional information on the proposed rule. The proposed rule will be published in the May 8, 2018 Federal Register, with comments being due by June 26, 2018.

The Department of Health and Human Services (HHS) has committed to improving the Medicare claims appeals process. This commitment includes the internal implementation of an expanded Settlement Conference Facilitation (SCF) program by the Office of Medicare Hearings and Appeals (OMHA). SCF is an alternative dispute resolution process at OMHA that gives certain providers and suppliers an opportunity to resolve their eligible Part A and Part B appeals.

 

In order to educate all Medicare Part A and Medicare Part B providers and suppliers who have OMHA or Medicare Appeals Council appeals pending, an SCF Expansion Open Door Call will be held on Tuesday, May 22, 2018 at 1:30 pm. The call will focus on the logistics of the SCF process and SCF eligibility criteria. Providers that plan to join the call are encouraged to submit their questions in advance via email and include “SCF May 22 Call” in the subject line. To participate, registration is required. Additionally, providers are encouraged to read the updated SCF expansion materials, including an SCF Expansion Frequently Asked Questions document, on the website.

Due to the Southeast Community HealthChoices (CHC) provider meetings being held in Philadelphia on June 4 – June 8, 2018, the Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting scheduled for June 6, 2018 has been rescheduled for Wednesday, May 30, 2018. The May 30 MLTSS Subcommittee meeting will be held at the Pennsylvania Department of Education, Honor’s Suite, 1st Floor, 333 Market Street Tower, Harrisburg, PA 17126 from 10:00 am to 1:00 pm.

If you have any questions, please contact the Office of Long-Term Living via email or call 717-857-3280.

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The Centers for Medicare and Medicaid Services (CMS) issued revised Change Request (CR) 10531 (MLN Matters Number: 10531). The article, “Claims Processing Actions to Implement Certain Provisions of the Bipartisan Budget Act of 2018,” was revised and provides direction to Medicare Administrative Contractors (MACs) to reprocess claims related to several provisions of the Bipartisan Budget Act of 2018. The initial MLN article was released on March 26, 2018.

On February 9, 2018, Congress passed the Bipartisan Budget Act of 2018, which contains a number of provisions that extend certain Medicare Fee For Service (FFS) policies, including Ambulance add-on payment provisions and a three percent home health Rural Add-on Payment. In addition, the Act permanently repeals the outpatient therapy caps beginning on January 1, 2018, while retaining the requirement to submit the KX modifier for services in excess of the prior cap amounts. Due to the retroactive effective dates of these provisions, various Medicare FFS claims shall be reprocessed. This CR provides guidance to MACs regarding Medicare FFS claims reprocessing requirements and time frames.

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Registration is now open for providers interested in attending a free two-day, in person training session on the inpatient rehabilitation facility quality reporting program (IRF QRP). The session, scheduled for Wednesday, May 9 –  Thursday, May 10, 2018 in Baltimore, MD will be hosted by the Centers for Medicare and Medicaid Services (CMS).

The primary focus of this “Train-the-Trainer” event will be to provide those responsible for training staff at IRFs with information about IRF QRP changes and updates to the Inpatient Rehabilitation Facility–Patient Assessment Instrument (IRF-PAI) v. 2.00, effective October 1, 2018. Topics will include information on new items, including those associated with the drug regimen review quality measure. Presenters will also discuss resources available on the CMS website, support available through the IRF help desks, public reporting, and use of reports to aid providers in better understanding the IRF QRP.

Additional information, including the registration page and agenda, is posted on the CMS website. Interested providers are encouraged to register as soon as possible as the in-person training is limited to the first 200 people on a first-come, first-served basis.

The training will not be available via webcast, but will be available via a link from the IRF QRP training web page after the training has completed.

The Pennsylvania Department of Health (DOH) has created a brain injury identification wallet card. The card was created as a result of a telephone call from an individual with a brain injury who moved from another state. The individual was inquiring as to whether PA had a card that could be used in emergent situations that would easily identify him as having a brain injury and his symptoms. The wallet card is available on the DOH website. The intent of the card is to provide a document for individuals with a brain injury that could be used to communicate their symptoms and emergency information to emergency personnel or the public.

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Today, the Centers for Medicare and Medicaid Services (CMS) released the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) transfer of health measures for public review and comment. CMS contracted with the RTI International and Abt Associates to develop cross-setting post-acute care transfer of health information and care preferences quality measures in alignment with the IMPACT Act.

As part of its measure development process, CMS is requesting comments on two draft measure specifications, including:

  1. Medication Profile Transferred to Provider
  2. Medication Profile Transferred to Patient

Additional information is provided on the public comment page on the CMS website. The public comment period closes on May 3, 2018.

The Office of Long-Term Living (OLTL) is offering a webinar on Tuesday, April 10, 2018, at 9:00 am that will focus on the topic of Pennsylvania Resources for Funding Assistive Technology. Assistive technology devices help make it possible for individuals with disabilities to work, live independently in their own homes, go to school, and participate in the community. Mrs. Susan Tachau, Chief Executive Officer (CEO) of the Pennsylvania Assistive Technology Foundation (PATF), will conduct the webinar.

Registration is required to participate in the webinar. Registrants will receive a confirmation email containing information about joining the webinar. Questions should be directed to Edward Butler, OLTL, at 717-214-3718.

On March 9, 2018, Representative Tina Pickett introduced House Resolution 741 designating the month of March 2018 as “Brain Injury Awareness Month” in Pennsylvania. The resolution was adopted (188–0) on March 14, 2018. A similar co-sponsorship memo was introduced in the Senate by Senator Schwank and will be voted on in the near future. March is nationally recognized as Brain Injury Awareness Month as well.

Due to cancellation of the March 7 Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting, the meeting has been rescheduled for Monday, March 19, from 10:00 am to 1:00 pm in the Honor’s Suite at 333 Market Street Tower in Harrisburg.

Attendance via phone/webinar:
If you wish to participate in the MLTSS Subcommittee meeting on March 19, but can’t attend in person, the option to participate via webinar is being offered. Provided below is the webinar link and dial-in information for the meeting.

Technology:
The Department of Human Services, Office of Long-Term Living is using technology similar to that used at Third Thursday webinars for MLTSS Subcommittee meetings. This technology allows individuals to participate in the webinar and listen in through computer speakers instead of participating by webinar and dial in. Dial in will still be available if you do not participate by webinar only, but the number is no longer toll free.

To participate in the meeting via webinar, please register by clicking on the link below. Members participating via webinar are encouraged to register early. When registering, please verify that you entered your email address correctly. You will receive a confirmation email containing information about joining the webinar if you registered correctly.

Webinar Registration Link:
https://attendee.gotowebinar.com/register/1406232880227054595

Dial-In Number:
The dial in number is: 1-415-655-0052; Access Code: 722-088-701

If you have any questions about registering for the webinar or require a toll free number to dial in, please contact the Office of Long-Term Living. For questions regarding this email, call 717-857-3280.