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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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On January 27, 2016, a letter was sent to Department of Human Services (DHS) Secretary Ted Dallas, requesting reconsideration of DHS’ decision to raise the minimum age of eligibility for Community HealthChoices (CHC). RCPA was one of more than 35 organizations and individuals that signed this letter of support.

Currently, the minimum age of eligibility for the Attendant Care, Independence, and OBRA waivers is 18. However, the CHC Request for Proposal (RFP) states, “CHC will serve adults age 21 or older who require Medicaid Long-Term Services and Supports (MLTSS) (whether in the community or in private or county nursing facilities)…. and current participants in DHS’ (Office of Long-Term Living) waiver programs who are 18-to 21 years old.” This would change the minimum age for home and community-based services administered by OLTL to age 21.

Concern was noted in the letter of how raising the minimum age of eligibility for CHC will create large gaps in services. Many examples were elaborated on the services that keep young adults in their homes and communities and out of institutional care, including home modifications, vehicle modifications, assistive technology, respite, and residential habilitation. The letter urges DHS to fix this critical problem before the CHC RFP is finalized.

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The RCPA Brain Injury Committee meeting, scheduled for January 13 from 10:00 am to 2:00 pm, will have a different focus from the regularly scheduled bi-monthly committee meetings.

Due to the timing of Community HealthChoices and all that has transpired, including the Managed Care Organization (MCO) Meet and Greet session for Brain Injury Providers planned for January 14, and the advancement of the RCP-SO for Community HealthChoices, the meeting will focus on these key important topics that will impact the brain injury providers.

Dr. Richard Edley, RCPA President/CEO, will be in attendance to provide everyone with updates on the one-to-one meetings that have been held with Managed Care Organizations regarding brain injury services, as well as updates regarding the RCO-SO offering. He will also answer any questions you may have on these issues.

Due to the importance of this meeting, members are encouraged to either attend or participate via webcast. If you have not registered yet, please do so as soon as possible.

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DHS and PDA Invite Brain Injury Providers to Meet With MCOs Interested in Community HealthChoices

The Departments of Human Services (DHS) and Aging are continuing to develop Community HealthChoices (CHC), Pennsylvania’s plan for managed long-term services and supports. The success of CHC will be determined by a number of factors, including the relationships between future managed care organizations (MCOs) and existing providers. It is extremely important to continue the conversation with MCOs and Pennsylvania’s experienced providers, to successfully transform the fee-for-service system to managed care.

An invitation has been extended to RCPA’s Brain Injury Committee members to participate in an upcoming MCO meet and greet session, exclusively for brain injury providers. As a part of this invitation, we were asked to establish a panel and presentation, as well as participate in a facilitated discussion with the MCOs. Because of the importance of this meeting, please plan on sending at least one representative from your organization to this event. We have also been asked to submit questions we may have for the MCOs prior to the meeting date.

The meeting is scheduled for Thursday, January 14 from 11:30 am to 2:30 pm at the Hilton Harrisburg, 1 North 2nd Street. This will be a working lunch meeting (boxed lunches will be provided to registered attendees). Registration/RSVP is required.

Please respond to Melissa Dehoff if you will be attending. Responses are due no later than Monday, January 11, so the list of attendees can be provided prior to the meeting and the appropriate number of lunches ordered.

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On December 11, 2015, the Centers for Medicare and Medicaid Services (CMS) posted an update to the inpatient rehabilitation facility (IRF) quality reporting spotlight & announcements page of their website, regarding an extension of the IRF quality reporting program data submission. CMS made the decision to extend the National Healthcare Safety Network (NHSN) data submission deadline for IRF providers until Monday, February 15, 2016. The extension also applies to the submission deadline to the calendar year 2015 quarters 1 and 2, fiscal year 2017 payment determination. In addition, the extension applies to the submission deadlines for assessment data for the quality reporting program.

Members are encouraged to run the applicable CMS output reports within their facility prior to each quarterly reporting deadline. Detailed guidance on how to run and interpret these reports, and additional information, are posted on the Centers for Disease Control and Prevention (CDC) website. Additionally, once these reporting deadlines have passed, members should run the advanced analysis reports within NHSN to view when each data element was first entered and last modified, to determine whether all data were complete at the time of the reporting deadline.

Additional information on how to run and interpret these reports is provided by the CDC/NHSN. Questions on the reports within NHSN should be directed to the NHSN help desk. Additional questions can be directed to the CMS help desk.

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Pursuant to Executive Order 1996-1, the State Board of Physical Therapy (PT) has requested member comments and suggestions on two draft rulemakings.

The first draft rulemaking, 16A-6518-Foreign Trained Evaluation, would amend the board’s regulations so that a foreign-trained applicant would be required to submit an evaluation showing that the applicant’s training was equivalent to what is required in a program accredited by the Commission on Accreditation in Physical Therapy Education (CAPTE) — the accrediting body for United States programs — rather than program contents specified in the regulations.

The second draft rulemaking, 16A-6519-Student in Master’s Program Statement of Policy, is for a statement of policy that would make clear that, for purposes of the exception to the licensure requirement for physical therapy students, the term “Board-approved School” includes all physical therapy programs at a school that has a program accredited by CAPTE, as CAPTE accredits only pre-licensure programs.

The State Board of PT welcomes comments on these draft rulemakings. Comments are due by Friday, January 15, 2016, and should be submitted via email. Please specify rulemaking 16A-6518 (foreign-trained applicant evaluation) or 16A-6519 (student in master’s program) as appropriate on your comments.

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On December 10, 2015, the Legislative Budget and Finance Committee (LB&FC) released and presented their report, Implementation of the PA Safety in Youth Sports Act, pursuant to HR 2014-1064. This bill called on the House of Representatives to direct the LB&FC to assess compliance with the Safety in Youth Sports Act, determine the best practices for managing concussions and traumatic brain injuries, and make recommendations on provisions of the act that should be strengthened to be more effective.

While changes were not recommended to the current act, there was concern expressed that concussions are still not taken as seriously as they should be. As a result, it was recommended that the Pennsylvania Department of Education (PDE) develop additional guidelines and recommended practices for schools to follow with regard to identifying, assessing, and managing student athletes suspected of having sustained a concussion. The recommendation was made to PDE to consider the guidelines developed by the New York Department of Education (Guidelines for Concussion Management in the School Setting) as a possible model. The report was accepted and approved to be released.

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The Centers for Medicare and Medicaid Services released a Request for Information (RFI) in the November 20, 2015 Federal Register. The RFI is geared to Inpatient Rehabilitation Facilities (IRFs) and will assist in the design and development of a survey regarding patient and family member experiences with the care received in the IRF. Comments will be received until 5:00 pm on Tuesday, January 19, 2016.

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Today, the Departments of Human Services and Aging announced the release of the draft of the request for proposal (RFP) to procure Community HealthChoices (CHC) and the program requirements that will be part of the agreement with the managed care organizations (MCOs).

The draft RFP, program requirements, and a summary document are available on the CHC website. Comments on the draft RFP should be sent via email (with “Community HealthChoices” in the subject line) by Friday, December 11, 2015.

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Today, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule, Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies. This revises the discharge planning requirements for hospitals (including inpatient rehabilitation facilities and long term care hospitals), critical access hospitals, and home health agencies; these requirements must be met in order to participate in the Medicare and Medicaid programs. The proposed rule also implements the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, which strives to improve consumer transparency and beneficiary experience during the discharge planning process, by developing a discharge plan based on the goals, preferences, and needs of each patient.

 

Under the proposed rule, hospitals would be required to develop a discharge plan within 24 hours of admission or registration and complete a discharge plan before the patient is discharged home or transferred to another facility. These requirements will apply to all inpatients, and certain types of outpatients, including patients receiving observation services, patients undergoing surgery (or other same-day procedures where anesthesia or moderate sedation is used), and emergency department patients who have been identified as needing a discharge plan. In addition, hospitals will be required to:

  • Provide discharge instructions to patients who are discharged home;
  • Have a medication reconciliation process with the goal of improving patient safety by enhancing medication management;
  • For patients who are transferred to another facility, send specific medical information to the receiving facility; and
  • Establish a post-discharge follow-up process.

The proposed rule is scheduled to be published in the November 3, 2015 Federal Register with a 60-day comment period.

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In the October 1, 2015 Federal Register, the Centers for Medicare and Medicaid Services (CMS) released a Request for Information (RFI) to seek public comment related to new provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). This is for the design of the new Medicare physician payment system that will replace the Sustainable Growth Rate (SGR) formula, which includes the merit-based incentive payment system, alternative payment models, and a physician-focused payment model. Originally, comments were due by November 2, 2015; however, an extension of the comment period for an additional 15 days was published in the October 20, 2015 Federal Register, indicating the new due date as Tuesday, November 17, 2015.

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