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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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As noted in the Rebaseline Timeline posted in the June 2016 National Healthcare Safety Network (NHSN) Newsletter, the Centers for Disease Control and Prevention (CDC) submitted standardized infection ratios (SIRs) to the Centers for Medicare and Medicaid Services (CMS), using the new 2015 baseline starting with 2016 Quarter 1 data. The inpatient rehabilitation facility (IRF) quality reporting program (QRP) preview reports that CMS provided on September 1, 2016, contained calendar year (CY) 2015 healthcare-associated infection (HAI) SIRs in accordance with the new NHSN baselines, based on nationally collected data from 2015. However, providers were unable to use NHSN to verify the accuracy of the HAI data contained within their preview reports for the Compare sites during the 30-day preview period established for this purpose.

As a result, CMS will begin publically displaying the NHSN data on the Compare sites for IRFs in the next quarterly refresh in spring 2017 instead of in fall 2016. Providers will have the chance to appropriately review their HAI data and inquire about data they believe to be incorrect. IRFs will receive preview reports in December 2016 for the data that will be displayed in spring 2017.

This change will affect the posting of quality performance data on the quality measure: NHSN Catheter-Associated Urinary Tract Infection (CAUTI) Outcome Measure.

When the IRF Compare website is launched in fall 2016, the following quality metrics will be displayed:

IRFs —

  • Percent of residents or patients with pressure ulcers that are new or worsened (short stay); and
  • All-cause unplanned readmission measure for 30 days post-discharge from inpatient rehabilitation facilities.

To assist IRFs in understanding the use of the rebaselined data, and how to monitor their data using the new baseline, a document has been posted in the downloads section of the IRF Quality Public Reporting web page.

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Today, the Office of Long-Term Living (OLTL) issued communication on changes to four OLTL home and community-based services waivers that were recently approved by the Centers for Medicare and Medicaid Services (CMS).

The changes include:

Aging Waiver amendments (effective 10/1/16)

  • Introduces the department’s intent to transition individuals from the Aging waiver into a managed care delivery system;
  • Revises language to reflect the current practice under the new child abuse clearance laws;
  • Breaks out the home health and therapeutic and counseling service definition into five discreet service definitions; and
  • Adds a new entity to perform waiver enrollments.

Attendant Care Waiver amendments (effective 10/1/16)

  • Introduces the department’s intent to transition individuals from the Attendant Care waiver into a managed care delivery system; and
  • Revises language to reflect the current practice under the new child abuse clearance laws.

Independence Waiver amendments (effective 10/1/16)

  • Adds five new employment-related service definitions* which are replacing one existing employment service definition;
  • Breaks out the Home Health and Therapeutic and Counseling service definition into eight discreet service definitions;
  • Introduces the Department’s intent to transition individuals from the Independence waiver into a managed care delivery system; and
  • Revises language to reflect the current practice under the new child abuse clearance laws.

CommCare Waiver amendments (effective 10/1/16)

  • Adds five new employment-related service definitions* which are replacing two existing employment service definitions;
  • Breaks out the home health and therapeutic and counseling service definition into eight discreet service definitions;
  • Introduces the department’s intent to transition of individuals from the Independence waiver into a managed care delivery system; and
  • Revises language to reflect the current practice under the new child abuse clearance laws.

OBRA Waiver renewal (effective 7/1/16)

  • Renewal of the waiver for an additional five years;
  • Introduces the department’s intent to transition individuals from the OBRA waiver into a managed care delivery system;
  • Breaks out the home health and therapeutic and counseling service definition into eight discreet service definitions; and
  • Revises language to reflect the current practice under the new child abuse clearance laws.

*New employment-related services are benefits counseling, career assessment, employment skills development (replaces prevocational services), job coaching (replaces supported employment), and job finding. For complete service definitions, provider qualifications, and requirements of each waiver, please refer to the approved waiver documents.

Providers of these new services will be paid at the proposed rates. Information on implementation of the new employment services, including transition from current employment services and billing procedures, is forthcoming.

In addition to the above changes, CMS has required OLTL to add limitations to any waiver services that are state plan services and are available to individuals under the age of 21. These services include: assistive technology, counseling, nursing services, nutritional consultation services, occupational therapy, personal assistance services, physical therapy, specialized medical equipment and supplies, and speech and language therapy. These services are only to be provided to individuals aged 21 and over. All medically necessary services for children under age 21 are to be covered in the state plan pursuant to the EPSDT benefit.

Questions on this information may be referred to either OLTL’s Bureau of Quality and Provider Management at 800-932-0939 or Bureau of Policy and Regulatory Management at 717-783-8412.

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In July 2016, the Centers for Medicare and Medicaid Services (CMS) proposed new bundled payment models to shift Medicare payments from rewarding quantity to rewarding quality by creating strong incentives for hospitals and clinicians to deliver better care to patients at a lower cost. These proposed new bundled payment models focus on heart attacks, heart bypass surgery, and hip fracture surgery, and would reward hospitals that work together with physicians and other providers to avoid complications, prevent hospital readmissions, and speed recovery. This proposal follows the implementation of the Comprehensive Care for Joint Replacement (CCJR) Model that began earlier this year which introduced bundled payments for certain hip and knee replacements.

CMS just released the second annual evaluation report for Models 2–4 of the Bundled Payments for Care Improvement (BPCI) Initiative, which include both retrospective and prospective bundled payments that may or may not include the acute inpatient hospital stay for a given episode of care. This report describes the characteristics of the participants and includes quantitative results from the first year of the initiative. Key highlights include:

  • 11 out of the 15 clinical episode groups analyzed showed potential savings to Medicare. Future evaluation reports will have more data to analyze individual clinical episodes within these and additional groups;
  • Orthopedic surgery under Model 2 hospitals showed statistically significant savings of $864 per episode while showing improved quality as indicated by beneficiary surveys. Beneficiaries who received their care at participating hospitals indicated that they had greater improvement after 90 days post-discharge in two mobility measures than beneficiaries treated at comparison hospitals; and
  • Cardiovascular surgery episodes under Model 2 hospitals did not show any savings yet but quality of care was preserved. Over the next year, we will have significantly more data available, enabling CMS to better estimate effects on costs and quality.

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The Centers for Medicare and Medicaid Services (CMS) published a final rule in the September 16, 2016 Federal Register that establishes national emergency preparedness requirements for Medicare and Medicaid participating providers and suppliers to plan adequately for both natural and man-made disasters, and coordinate with federal, state, tribal, regional, and local emergency preparedness systems. It will also assist providers and suppliers to adequately prepare to meet the needs of patients, residents, clients, and participants during disasters and emergency situations. The effective date of the regulations are effective on November 15, 2016.

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The Centers for Medicare and Medicaid Services (CMS) has announced that the inpatient rehabilitation facility (IRF) quality reporting program (QRP) provider preview reports are currently available until September 30, 2016. Members are encouraged to preview the performance date on each quality measure prior to public display on the IRF Compare website. While corrections to the underlying data will not be permitted during this timeframe, members can request a CMS review during the 30-day preview period if you feel the data is inaccurate. Additional information, including instructions on how to access preview reports, is available from the IRF Quality Public Reporting web page.

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The Department of Human Services (DHS) has published a notice that includes proposed changes to the Medical Assistance Fee Schedule for the Aging, COMMCARE, Independence, and OBRA Waivers in the Pennsylvania Bulletin.

The Office of Long-Term Living (OLTL) is proposing to add the following employment services to three of its waivers listed below:

  • COMMCARE waiver – Benefits Counseling, Career Assessment, Employment Skills Development, Job Coaching Intensive, and Follow-along and Job Finding.
  • Independence waiver – Benefits Counseling, Career Assessment, Employment Skills Development, Job Coaching Intensive, and Follow-along and Job Finding.
  • OBRA waiver – Benefits Counseling, Career Assessment, Employment Skills Development, Job Coaching Intensive, and Follow-along and Job Finding.

DHS has developed Medical Assistance (MA) fee schedule rates for the additional services added to these waivers. The proposed MA Fee schedule rates are available for review.

Comments regarding the notice and the proposed MA fee schedule rates will be accepted until Monday, October 3, 2016, and should be sent to: Department of Human Services, Office of Long-Term Living, Bureau of Policy and Regulatory Management, Attn: HCBS Rates, PO Box 8025, Harrisburg, PA 17105-8025. Comments can also be sent via email.

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The Departments of Human Services (DHS) and Aging just announced their selection of three managed care organizations (MCOs) for Community HealthChoices (CHC). CHC will coordinate physical health and long-term services and supports (LTSS) to individuals who are dually eligible for Medicare and Medicaid, older Pennsylvanians, and individuals with disabilities.

Through a review of a request for proposals, the following MCOs have been selected to proceed with negotiations to deliver services statewide in Pennsylvania beginning in 2017:

  • AmeriHealth Caritas
  • Pennsylvania Health and Wellness (Centene)
  • UPMC for You

CHC will roll out in three phases. Persons eligible for CHC are individuals aged 21 or older who have both Medicare and Medicaid, or who receive long-term services and supports through Medicaid because they need help with everyday activities of daily living.

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An RCPA Info was issued on August 18, 2016 regarding a project that was announced by the Centers for Medicare and Medicaid Services (CMS) specific to the development and maintenance of a post-acute care (PAC) cross-setting standardized assessment data. Originally, the comment deadline on this project was set for August 26, 2016. Due to concerns voiced to CMS regarding a two-week comment period, the deadline has now changed. The comment period on this project has now been extended to Monday, September 12, 2016.

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On August 15, 2016, the Centers for Medicare and Medicaid Services (CMS) posted to their public comment page, Development and Maintenance of Post-Acute Care (PAC) Cross-Setting Standardized Assessment Data, with a request for comment deadline of August 26, 2016.

This project involves CMS contracting with RAND to develop standardized assessment-based data items to meet the requirements as set forth under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, Section 2(a). Development of standardized data items includes conducting environmental scans of the evidence, data item conceptualization, drafting data item specifications, convening technical expert panels, and feasibility piloting.

The Centers for Medicare & Medicaid Services (CMS) seeks comments from stakeholders on data items that meet the IMPACT Act domains of: cognitive function and mental status; special services, treatments, and interventions; medical conditions and co-morbidities; and impairments. In addition to general comments, CMS is specifically interested in public feedback regarding the topics below:

  • Potential for improving quality: includes consideration of the data element’s ability to improve care transitions through meaningful exchange of data between providers; improve person-centered care and care planning; be used for quality comparisons; and support clinical decision-making and care coordination;
  • Validity: includes consideration of the data element’s proven or likely inter-rater reliability (i.e., consensus in ratings by two or more assessors) and validity (i.e., whether it captures the patient attribute being assessed);
  • Feasibility for use in PAC: includes consideration of the data element’s potential to be standardized and made interoperable across settings; clinical appropriateness; and relevance to the work flow across settings; and
  • Utility for describing case mix: includes whether the data element could be used with different payment models, and whether it measures differences in patient severity levels related to resource needs.

Comments may be submitted on the entire set of data elements or specific to individual data elements and should be sent via email or to:

RAND Corporation
1200 South Hayes Street
Arlington, VA 22202-5050
Attn: Barbara Hennessey, W7E

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