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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 December 20, 2016, the Centers for Medicare and Medicaid Services (CMS) announced the release of a final rule that will implement three new Medicare Parts A and B episode payment models, a Cardiac Rehabilitation Incentive Payment model and modifications to the existing Comprehensive Care for Joint Replacement (CJR) model under Section 1115A of the Social Security Act.

The finalization of these new Innovation Center models will continue the shift of Medicare payments from rewarding quantity to rewarding quality by creating incentives for hospitals to deliver better care to patients at a lower cost. The models will reward hospitals that work together with physicians and other providers to avoid complications, prevent hospital readmissions, and speed recovery.

The announcement finalizes significant new policies that:

  • Improve orthopedic care: One new payment model will support clinicians in providing care to patients who receive surgery after a hip fracture, other than hip replacement. In addition, CMS is finalizing updates to the CJR Model, which began in April 2016.
  • Improve cardiac care: Three new payment models will support clinicians in providing care to patients who receive treatment for heart attacks, heart surgery to bypass blocked coronary arteries, or cardiac rehabilitation following a heart attack or heart surgery.
  • Provides an accountable care organization (ACO) opportunity for small practices: The new Medicare ACO Track 1+ Model will have more limited downside risk than Tracks 2 or 3 of the Medicare Shared Savings Program in order to encourage more practices, especially small practices, to advance to performance-based risk.

The final rule makes several modest adjustments to the CJR Model that are largely conforming changes for consistency with the other episode payment models. These include refinements for use of the skilled nursing facility waiver, exclusion of beneficiaries participating in selected ACOs, and revising target pricing methodology to include reconciliation and repayment amounts for performance years 3, 4, and 5. CMS is finalizing revisions to the quality adjustment to incorporate improvement as well as absolute performance, and also finalized changes to align CJR with the episode payment models around financial arrangements and beneficiary engagement incentives, compliance enforcement, appeals processes, and beneficiary notifications.

The final rule is scheduled to be published in the Federal Register on January 3, 2017, and is effective on February 18, 2017.

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The decision for Pennsylvania to postpone the implementation of Community HealthChoices (CHC) was announced today. This decision was made as a result of the delays associated with the resolution of several bid protests.

Following the announcement of the selection of the managed care organizations (MCOs) that would deliver health care coverage in Community HealthChoices, several protests were filed. As a result, the progress of major components of CHC implementation was delayed, resulting in the Department of Human Services (DHS) feeling uncertain with moving forward with their established start dates. Some of the impacted activities associated with this decision include:

  • Developing an adequate network: DHS has not been able to engage with the selected offerors. The agreement and rate negotiations and finalization typically take six weeks, and the agreements need to be finalized before the MCOs are able to engage in network development activities. The current delays mean the MCOs will not have enough time to meet the network adequacy requirements by July 1, 2017.
  • Completing a readiness review: Readiness review is a requirement for the MCOs before they are certified to be able to go live and provide services. Protests prohibit MCO engagement for readiness review and the window to complete the certification continuously shrinks. New programs require a minimum of six months to complete a readiness review.
  • Communicating: Communication about selected MCOs and their available networks is a critical component to CHC education and outreach. Individuals who will be enrolling in CHC need to have complete information about the MCO provider network in order to be able to make an informed provider choice. That communication will not be able to take place until the agreements are largely finalized and the MCOs are in a position to provide network information.

Important dates to note include:

  • Phase 1 will now begin in January 2018 in the Southwest region of the state.
  • Phase 2 will now begin in July 2018 in the Southeast region of the state.
  • The January 2019 start date for the rest of the state remains unchanged.

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The Centers for Medicare and Medicaid Services (CMS) finalized a new Therapy Information section on the inpatient rehabilitation facility (IRF) patient assessment instrument (PAI) in the fiscal year (FY) 2015 IRF Prospective Payment System (PPS) final rule.

On January 12, 2017, from 1:30 pm to 3:00 pm, CMS will conduct a call focusing on this IRF-PAI therapy information data collection. During this call, CMS will focus on reviewing the types and methods of therapy collected on the IRF-PAI, examples of each type of therapy, and how to accurately code and complete the therapy information section on the IRF-PAI. Prior to the call, participants are encouraged to review the IRF-PAI Training Manual. A question and answer session will follow the presentation.

To participate, registration is required. Registration will close at 12:00 pm on January 12, 2017, or when available space has been filled. The call presentation will be posted at least one day in advance on the MLN National Provider Calls and Events web page.

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On Thursday, December 1, 2016, the Centers for Medicare and Medicaid Services will conduct a call from 1:30 pm to 3:00 pm that will focus on the soon to be released Certification and Survey Provider Enhanced Reports (CASPER) Quality Measure (QM) reports for the inpatient rehabilitation facility (IRF) quality reporting program. Agenda topics include:

  • Quality measures for public reporting in 2016;
  • Reports associated with public reporting;
  • Content of the CASPER QM reports by data source;
  • How to interpret facility and patient level results;
  • Accessing reports in CASPER; and
  • Resources for providers.

To register or for more information, visit MLN Connects Event Registration. Because space may be limited, those interested are encouraged to register early.

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The Centers for Medicare and Medicaid Services (CMS) recently posted a project on the CMS public comment page, Quality Measures to Satisfy the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) Domain of: Transfer of Health Information and Care Preferences When an Individual Transitions.

This project involves CMS contracting with RTI International and Abt Associates to further develop a cross-setting post-acute care transfer of health information and care preferences quality measure in alignment with the IMPACT Act. The purpose of the project is to develop, maintain, re-evaluate, and implement measures reflective of quality care for post-acute care (PAC) settings to support CMS quality missions, including the Inpatient Rehabilitation Facility Quality Reporting Program, Long-Term Care Hospital Quality Reporting Program, the Nursing Home/Skilled Nursing Facility Quality Reporting Program, and the Home Health Quality Reporting Program. In addition, this project will address the domains required by the IMPACT Act, which mandates specification of cross-setting quality, resource use, and other measures for post-acute care providers.

The areas of focus for commenting, along with documents for review, are provided on the public comment page and are encouraged to be reviewed prior to submitting comments. The public comment period closes on Sunday, December 11, 2016.

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The Centers for Medicare and Medicaid Services (CMS) recently approved five new employment-related services in the Office of Long-Term Living’s (OLTLs) CommCare and Independence waivers. The services offer providers an opportunity to expand their profiles, particularly those who have been providing prevocational services and supported employment. Listed below are the new services, their credentialing and certification requirements, and rates that will be paid for the services.

  • Benefits Counselors must hold a Certified Work Incentives Counselor (CWIC) certification that is accepted by the Social Security Administration for its Work Incentives Planning and Assistance program. To learn more about CWIC, visit this web page.
  • Employment Skills Development (replaces Prevocational Services), Job Coaching (replaces Supported Employment), Job Finding, and Career Assessment workers must hold one of the following:
  1. A Certified Employment Support Professional (CESP) credential from the Association of People Supporting Employment First (APSE); and
  2. A Basic Employment Services Certificate of Achievement or Professional Certificate of Achievement in Employment Services from an Association of Community Rehabilitation Educators (ACRE) organizational member that has ACRE-approved training. Individuals without one of these certifications must be supervised by an individual holding the above certification until certification is achieved. Certification must be achieved within 18 months of employment.

Information on APSE credentialing can be found here.
Information on how to receive a certificate of achievement from ACRE can be found here.

(NOTE: Employment Skills Development services that are provided in vocational rehabilitation facilities that fall under 55 PA Code Chapter 2390 are not required to have the above credential or certification. Employment Skills Development services provided in the community do require the above credential or certification.)

A complete description of these services and provider qualifications can be found in the CommCare and Independence waivers here.

NOTE: OLTL has scheduled a webinar on Friday, November 18, 2016 at 1:00 pm to review and discuss these new services. Registration is required to participate.

Listed below are the rates for the new employment services:

 
Service PT/Spec CC IW Procedure Code Modifier Region 1 Region 2 Region 3 Region 4 Unit
Benefits Counseling 59/502 X X W1740 $9.78 $10.21 $10.54 10.87 15 mins
Career Assessment 59/503 X X W1732 $11.12 $12.12 $12.39 12.67 15 mins
Employment Skills Development (1:1) 59/505 X X W1728 $9.44 $11.22 $10.07 10.12 15 mins
Employment Skills Development (1:2 to 1:3) 59/505 X X W1729 $3.77 $4.49 $4.03 4.05 15 mins
Employment Skills Development (1:15) 59/505 X X W1741 $6.29 $6.50 $6.96 6.54 15 mins
Job Coaching 1:1 (Follow-Along) 59/504 X X W1733 U5 $9.78 $10.21 $10.54 10.87 15 mins
Job Coaching 1:2 to 1:4 (Follow-Along) 59/504 X X W1734 U5 $3.26 $3.40 $3.51 3.62 15 mins
Job Coaching 1:1 (Intensive) 59/504 X X W1733 U4 $9.78 $10.21 $10.54 10.87 15 mins
Job Coaching 1:2 to 1:4 (Intensive) 59/504 X X W1734 U4 $3.26 $3.40 $3.51 3.62 15 mins
Job Finding 59/530 X X W1735 $11.15 $12.11 $11.98 12.34 15 mins

 

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On November 4, 2016, the Centers for Medicare and Medicaid Services (CMS) published the final rule with comment period for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) as the payment program that will replace the Sustainable Growth Rate methodology. The rule finalizes MACRA’s Quality Payment Program, whose primary goal is to reduce administrative burden on physicians to allow them to focus on improving care, promote the adoption of value-based care, and smooth the transition to these new models of care. The final rule establishes guidelines for Medicare health care providers to participate in either the Advanced Alternative Payment Models (APMs) or the Merit-based Incentive Payment System (MIPS), which consolidates components of three existing programs: the Physician Quality Reporting System, the Physician Value-based Payment Modifier, and the Medicare Electronic Health Record (EHR) Incentive Program for Eligible Professionals. According to CMS, the Advanced APMs pathway provides clinicians with the opportunity to be paid more for better care and investments that support patients by reducing existing requirements, while still emphasizing and rewarding quality care. Participants in the advanced APMs must meet the following requirements:

  • Be part of CMS Innovation Center models, Shared Savings Program tracks, or certain federal demonstration programs;
  • Use certified EHR technology;
  • Base payments for services on quality measures comparable to those in MIPS; and
  • Be a medical home model expanded under innovation center authority or require participants to bear more than nominal financial risk for losses.

The final rule has a 60-day comment period, with comments due by Monday, December 19, 2016. RCPA will be offering a webinar in the near future on the details of the final rule, hosted by the American Medical Rehabilitation Providers Association (AMRPA). The date and time will be released soon.

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On October 31, 2016, the Centers for Medicare and Medicaid Services (CMS) announced the awards for the Medicare Fee-for-Service (FFS) Recovery Audit Contractor (RAC) contracts. The five regions include:

  • Region 1 – Performant Recovery, Inc.;
  • Region 2 – Cotiviti, LLC;
  • Region 3 – Cotiviti, LLC;
  • Region 4 – HMS Federal Solutions; and
  • Region 5 – Performant Recovery, Inc.

Pennsylvania is under Region 4. Maps depicting the new regions and related RACs are available in the “Downloads” section of the Future Changes page on CMS’ website.

The RACs in Regions 1–4 will perform post-payment reviews to identify and correct Medicare claims that contain improper payments (overpayments or underpayments), made under Part A and Part B, for all provider types other than Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) and Home Health/Hospice. The Region 5 RAC will be dedicated to the post-payment review of DMEPOS and Home Health/Hospice claims nationally. These awards continue the implementation of many of the Recovery Audit Program enhancements designed to reduce provider burden, enhance program oversight, and increase transparency in the program. CMS will continue to update this website with more information on the implementation of the new RACs.

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The Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN) is the nation’s most widely used health care-associated infection (HAI) tracking system. CDC is implementing a new national baseline for HAI’s that are reported to NHSN. On Saturday, December 10, 2016, NHSN users will be able to run standardized infection ratios for 2015 and 2016 under both the old baseline and the new baseline. Data for 2017 and forward will be available under the new baseline only.

A webinar has been scheduled for Wednesday, November 16, 2016, from 1:00 – 2:00 pm EST, and will include CDC providing an overview of the new HAI models as they relate to inpatient rehabilitation facilities (IRFs). Also to be discussed is the reason HAI data contained within the IRF preview reports may not align with the data in NHSN for the same target period. Registration is required to participate in the webinar; there is no fee to register.

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Late on Friday, October 28, the Office of Long-Term Living (OLTL) released a draft Request for Proposal (RFP) for an Independent Enrollment Broker (IEB) to manage the enrollment processes for all OLTL programs. The RFP includes enrollments for Community Health Choices when implemented, Home and Community-based Services Waivers, the Act 150 program, and the LIFE program. Comments are due no later than 5:00 pm on Monday, November 21, 2016, and should be submitted via email by using the drop down menus within the comment template.

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