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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 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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The Centers for Medicare and Medicaid Services (CMS) has announced that a special open door forum for inpatient rehabilitation facilities (IRFs) will be held on Tuesday, October 20, 2015, from 2:00 to 3:00 pm. During the call, CMS will discuss the upcoming Dry Run for IRFs Provider Performance reports on All-Cause Unplanned Readmissions for 30-day post discharge from IRFs. This will also include timeline and content of facility dry run reports that will be disseminated to IRFs from November 3 through December 3, 2015.

To participate in this special open door forum call:
Dial: 1-866-402-6263
Conference ID #: 55982595

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The Departments of Human Services and Aging have extended an invitation for Managed Care Organizations (MCOs) and Home and Community-based Service (HCBS) providers to convene to discuss Community HealthChoices (CHC). The purpose of the meeting is to begin the conversation between the MCOs and providers, as the transition from fee-for-service to managed care begins.

The meeting has been scheduled for Wednesday, November 4, 2015, from 1:00 to 3:00 pm at the Radisson Hotel located at 1150 Camp Hill Bypass, Camp Hill, PA 17011.

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On Thursday, October 1, 2015, at 10:00 am, the House Energy and Commerce Health Subcommittee will hold a hearing, “Examining Potential Ways to Improve the Medicare Program,” that will include the review of three bills that strive to strengthen Medicare. The bills that will be examined include:

  • HR 1934, the Cancer Care Payment Reform Act, which would build on the promise of new provider delivery model development envisioned in the sustainable growth rate replacement policy, enacted into law earlier this year. This bill would establish a national oncology medical home demonstration project to improve Medicare payments for cancer care.
  • Draft legislation that would make changes to documentation and face-to-face requirements for home health providers under the Medicare program.
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