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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 March 14, 2016, the House Energy and Commerce Oversight and Investigations Subcommittee convened a forum on the state of the knowledge relating to the causes, effects, and treatments of concussions. The forum featured input from experts representing the medical, military, athletic, and research communities with a goal of building a collaborative body of knowledge to help improve the diagnosis and treatment of concussions. Included in the opening statement by Honorable Tim Murphy, Chairman of the Subcommittee: “Today, we begin a new chapter in the national dialogue on concussions. We are not here to re-litigate past actions, point fingers or cast blame. We are here to take a step back, to gain some perspective and to begin a conversation focused on solutions, not on problems.” And most importantly, “We are also here today to make one thing clear – this is not just a sports issue or a military issue. This is a public health issue…That is why we are here today – to ensure we are on the path, though it may be long, to providing the public the answers they deserve.”

The list of participants and webcast of the forum are available on the Energy and Commerce Committee’s website.

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The next Community HealthChoices (CHC) Third Thursday webinar is coming up on Thursday, March 17, 2016 at 1:30 pm. Office of Long-Term Living’s (OLTL) Deputy Secretary Jennifer Burnett will offer an update on CHC, followed by information about the Commonwealth’s waiver documents. In addition, Virginia Brown will discuss the waiver authority Pennsylvania is pursuing to implement CHC. To participate in the webinar, please register online.

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The Department of Human Services (DHS) has released the long-awaited Request for Proposals (RFP) for Community HealthChoices (CHC). CHC is a new initiative that will provide managed long-term services and supports (MLTSS) to older individuals, persons with physical disabilities, and physical health coverage to those who are dually eligible for Medicare and Medicaid.

The goals of CHC are to:

  • Enhance opportunities for community-based services;
  • Strengthen health care and LTSS delivery systems;
  • Allow for new innovations;
  • Promote the health, safety, and well-being of enrolled participants; and
  • Ensure transparency, accountability, effectiveness, and efficiency of the program.

The official release of the RFP is the first step in the procurement process for the selection of managed care organizations (MCOs). The Commonwealth plans to coordinate health and LTSS through MCOs. Participants will have a choice of two to five MCOs in each region. Responses to the RFP by the managed care organizations are due on Monday, May 2, 2016.

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The Department of Human Services Office of Long-Term Living (OLTL) announced they will be submitting a renewal of the OBRA waiver, which expires on June 30, 2016. This announcement/public notice will be published in the February 27 Pennsylvania Bulletin, which seeks public comments.

Written comments regarding the OBRA Waiver renewal should be sent to the Department of Human Services, Office of Long-Term Living, Bureau of Policy and Regulatory Management, Attention: OBRA Renewal, PO Box 8025, Harrisburg, PA 17105-8025 or via email, using the comment forms that OLTL has provided. Please use OBRA Renewal as the subject line. The comment forms, as well as a side-by-side comparison of the current and revised language, and the renewal in its entirety (including the OBRA-specific HCBS Allowable Settings Transition Plan and the Community HealthChoices Transition Plan, which are contained in the main module), can be found on the “OLTL Waiver Amendment, Renewals and Accompanying HCBS Transition Plans” web page. The public comment period ends on Monday, March 28, 2016.

OLTL will offer two webinars for public input and discussion on March 9 and March 23, 2016. Please see the information below for further details on the scheduled webinars.

Title: OBRA Renewal
Date: Wednesday, March 9, 2016
Time: 1:00 – 2:00 pm
Join WebEx meeting
Meeting number:  644 892 538
Meeting password:  OBRA##1
Join by phone
1-877-668-4493 Call-in toll-free number (US/Canada)
1-650-479-3208 Call-in toll number (US/Canada)
Access code: 644 892 538
Toll-free calling restrictions

Title: OBRA Renewal
Date: Wednesday, March 23, 2016
Time: 10:00 – 11:00 am
Join WebEx meeting
Meeting number:  640 051 990
Meeting password:  OBRA##2
Join by phone
1-877-668-4493 Call-in toll-free number (US/Canada)
1-650-479-3208 Call-in toll number (US/Canada)
Access code: 640 051 990
Toll-free calling restrictions

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The Centers for Medicare and Medicaid Services had originally scheduled a webinar on February 11, 2016 on the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. However, the webinar had to be canceled due to technical difficulties. The webinar has now been rescheduled for Tuesday, February 23, 2016 from 1:00 – 2:30 pm.

The IMPACT Act requires the reporting of standardized patient assessment data in the following areas, to better coordinate care and improve outcomes for people with Medicare:

  • Quality measures;
  • Resource use; and
  • Other measures in inpatient rehabilitation facilities, long-term care hospitals, skilled nursing facilities, and home health agencies.

To participate in this webinar, registration is required.

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The Office of Long-Term Living (OLTL) has announced changes that are being made to the enrollment process for Home and Community-based Services (HCBS), including the Aging Waiver, Attendance Care Waiver, CommCare Waiver, Independence Waiver, OBRA Waiver, and Act 150 Program. Effective Tuesday, March 1, 2016, OLTL will enter into a new contract with MAXIMUS, the PA Independent Enrollment Broker (IEB). According to OLTL, the adjustments being made and expectations regarding this new contract will streamline the enrollment process, as well as ensure consistency across all home and community-based programs, in anticipation of the roll-out of Community HealthChoices (CHC), a Managed Long-Term Services and Supports program for older Pennsylvanians and adults with physical disabilities. CHC will move the Commonwealth’s home and community-based waiver system from fee-for service to a capitated Medicaid managed long-term services and supports delivery system. The changes OLTL is making to the enrollment process support the Commonwealth’s efforts to ensure that the enrollment process is conflict free, strengthening necessary firewalls between enrollment in services and the provision of ongoing service coordination and other services.

Changes made to improve the IEB process:

  • The enrollment timeframe requirement has been reduced from 90 days to 60 days. This change is effective March 1, 2016.
  • The IEB will assume the Aging Waiver enrollment process effective April 1, 2016.
  • Enrollments that are already in process before April 1 will remain the responsibility of the Area Agency on Aging. Aging Waiver applications initiated prior to April 1 must be completed by the AAA prior to June 30. Applications still pending on June 30 will revert to Maximus for completion. OLTL will provide additional information on this process in an upcoming webinar.
  • These changes, which affect all OLTL Home- and Community-Based Programs – Aging, Attendant Care, CommCare, Independence, OBRA and the Act 150 program administered through the Office of Long-Term Living – will be completed by the PA Independent Enrollment Broker (IEB), Maximus.

The tasks completed by the IEB (Maximus) include the following:

  • Coordinate with the County Assistance Office to ensure timely completion of the PA 600L Medical Assistance Applications.
  • Coordinate with the Area Agency on Aging to ensure timely completion of the Clinical Eligibility Determination (formerly known as the Level of Care Determination). Complete in-home visit with applicant to gather information for enrollment.
  • Complete the Program Eligibility Determination.
  • Provide applicant with choice of Service Coordination provider.
  • Enroll applicant in waiver upon receipt of PA 162.
  • Transfer record and enrollment documentation to the selected Service Coordination agency.

If you have any questions, please contact Amy High, Office of Long-Term Living, Bureau of Participant Operations, at 717-787-8091.

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On February 9, 2016, the Centers for Medicare and Medicaid Services (CMS) posted this update to the “Therapy Cap” page on their website, regarding manual medical review (MMR) of therapy claims above the $3,700 threshold. The guidance is vague and additional information is needed for clarification. Members that provide outpatient therapy services should be cognizant that MMR will resume in the near future and should comply with medical record requests issued by Strategic Health Solutions.

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The Centers for Medicare and Medicaid Services (CMS) released a proposed rule that was published in the February 3, 2016 Federal Register, which updates the methodology used to measure the performance of Accountable Care Organizations (ACOs) in the Medicare Shared Savings Program.

Under the proposed rule, CMS would modify the process for resetting the benchmarks, which are used to determine ACO performance for those renewing their participation agreements. The proposed rule addresses changes to the Shared Savings Program that would modify the program’s benchmark rebasing methodology, to encourage ACOs’ continued investment in care coordination and quality improvement, and identifies publicly available data to support modeling and analysis of these proposed changes. In addition, it would streamline the methodology used to adjust an ACOs historical benchmark for changes in its ACO participant composition. Comments on the proposed rule are due by March 28, 2016.

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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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