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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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The Centers for Medicare and Medicaid Services (CMS) published the final rule that updates the fiscal year (FY) 2016 Medicare payment policies and rates for the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) and the IRF Quality Reporting Program (IRF QRP) in the August 6, 2015 Federal Register. Highlights of the final rule are provided below.

Changes to the Payment Rates: CMS is updating the IRF PPS payments for FY 2016 to reflect an estimated 1.7 percent increase (reflecting a new IRF-specific market basket estimate of 2.4 percent, reduced by a 0.5 percentage point multi-factor productivity adjustment and a 0.2 percentage point reduction required by law). An additional 0.1 percent increase to aggregate payments due to updating the outlier threshold results in an overall update of 1.8 percent (or $135 million), relative to payments in FY 2015.

No Changes to the Facility-Level Adjustments: As stated in the FY 2015 IRF PPS final rule, CMS froze the facility-level adjustment factors at the FY 2014 levels for FY 2015 and all subsequent years. For FY 2016, CMS will continue to hold the facility-level adjustment factors at the FY 2014 levels as they continue to monitor the most current IRF claims data available to assess the effects of the FY 2014 changes.

ICD-10-CM Conversion: In the FY 2015 IRF PPS final rule, CMS finalized conversions from the International Classification of Diseases, 9th Revision, Clinical Modification (ICD-9-CM) to the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for the IRF PPS, which will be effective when ICD-10-CM becomes the required medical data code set for use on Medicare claims and IRF PAI submissions. The implementation date for ICD-10-CM is October 1.

IRF-specific Market Basket: For FY 2016, CMS is finalizing an IRF-specific market basket to replace the Rehabilitation, Psychiatric and Long-Term Care market basket. The IRF market basket is based on 2012 data (the RPL market basket is based on 2008 data). The IRF market basket is derived from using both freestanding and hospital-based IRF Medicare cost report data from FY 2012.

Changes to the Wage Index: CMS finalized its proposal for transitioning to the wage index associated with the new Office of Management and Budget delineations without any modifications. A one-year blended wage index will be provided for all IRFs, and a three-year phase-out of the rural adjustment for IRFs that were deemed rural in FY 2015 but are considered urban under the new delineations. CMS will apply the one year blended wage index in FY 2016 for all geographic areas, to assist IRFs in adapting to these changes.

  • FY 2015 rural IRFs classified as urban in FY 2016 will receive two-thirds of the FY 2015 rural adjustment in FY 2016, as well as the blended wage index.
  • For FY 2017, these IRFs will receive the full FY 2017 wage index and one-third of the FY 2015 rural adjustment.
  • For FY 2018, these IRFs will receive the full FY 2018 wage index without a rural adjustment.

Changes to the IRF Quality Reporting Program (QRP): The Improving Medicare Post-Acute Care Transformation Act of 2014 (“IMPACT” Act) added Section 1899B to the Social Security Act (the Act) to require that IRFs report data on measures that satisfy measure domains specified in the Act. These same measures are to be implemented in long-term care hospitals, IRFs, skilled nursing facilities and home health agencies. This final rule adopts measures that satisfy three of the quality domains required by the IMPACT Act in FY 2016: skin integrity and changes in skin integrity; functional status, cognitive function, and changes in function and cognitive function; and incidence of major falls. IRFs that fail to submit the required quality data to CMS will be subject to a 2 percentage point reduction to their applicable FY annual increase factor.

Finalized Changes:

The domains specified by the IMPACT Act, and the quality measures finalized, are as follows:

  • Domain 1: Skin integrity and changes in skin integrity:
    • Quality Measure: “Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened” (NQF #0678)
  • Domain 2: Functional status, cognitive function, and changes in function and cognitive function:
    • Quality Measure: Application of the “Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function” (NQF #2631; Endorsed on July 23, 2015)
  • Domain 3: Incidence of major falls:
    • Quality Measure: Application of the “Percent of Residents Experiencing One or More Falls with Major Injury” (NQF #0674)

In addition to the measures listed above, CMS adopted four additional functional status quality measures, and completed the previously finalized quality measure “All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from Inpatient Rehabilitation Facilities” (NQF #2502), in order to establish its newly NQF-endorsed status.

Additionally, CMS will begin publically reporting IRF quality data in the fall of 2016. This includes a 30-day period for review and correction of quality data prior to public display.

Finally, CMS is temporarily suspending their previously finalized data validation policy in order to allow time to develop a more comprehensive policy that will potentially decrease the burden on IRF providers, allow CMS the ability to establish an estimation of accuracy related to quality data submitted to them, and facilitate the alignment of the IRF validation policy with that of other CMS quality reporting programs policies.

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The Centers for Disease Control and Prevention (CDC) has released a new report, Concussion at Play: Opportunities to Reshape the Culture Around Concussion. The report provides an overview of current research on concussion knowledge, awareness, attitudes, and behaviors among athletes, coaches, parents, health care providers, and school professionals.

This report also describes opportunities to help build a culture in sports where athletes take steps to lower their chances of getting a concussion, and recognize and report concussion symptoms. This involves moving beyond our general concussion knowledge and changing the way we talk about and respond to concussion. The goal is to empower athletes not to play with a concussion or hide their symptoms. The document builds from the work of the Institute of Medicine (IOM) report, Sports-Related Concussions in Youth: Improving the Science, Changing the Culture.

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On July 22, the Departments of Human Services and Aging announced the next steps in Governor Wolf’s plan to improve care coordination and move to Medicaid Managed Long-Term Services and Supports (MLTSS). These updates are a result of overwhelming response to the public comment period and stakeholder input.

Along with feedback on how MLTSS should be implemented in the Commonwealth, the departments heard feedback on changes that can be made today to improve the current system. They will take the following steps:

 

Doubling the number of staff who work on Nursing Home Transition (NHT)
PDA and DHS recognize that current processes to move individuals who are able to be better served in the community from institutional settings are lengthy and complicated. To address this, the departments will:

  • Increase the number of staff assigned to NHT from 5 to 10;
  • Identify and implement strategies intended to
    • improve the process
    • enhance program outcomes
    • advance the opportunities for individuals to either avoid premature placement and/or transition back into the community;
  • Evaluate and redesign the entire NHT process; and
  • Increase training for all current NHT staff and providers.

 

Creating an advisory committee with at least 50 percent representation by participants and caregivers and conducting monthly webinars
Throughout the MLTSS public input sessions, participants, advocates, and providers made it clear that more education, involvement, and communication are necessary as the Commonwealth moves to MLTSS. In order to accomplish this, the departments will:

  • Host monthly webinars on the third Thursday of every month.
  • Create an MLTSS Advisory Committee that will meet under the federally mandated purview of the Medical Assistance Advisory Committee (MAAC).
    • MLTSS program participants will comprise half of the membership, with the remaining half representing provider communities
    • Opportunities for participation via telephone for increased accessibility and convenience
    • This committee will meet bi-weekly
  • Encourage open communications; questions can be submitted via email.

 

Restructuring existing contracts to provide more choice for participants
Issue a procurement for a home modification quality improvement program in August 2015: In some cases, the transition from a nursing home to living in the community can be accomplished through a simple home modification such as the installation of a ramp for wheelchair access. The new procurement will streamline the current process to make this easier to complete these modifications, while at the same time ensuring that only high-quality contractors complete the work. The contracts will include two providers in each part of the state to provide choices in completing the work.

Issue a financial management services procurement in November 2015: There is currently one statewide vendor that acts on behalf of the consumer to make payroll, withhold and report taxes, and pay bills for individuals in home- and community-based waiver programs. Moving forward, multiple vendors will be awarded the contracts to ensure choice, and they will be required to maintain a regional presence throughout the state.

Award New Contracts for Independent Enrollment Broker (IEB) Services in November 2015: One of the most significant barriers to serving individuals in the community is the length of time it takes to enroll someone in home- and community-based services. The new contracts will be awarded in four regional lots and include new, strong performance standards, to ensure that the vendors are held accountable and participants are not stuck waiting for services.

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On July 14, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule in the Federal Register, announcing the implementation of a new Medicare Part A and B payment model called the Comprehensive Care for Joint Replacement (CCJR) model. Under this model, acute care hospitals in 75 selected geographic areas would receive retrospective bundled payments for episodes of care for lower extremity joint replacement or reattachment of a lower extremity. All related care within 90 days of hospital discharge from the joint replacement procedures will be included in the episode of care.

CMS anticipates the proposed CCJR model would benefit Medicare beneficiaries by improving the coordination and transition of care, improving the coordination of items and services paid through Medicare fee-for-service, encouraging more provider investment in infrastructure and redesigned care process for higher quality and more efficient service delivery, and incentivizing higher value care across the inpatient and post-acute care spectrum spanning the episode of care. According to CMS, hip and knee replacements are the most common inpatient surgery for Medicare beneficiaries and can require lengthy recovery and rehabilitation periods.

CMS proposes to test CCJR for a five year performance period, beginning January 1, 2016, and ending December 31, 2020. Comments will be accepted on the proposals contained in the proposed rule, as well as other alternatives or suggestions, through September 8. Contact Melissa Dehoff at RCPA with questions.

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On July 14, Estelle Richman, former secretary of the Department of Human Services (DHS), will conduct a presentation; Person-Driven Services in Managed Care Long-Term Services and Supports (MLTSS), from 1:00 to 3:00 pm at Temple University, Ritter Annex Room 555, 1301 Cecil B. Moore Avenue, Philadelphia, PA 19122. Members can participate in person or online.

Topics will include:

  • Overview of DHS discussion document on managed care;
  • Overview of federal options for self-directed services and supports in managed care; and
  • Discussion of what stakeholders can do to ensure that good self-directed options are available in any managed care model that DHS administers.
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