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On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.

If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:

Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.

RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:

Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the ‎reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.

Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following ‎information:‎

  • A copy of the CMS non-compliance letter;
  • A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of ‎calendar year 2024; and
  • If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the ‎monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract ‎Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among ‎Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.

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The Bureau of Human Services Licensing (BHSL) has received a small number of reports of issues with faxing the updated Documentation of Medical Evaluation (DME) forms. These reports indicate that some fax machines cannot pick up the contrast in the grey shaded areas. You will find both DME forms with the grey areas lightened significantly. These forms are also being added to the BHSL website.

Please note, BHSL has fax-tested both versions of these forms and did not encounter any issues. Issues with faxing may be related to the age/condition or settings of individual fax machines. Online faxing services that do not require the use of a fax machine are widely available, as are alternative methods of form transmission, such as in-person drop off, email, online drop boxes, or the United States Postal Service.

Questions about this communication may be sent electronically.

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RCPA’s 2025 Conference Strive to Thrive will be held in Hershey September 9 – 12, 2025. Early bird rates for registration end August 8! Be sure to register today and take advantage of the early bird rates!

RCPA is proud to host those who lead PA in health and human services at our Annual Conference. This year, DHS Secretary Valerie Arkoosh will be presenting as our kickoff plenary speaker on September 9. Throughout the week, we will hear updates from various departments and leaders of DHS, including:

  • ODP Deputy Secretary Kristin Ahrens;
  • OLTL Deputy Secretary Juliet Marsala;
  • DDAP Deputy Secretary Kelly Primus; and
  • OMHSAS Deputy Secretary Jennifer Smith.

View our Registration Brochure for complete details of the conference schedule and speakers. You can also register directly here. Be sure to check the RCPA Conference website regularly for details and updates to the schedule, registration, and sponsors/exhibitors.

In addition to registration, there are still many opportunities available for sponsorship and exhibit booths, so don’t delay! We are grateful to all our sponsors and exhibitors who help make the conference happen. If your organization is interested in sponsoring or exhibiting at our conference, all information is available in our Sponsor, Exhibit, and Advertise Brochure. You can contact Carol Ferenz, Conference Coordinator, for more details.

Thank you to our Sponsors and Exhibitors! We thank you for your support!

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The Office of Developmental Programs (ODP) has shared ODPANN 25-072 and its accompanying attachments. The purpose of this announcement is to provide updated guidance for completing the SC Individual Monitoring Tool (IMT), specifically regarding when self-employment is considered Competitive Integrated Employment (CIE).

With the implementation of Performance-Based Contracting (PBC) for ID/A Residential Providers and SCOs, ODP has reviewed how CIE data is collected and interpreted. Because CIE performance measures rely on information collected through the SC IMT, ODP is issuing updated guidance to clarify how SCs should apply CIE criteria — particularly in cases involving self-employment. While PBC is not being implemented for Residential Providers or SCOs enrolled in the AAW, the AAW is also updating its IMT guidance in alignment with the ID/A IMT guidance.

These updates do not change the monitoring tool questions themselves in either the ID/A or AAW IMT. The new guidance provides additional instructions to ensure consistent understanding and documentation.

ATTACHMENTS:

  • Attachment #1: ID/A Individual Support Plan Monitoring Tool – SC Guidance Document – Reissued 7/23/2025
  • Attachment #2: AAW SC Individual Monitoring Guidance – Reissued 7-2025

Please review the announcement and attachments for additional information and details.

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The Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS/ASC) proposed rule in the July 17, 2025, Federal Register.

The rule outlines new proposed payment rates and related policies for a wide variety of Medicare providers, including not only physicians but other individual Medicare clinicians, such as physical and occupational therapists, speech-language pathologists, nurse practitioners, and physician assistants.

The proposed CY 2026 OPPS/ASC would implement a 2.4% increase to OPPS payment rates that reflects a market basket update of 3.2%, reduced by a productivity adjustment of 0.8 percentage points.

RCPA will provide a more detailed analysis of the OPPS/ASC proposed rule with a focus on the implications for rehabilitation providers. Additional information can be provided on this OPPS fact sheet.

Comments on the proposed rule are due by September 15, 2025. Members are encouraged to share comments and concerns to Melissa Dehoff by September 8, 2025, to include in RCPA’s comment letter.

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The Administration for Children and Families (ACF) Children’s Bureau will be conducting a Title IV-E Federal Review for Pennsylvania (PA) in July of 2026. These reviews are mandatory every three (3) years and includes a systematic monitoring of the Title IV-E Foster Care Program. This program provides the cost of foster care maintenance, administrative expenses to manage the program, and training for staff and foster parents. PA’s period under review (PUR) will begin this October 1 and last through March 31, 2026. A random sample of 100 cases of youth in Foster Care will be selected.

In essence, the review considers:

  • Judicial determinations regarding reasonable efforts and child’s best interest;
  • Timely court hearings and determinations;
  • Voluntary placement agreements;
  • Responsibility for placement and care vested with state agency;
  • Eligibility for Aid to Families with Dependent Children (AFDC) under the state plan in effect July 16, 1996;
  • Placement in a licensed foster family home or child-care institution; and
  • Safety requirements for the child’s foster care placement.

What does this mean for you? The Children’s Bureau will review County and Provider case files of the selected child and all their placement detail. The records must be able to show compliance with Federal Regulations as well as the Child Protective Services Law. The review includes the licensing of all agencies with particular attention on:

  • Criminal Clearances for all staff, including those who are not child serving and those who are no longer employed;
  • No lapse in licensing where Title IV-E claims were made (particularly in single foster homes);
  • Fingerprints provided prior to the licensing date;
  • Safety Considerations document for staff and foster parents with criminal charges or critical incidents;
  • All trainings required for staff and foster parents having been completed; and
  • Clearances for Household Members by 30 days after their 18 birthday.

As such, on August 4, 2025, from 10:00 am – 12:00 pm, OCYF will be offering a virtual training option to learn more about this review. OCYF will complete the following:

  • Review details expected during the review;
  • Brainstorm PA’s strengths and areas in need of improvement;
  • Create tools to ease document collection; and
  • Address communication gaps.

To register for this virtual training option, please fill out the form here. Please note that the form mentions an in-person option, but OCYF will now only be offering the virtual option.

Please feel free to contact Caitlin Robinson with any questions regarding the registration of this training. Thank you in advance for your participation in this meeting. OCYF appreciates your partnership and cooperation as they move closer to critical audit for PA.

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Hearing All Perspectives: The Development of a Multi-State, Multi-Diagnosis Youth Advisory Council
Free RCPA Members-Only Webinar

Wednesday, August 6, 2025
11:00 am – 12:00 pm
Register Here

This presentation will discuss the formation of a novel and innovative version of a standard Youth Advisory Council (YAC). This particular YAC adds a twist to the traditional means of involving youth by creating a council combining voices of individuals served who have two very different diagnoses: those with an emotional/behavioral disorder (EBD) and those with an autism/intellectual disability (ASD/IDD). Spanning across three states, this internal YAC has been established to hear the voices of and to teach leadership principles and skills to those who are receiving the services offered by Devereux Advanced Behavioral Health.

Presenters:

  • Amy Kelly, MBA, MNM, National Director of Family Engagement, Devereux Advanced Behavioral Health
  • Judy Starr, JD, Deputy General Counsel, Devereux Advanced Behavioral Health

Objectives: Following this course, the learner will:

  • Describe the value of constituents’ voices from services and programs provided, regardless of individual communication type, cognitive ability, or diagnosis;
  • Discuss how to engage leadership and staff to support and sponsor a youth/constituent advisory council; and
  • List some “lessons from the journey” with do’s and don’ts when developing a youth advisory council.

Certificates of attendance are available to RCPA members who attend this webinar; anyone interested in a certificate should contact Cathy Barrick. To apply for CEs, you will need to register for the RCPA Annual Conference Strive to Thrive and indicate you attended the webinar in your CE packet, which will be made available on the mobile app.

Contact Carol Ferenz, Conference Coordinator, for details, or visit the RCPA Conference website for information on workshops, sponsors, exhibitors, and more!

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Photo by Matt Popovich on Unsplash

FOR IMMEDIATE RELEASE

July 22, 2025

Media Contact: Tpr. Gagliardi / X: @PSPTroopBPIO

Providers with any information are encouraged to contact PSP Washington at 724-223-5200.

Washington, PA – To aid in an ongoing investigation, the Pennsylvania State Police (PSP) Bureau of Criminal Investigation is requesting health care agencies and providers in the state to review their employment records due to an investigation of suspected fraudulent activities involving Shannon Nicole Womack.

Womack is alleged to have used at least 10 aliases to pose as a licensed practical nurse (LPN), registered nurse (RN), and registered nurse supervisor at rehabilitation and nursing home facilities in various regions across Pennsylvania. She is charged with securing the nursing positions through staffing agencies by submitting fraudulently signed documents and also by creating a false LLC to deploy herself to jobs. Reports indicate Womack worked at each of these jobs for only a short time.

The PSP is working with the Department of Health, Department of State, and multiple district attorneys and states in the ongoing investigation.

Investigators confirmed Womack used the following aliases in various parts of the state:

  • Shannon Nicole Parham
  • Shannon Nicole Abiola
  • Shannon Nicole Armstrong
  • Shannon Abiola-Parham
  • Shannon Nicole Grimes
  • Shannon Nicole Womack
  • Shannon Nicole Lawson
  • Shannon Nicole Lethco
  • Shannon Nicole Robinson
  • Shannon Lee Lawson

If any of the names listed above match any employment records at a provider’s facility, they are urged to contact PSP Washington at 724-223-5200.

Womack is charged with Corrupt Organizations, Endangering the Welfare of Care, Unlawful Use of a Computer, Identity Theft, Forgery, Theft by Unlawful Taking, and multiple other charges.

Criminal charges are merely allegations, and all defendants are presumed innocent unless and until proven guilty.

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