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Brain Injury

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The Department of Human Services (DHS) just announced their decision to lengthen the transition time for the start of the Community HealthChoices (CHC) program. The first phase (southwest part of the state) was originally scheduled to be implemented on January 1, 2017. The implementation date of phase one has now been changed to begin July 1, 2017.

The decision to extend the start date allows more time for the 420,000 Pennsylvanians who will ultimately benefit from CHC to understand the program adjustments that will occur, including how access to and receipt of home- and community-based services will be improved.

All other established CHC timeframes will remain the same. The selection of managed care companies, changes in the Commonwealth’s information technology systems, and other changes are still proceeding on the same timeframe. The implementation of phases two and three (the southeast and remainder of the Commonwealth) also remain on the previously announced timelines of 2018 and 2019, respectively.

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The commencement of Certified Community Behavioral Health Clinics through Pennsylvania’s Department of Human Services, and the growing movement of individual providers to create medical homes to provide clients with co-located mental health and primary care providers in one facility, holds tremendous promise and opportunity for the coordination and enhancement of delivery of care to clients. These new provider relationships in shared office and facility spaces create new legal issues for providers under the federal Stark law and Anti-kickback statute. Providers must ensure that they do not inadvertently run afoul of these important federal fraud and abuse laws.

RCPA will offer a webinar presented by Renee H. Martin, JD, RN, MSN, a partner in the firm of Dilworth Paxson, LLP. This webinar will describe the legal requirements providers must be aware of under these federal laws and help to apply that knowledge in structuring financial relationships for use of these shared spaces. The webinar is intended for provider organizations’ executive staff, project planners, and legal counsel.

Stark Law and Integrated Health Care Webinar
Wednesday, June 29
12:00 – 1:00 pm
Register today

  • RCPA member registration is $25
  • Non-member registration is $40

Presenter: Ms. Martin exclusively practices health care law and advises both individual and institutional health care providers on regulatory and transactional matters. A significant portion of her practice centers on mental health and substance abuse law, including HIPAA, informational privacy, and fraud and abuse compliance. Ms. Martin has assisted in the formation of regional health information centers and mental health medical homes, working closely with federally qualified health centers and mental health providers.

RCPA will now distribute INFOS and ALERTS covering research, delivery and training models, policy issues, and other topics that will inform our members about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.

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Dear Colleagues:

We are excited to announce that we have received 14 responses to the recent request for proposal (RFP) issued for Community Health Choices (CHC). This vital program will allow the departments of Human Services and Aging to serve more Pennsylvanians in their communities and allow consumers to have an active voice in the services they receive.

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The Department of Human Services (DHS) has made available for public review and comment the proposed Community HealthChoices (CHC) 1915(b) waiver and the proposed CHC 1915(c) waiver amendments, as published in the April 23, 2016 Pennsylvania Bulletin. If approved, the waiver will govern the operation of the CHC program, Pennsylvania’s managed long-term services and supports initiative.

Available for review on the DHS website are the proposed CHC concurrent 1915(b) and (c) waiver application and a detailed summary of all provisions, including a list of long-term services and supports which will be covered under the 1915 (c) waiver, and a summary of the person-centered planning requirements, participant fair hearing rights and grievance and complaint procedures, participant safeguards, quality management processes, payment methodologies, and cost effectiveness demonstration.

The Office of Long-Term Living will offer two CHC Waiver webinars in May for public input and discussion:

The public comment period ends Monday, May 23, 2016. Comments received within the 30-day comment period will be reviewed and considered for revisions to the applications.

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A Question and Response Addendum has been added to the PA e-Marketplace website, for the request for proposals (RFP) for managed care organizations that will be submitting their proposals and responses for the Community HealthChoices program. The addendum is located under “Flyers/Addendums” on the web page. The 81-page addendum includes the RFP section, questions, and answers to each question posed.

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The Department of Human Services (DHS) Office of Long-Term Living (OLTL) will be submitting amendments to the Aging, Attendant Care, and Independence waivers. The public notice announcing the amendments will appear in the April 2, 2016 Pennsylvania Bulletin.

To view a side-by-side comparison of the current and revised language, and to access the amendments in their entirety (including specific HCBS Allowable Settings Transition Plans and the Community HealthChoices Transition Plans for each waiver, contained in the Main Module), visit the OLTL Waiver Amendment, Renewals, and Accompanying HCBS Transition Plans website and select the individual waiver amendment you would like to review under “Related Topics.”

OLTL is seeking public comment on the Aging, Attendant Care, and Independence waiver amendments. Those interested are invited to submit written comments to the Department of Human Services, Office of Long-Term Living, Bureau of Policy and Regulatory Management, Attention: Aging Waiver, Independence Waiver, or Attendant Care Waiver, PO Box 8025, Harrisburg, PA 17105-8025. Comments can also be sent via email, using the comment form link. On this site, select the individual waiver amendment you would like to view under “Related Topics” and the comment form will be listed in the documents.

The public comment period ends on Monday, May 2, 2016. Comments received within the 30-day comment period will be reviewed and considered for revisions to the amendments.

OLTL will offer two webinars in April for public input and discussion:

Aging, Attendant Care, and Independence Waiver Changes Webinar
Wednesday, April 13, 2:00 – 3:00 pm

Aging, Attendant Care, and Independence Waiver Changes Webinar
Tuesday, April 19, 10:00 – 11:00 am

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The Department of Human Services (DHS) Medical Assistance Online Provider Enrollment Application information is now electronic, online, and available to provider organizations. The improvements and modernization of the PROMISe system have been strongly encouraged by RCPA and a significant goal of DHS. Some of the benefits of online enrollment application submissions are:

  • Allowing documents that previously had to be mailed or faxed to be uploaded directly to the portal;
  • Permitting providers see the status of their submissions; and
  • Decreasing wait time to review applications.

The information you will need to submit an application for enrollment:

  • Access the online enrollment application
  • Review the training guide
  • Review the frequently asked questions document for important clarifications
  • A “Help” feature is available at any time during the completion of an application
  • Supplemental Services require the Behavioral Health Managed Care Organization to attest that a provider is credentialed
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