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Medical Rehab

2019 marks the official 18th anniversary of Sexual Assault Awareness Month (SAAM) — but did you know we can trace its history even further back?

Even before its official declaration, SAAM was about both awareness and prevention of sexual assault, harassment, and abuse. Looking at the history of the movement to end sexual violence, it’s clear why: it’s impossible to prevent an issue no one knows about, and it’s difficult to make people aware of a problem without providing a solution. The two work in tandem, and they always have. From the civil rights movement to the founding of the first rape crisis centers to national legislation and beyond, the roots of SAAM run deep.

Roots of the Movement
As long as there have been people who care about making the world a better place, there have been individuals advocating for sexual assault prevention. In the United States, movements for social change and equality began to gain traction in the 1940s and 50s with the civil rights era. Although open discussion of the realities of sexual assault and domestic violence were limited at these times, activists for equal rights began to challenge the status quo.

Sexual Assault Awareness Month is about more than awareness — the ultimate goal is prevention. Since consent is a clear, concrete example of what it takes to end sexual harassment, abuse, and assault, this year’s theme centers on empowering all of us to put consent into practice. The campaign theme, I Ask, champions the message that asking for consent is a healthy, normal, and necessary part of everyday interactions.

Sexual assault is a serious and widespread problem. Nearly one in five women in the US have experienced rape or attempted rape at some time in their lives, and one in 67 American men have experienced rape or attempted rape. When we talk about prevention, we mean stopping sexual violence before it even has a chance to happen. This means changing the social norms that allow it to exist in the first place, from individual attitudes, values, and behaviors to laws, institutions, and widespread social norms. Prevention is everyone’s responsibility: All of us can create and promote safe environments. We can intervene to stop concerning behavior, promote and model healthy attitudes and relationships, and believe survivors and assist them in finding resources.

The National Sexual Violence Resource Center (NSVRC) is the leading nonprofit in providing information and tools to prevent and respond to sexual violence. NSVRC translates research and trends into best practices that help individuals, communities, and service providers achieve real and lasting change. The center also works with the media to promote informed reporting. Every April, NSVRC leads Sexual Assault Awareness Month (SAAM), a campaign to educate and engage the public in addressing this widespread issue.

Be sure to share your sexual assault awareness programs and activities on social media, and feel free to share on the RCPA Facebook page and Twitter feed as well.

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One of the topics on the agenda at the March 2019 Medicare Payment Advisory Commission (MedPAC) public meeting focused on the evaluation of an episode-based payment system for post-acute care (PAC). MedPAC advises Congress about the federal programs (Medicare and Medicaid). Over the years, there have been many discussions regarding whether the federal government should implement one payment system across post-acute providers, which vary greatly in how they are paid. Post-acute providers include inpatient rehabilitation facilities (IRFs), skilled nursing facilities (SNFs), home health agencies, and long-term care hospitals (LTCHs). During the March presentation, MedPAC shared that they favor a stay-based system, rather than one tied to a whole episode of care for fear that the episode of care would encourage providers to discharge patients early. The Department of Health and Human Services (HHS) will work with an outside vendor to build a unified PAC payment model with a goal to submit it to Congress by 2022. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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The Centers for Medicare and Medicaid Services (CMS) recently updated the inpatient rehabilitation facility (IRF) provider preview reports. The data contained in these reports is based on quality data that was submitted by providers between Quarter 3 for 2017 and Quarter 2 for 2018 and reflects what will be published on IRF Compare when the site is refreshed in June 2019. Instructions are available for providers on how to review the reports. The reports will be available for providers to review until April 3, 2019. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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The Department of Defense (DoD) issued a proposed rule to add certified or licensed physical therapy assistants (PTAs) and occupational therapy assistants (OTAs) as TRICARE-authorized providers, to engage in physical or occupational therapy, under the supervision of a TRICARE-authorized physical or occupational therapist, in accordance with Medicare’s rules for supervision and qualification when billed by under the supervising therapist’s national provider identification number. This rule will align TRICARE with Medicare’s policy. Comments on this proposed rule will be accepted until Tuesday, February 19, 2019. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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During the November Centers for Medicare and Medicaid Services (CMS) National Provider call with inpatient rehabilitation facilities (IRFs), CMS responded to a question related to the counting of minutes of therapy provided by a therapy student that these minutes would not count, regardless of the level of supervision.

This triggered much confusion and led to the therapy professional associations requesting a meeting with CMS to discuss and address this and their concerns surrounding this response. After this collaborative effort between these associations and CMS, CMS issued a clarification of its position on therapy students in IRFs.

CMS has noted that student therapists may participate in therapy provided in an IRF if the student is appropriately supervised, and that the time spent with the student may count towards satisfying intensity of therapy requirements for IRFs. Cited directly from the clarification:

“Regarding the IRF intensive rehabilitation therapy program requirement in 42 CFR 412.622(a)(3)(ii), CMS’s current policy does not prohibit the therapy services furnished by a therapy student under the appropriate supervision of a qualified therapist or therapy assistant from counting toward the intensive rehabilitation therapy program. However, IRFs provide a very intensive hospital level of rehabilitation therapy to some of the most vulnerable patients. To ensure the health and safety of this vulnerable population, CMS expects that all student therapy services will be provided by students under the supervision of a licensed therapist allowed by the hospital to provide such services.”

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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The Centers for Medicare and Medicaid Services (CMS) released Change Request (CR) 11055, “Annual Update to the Per-Beneficiary Therapy Amounts.” This CR provides information on the annual per-beneficiary incurred expense amounts, now known as the KX modifier thresholds, and related policy updates for calendar year (CY) 2019. These amounts were previously associated with the financial limitation amounts (therapy caps) before the application of the therapy caps was repealed when the Bipartisan Budget Act (BBA) of 2018 was signed into law.

For CY 2019, the KX modifier threshold amount for physical therapy (PT) and speech-language pathology (SLP) services combined is $2,040. For occupational therapy (OT) services, the CY 2019 threshold amount is $2,040.

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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On November 15, 2018, the Centers for Medicare and Medicaid Services (CMS) held a National Provider Call for inpatient rehabilitation facilities (IRFs) that focused on the changes included in the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule.

CMS has posted the presentation from this call and recently posted both the audio recording and transcript. RCPA encourages all members in the Rehabilitation Services Division to listen to this recording or read the transcript from this call. Questions can be directed to Melissa Dehoff.

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During the question and answer segment of the Centers for Medicare and Medicaid Services (CMS) National Provider call that focused on the inpatient rehabilitation facility (IRF) payment and coverage policies for the fiscal year 2019 final rule on November 15, 2018, there was a response from CMS on the role of therapy students in providing care to patients in IRF hospitals and units that caused a great deal of confusion. The question related to counting minutes of therapy provided by a therapy student with guidance. The response was that these minutes would not count, regardless of the level of supervision.

Due to the amount of confusion this call has triggered, the therapy professional associations will be working with CMS on this issue and clarification will likely be forthcoming. RCPA will provide this clarification to members once this is received. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.