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Medical Rehab

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Today, the Centers for Medicare and Medicaid Services (CMS) released the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) transfer of health measures for public review and comment. CMS contracted with the RTI International and Abt Associates to develop cross-setting post-acute care transfer of health information and care preferences quality measures in alignment with the IMPACT Act.

As part of its measure development process, CMS is requesting comments on two draft measure specifications, including:

  1. Medication Profile Transferred to Provider
  2. Medication Profile Transferred to Patient

Additional information is provided on the public comment page on the CMS website. The public comment period closes on May 3, 2018.

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On March 9, 2018, Representative Tina Pickett introduced House Resolution 741 designating the month of March 2018 as “Brain Injury Awareness Month” in Pennsylvania. The resolution was adopted (188–0) on March 14, 2018. A similar co-sponsorship memo was introduced in the Senate by Senator Schwank and will be voted on in the near future. March is nationally recognized as Brain Injury Awareness Month as well.

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The Administration for Community Living (ACL) recently posted a number of grant opportunities associated with traumatic brain injuries (TBI).

On February 7, 2018, College and Career Success for Students with Serious Mental Illness or Traumatic Brain Injury was posted. The purpose of this grant opportunity is to generate new knowledge about the effectiveness of interventions to improve college education and employment outcomes of people with serious mental illness or traumatic brain injury. The funding for this grant is $475,000 and the closing date for applications is April 9, 2018.

On February 14, 2018, two additional grant opportunities were posted:

Traumatic Brain Injury State Partnership Program Partner State Funding Opportunity, whose purpose is to create and strengthen a system of services and supports that maximizes the independence, well-being, and health of persons with TBI across the lifespan, their families, and their caregivers. Through the TBI State Partnership Program, the goal is two-fold:

  1. To allow states to strengthen and grow their capacity to support and maintain a system of services and supports that will help maximize the independence, well-being, and health of persons with TBI; and
  2. To learn from and call upon the expertise of states that have built and maintained a strong and sophisticated state TBI infrastructure. This grant opportunity has an award ceiling of $150,000.

The Traumatic Brain Injury State Partnership Program Mentor State Funding Opportunity has a purpose to create and strengthen a system of services and supports that maximizes the independence, well-being, and health of persons with TBI across the lifespan, their families, and their caregivers. Through the TBI State Partnership Program, the goal is two-fold:

  1. To help states strengthen and grow their capacity to support and maintain a system of services and supports that will help maximize the independence, well-being, and health of persons with TBI; and
  2. To learn from and call upon the expertise of states that have built and maintained a strong and sophisticated state TBI infrastructure. For the 2018 funding cycle, ACL is funding two tiers of grantees that will work together to maximize the program’s impact nationally.

Partner State Grants will provide funding to states for building and enhancing basic infrastructure, while Mentor State Grants will provide funding to more established states to maintain and expand their infrastructure and also to mentor Partner States and work together with other Mentor States and ACL to improve the national impact of the TBI program. Applicants must agree to provide the required 2:1 state match, support a state TBI advisory board, provide at least one full-time dedicated staff person, create an annual TBI state plan, create and/or expand their state TBI registry, work with one or more Partner States to increase their capacity to provide access to comprehensive and coordinated services for individuals with TBI and their families, and work with other Mentor States and ACL to improve national coordination and collaboration around TBI services and supports.

ACL encourages organizations that are interested and qualify to apply for both funding opportunity announcements; however, ACL will not make more than one award to a single applicant. Applicants that score in the fundable range on both reviews may choose which award they wish to receive. Applicants that are only interested in receiving a Partner State Grant do not need to apply for this opportunity. This grant opportunity has an estimated award ceiling of $300,000. The closing date for both of these grant opportunities is April 16, 2018.

RCPA will be working with the Pennsylvania Department of Health (DOH) to review the grant applications and discuss next steps surrounding these opportunities.

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During the January 2018 Medicare Payment Advisory Commission (MedPAC) public meeting, the agenda included the topic of the Merit-based Incentive Payment System (MIPS). MedPAC members voted in favor of recommending Congress eliminate this system, stating the program was burdensome and complex. The presentation also cited that the program “Replicates flaws of prior value-based purchasing programs.” It was recommended that MIPS be replaced with a new model known as the voluntary value program (VVP). The VVP would include an across-the-board withhold for all fee schedule payments, and performance would be assessed using uniform measures across three categories, which include clinical quality, patient experience, and value. Those in favor of the new program indicated it would better prepare physicians to participate in the Medicare Access and CHIP Reauthorization Act’s (MACRA) Advanced Alternative Payment models.

The agenda included many additional topics of interest, some of which referenced increasing the equity of Medicare’s payments within each setting, mandated report on telehealth services and the Medicare program, and a status report on Medicare Accountable Care Organizations.

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On January 9, 2018, the Centers for Medicare and Medicaid Services (CMS) announced their launch of a new voluntary bundled payment model called the Bundled Payments for Care Improvement (BPCI) Advanced. BPCI Advanced will test a new iteration of bundled payments for 32 clinical episodes initially (29 Inpatient Clinical Episodes and 3 Outpatient Clinical Episodes) and will qualify as an advanced alternative payment model (APM) under the quality payment program (QPP). Participants can earn additional payment if all expenditures for a beneficiary’s episode of care are under a spending target that factors in quality.

The Model Performance Period for BPCI Advanced begins on October 1, 2018, and runs through December 31, 2023. For additional information about the model, including the Request for Applications document, application template, etc., visit the BPCI Advanced web page. Applications must be submitted via the application portal. The application portal will close on March 12, 2018.

An open door forum, BPCI Advanced – Model Overview and Application Process, has been scheduled for Tuesday, January 30, 2018, from 12:00 pm – 1:00 pm EST. Registration is now open.

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The Department of Defense (DoD) published the final rule, TRICARE; Reimbursement of Long Term Care Hospitals and Inpatient Rehabilitation Facilities, in the December 29, 2017 Federal Register. This final rule finalizes the changes in the inpatient rehabilitation facility (IRF) payments from the proposed rule that was published back in 2016 and establishes TRICARE inpatient care reimbursement methodologies and rates similar to Medicare. Currently, IRFs are exempted from the TRICARE diagnosis related group (DRG) based payment system and paid by TRICARE at the lower of a negotiated rate or billed charges.

 

To reduce the burden from sudden significant reductions on the IRFs, the final rule includes a gradual transition from TRICARE’s current policy of allowing 100 percent of allowable charges (either the billed charge or voluntary negotiated rate), by phasing-in the Medicare IRF prospective payment system (PPS) rates as follows:

  • Allowing 135 percent of Medicare IRF PPS amounts in the first 12-month period after implementation (estimated reduction of $24M);
  • 115 percent in the second 12-month period after implementation (an estimated reduction of $41M); and
  • 100 percent in the third 12-month period after implementation (an estimated $57M).

The DoD will apply the FY 2019 IRF PPS for purposes of the 12-month period beginning on October 1, 2018, and follow any changes adopted by the Medicare IRF PPS for subsequent years. The provisions in the final rule become effective on March 5, 2018.

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On December 11, 2017, the Centers for Medicare and Medicaid Services (CMS) issued Medicare Learning Network (MLN) Matters Article, SE17036, which provides information about new instructions recently issued to Medicare medical review contractors. The guidance also provides the standards to use when reviewing claims for compliance with the intensity of therapy requirements for inpatient rehabilitation facility (IRF) claims.

If you have any questions, please contact your MAC at their toll-free number, available online.

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The Department of Human Services has been working in collaboration with Managed Care Organizations (MCOs), county oversight organizations, and RCPA regarding the concerns and challenges with implementing federal Ordering, Referring and Prescribing (ORP) requirements by the January 1, 2018 deadline. The Department of Human Services has informed RCPA of the following:

  • The ORP requirements for Fee-for-Service continue to apply; i.e., allORP practitioners must be enrolled in the Pennsylvania Medical Assistance (MA) Program or the rendering provider will not be paid.
  • In the HealthChoices managed care delivery system, if a rendering network provider submits a claim to an MCO with the National Provider Identifier (NPI) information that results in edits identifying that the non-networkORP is not enrolled in MA, the claim can be paid. However, if the non-MA enrolled ORP has a high volume of claims, the MCO will work with the network provider and non-MA enrolled ORP to have them enroll in MA or work to transition the member to an enrolled MA provider.

Contact your contracting BH-MCO for additional information.

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