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Medical Rehab

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The Pennsylvania Departments of Aging and Human Services recently announced an agreement with Aging Well (a subsidiary of the Pennsylvania Association of Area Agencies on Aging or P4A that represents all Area Agencies on Aging) to partner on the implementation of Community HealthChoices (CHC).

Under this new agreement, Aging Well will have the following responsibilities:

  • Complete the Functional Eligibility Determinations (FEDs) (via subcontracts with AAAs). Aging Well will conduct the FEDs for participants seeking eligibility for long-term services and supports. Aging Well will also perform the annual in-person re-determinations for people over the age of 60. While FEDs currently need to be completed for individuals applying for the Office of Long-Term Living (OLTL) waivers, ACT 150 program, Living Independence for the Elderly (LIFE), and nursing facility coverage, as the commonwealth begins its implementation of Community HealthChoices, Aging Well will continue to fulfill this role. In addition, as the commonwealth transitions from the existing assessment tool (the Level of Care Determination) to the FED, Aging Well will continue to actively support and facilitate this conversion.
  • Conduct Pennsylvania Preadmission Screening Resident Review Evaluation (PASRR-EV Level II Tool) (via subcontracts with AAAs). Aging Well will conduct the screening for individuals with a mental illness, intellectual disability or related condition, who are seeking admission to Medicaid certified nursing facilities regardless of payer source. These individuals must have the PASRR process completed prior to admission to the nursing facility.
  • Annual re-determinations (via subcontracts with AAAs). Prior to the implementation of CHC, Aging Well will conduct an annual in-person re-assessment within 10 business days of request by a service coordinating entity for all Aging Waiver participants. After the implementation of CHC, Aging Well will review FED assessment data collected by the managed care organizations for all CHC waiver participants in order to confirm annual redeterminations of level of care have been properly conducted. This will be completed as a desk review.
  • Conduct CHC outreach and education activities statewide (via partnerships with AAAs, nursing facilities, and community-based organizations). Aging Well will begin outreach and education activities in July 2017 for the rollout of Phase 1. These activities include 20 public information sessions and training of service coordinators and nursing facility staff.

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On Thursday, June 29, 2017, the Centers for Medicare and Medicaid Services (CMS) and the Office of Medicare Hearings and Appeals (OMHA) will host a call from 1:00 pm to 3:00 pm that will focus on the recent regulatory changes to the Medicare claims appeals process. There will also be discussion surrounding the Medicare Appeals Final Rule that was published in the January 17, 2017 Federal Register, as well as the changes that are intended to streamline the administrative appeals processes, reduce the backlog of pending appeals, and increase the consistency in decision making across appeal levels.

To participate in the call, registration is required by 12:00 pm on June 29, or until the event is full. Following the presentation, time will be allocated to a session for questions and answers.

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In this year of challenging state-level budget negotiations, RCPA is working with a coalition of community foundations, United Way organizations, Labor Unions, religious and advocacy groups, and other key stakeholders in the #FamilyFirstPA Coalition. The growing list of coalition members can be viewed on the #FamilyFirstPA#FamilyFirstPA website. The main goal of the #FamilyFirstPA Campaign is to ensure that there are no cuts to human services in upcoming 2017/2018 state budget. Cuts to human services not only cause irreparable damage to Pennsylvania families, but they also have adverse impacts on organizations that our families rely on. Sharing family stories via social media was the first phase of this campaign. Now, we need your support to push our efforts to the next level. As a coalition partner, RCPA is encouraging our members to amplify the work of the coalition by making use of the social media resources created by this initiative for the coalition. Engage with #FamilyFirstPA on social media; “Like” us on Facebook and “follow us” on Twitter. The initiative is now sharing family stories from across Pennsylvania and engaging legislators through our posts and tweets. Encourage your staff, families, other organizations, county and state level stakeholders, to like and follow the campaign as well.

Any questions about the work of the #FamilyFirstPA Coalition can be directed to Connell O’Brien, who is serving as liaison between RCPA and the #FamilyFirstPA initiative.

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The Office of Long-Term Living (OLTL) recently announced an upcoming stakeholder meeting regarding the Consumer Assessment of Healthcare Providers and Systems (CAHPS) Home and Community-based Services (HCBS) survey. This meeting, scheduled for Wednesday, June 7, 2017, at 1:30 pm, will include representatives from the State of Connecticut (CT) who will share their experiences during the testing of the tool. Members are invited to participate in person (Honor’s Suite 333 Market Street Tower, Harrisburg, PA) or via webinar by registering prior to the meeting. After registering, you will receive a confirmation email containing information about the webinar. Members are encouraged to submit any questions for the representatives from CT in advance of the call to Melissa Dehoff by 12:00 pm on Tuesday, June 6.

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During the past few years, the state Medicaid program, HealthChoices, has begun to implement and expand the use of Value-Based Purchasing models in procurement contracts with all Physical Health Managed Care Organizations (PH-MCOs). With a goal of increasing clinical outcomes, patient satisfaction, and cost management, the PH-MCOs have called for increased use of such Value-Based Purchasing models as Pay for Performance, Patient Centered Medical Homes, and Bundled Payments. On May 25, the leadership of the Offices of Medical Assistance Programs (OMAP) and Mental Health and Substance Abuse Services (OMHSAS) conducted a webcast to review the implementation process used in HealthChoices by the PH-MCOs and their provider networks, and to introduce the process of expanding Value-Based Purchasing to the Behavioral Health Managed Care Organizations and their provider networks. The OMHSAS target for introducing this expansion is January, 2018 with a focus on integrated and collaborative behavioral and physical health and care coordination.

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The Centers for Medicare and Medicaid Services (CMS) announced in the May 19, 2017 Federal Register, that they will again delay the final rule that implements three new Medicare Parts A and B episode payment models (EPMs), the cardiac rehabilitation incentive payment model, as well as changes to the existing comprehensive care for joint replacement (CCJR) model. The delay in the CCJR regulation amendments will allow CMS to maintain and align policy changes with the EPMs. The final rule will now become effective on January 1, 2018.

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The Pennsylvania Department of Health (PA-DOH), in collaboration with the state’s Academy of Pediatrics’ Medical Home Initiative (PA-AAP, MHI), is working “to increase access to medical homes for children, youth, and young adults, including those with special health care needs.” Medical Homes are comprehensive, team-based care that takes into account the whole person. Input from a broad range of health, behavioral health, dental, and social support providers, as well as families, is needed. Over the past month, PA-DOH and PA-AAP, MHI have conducted stakeholder meetings across Pennsylvania. Now, you are invited to participate in a Stakeholder Input Survey and provide your ideas about strengthening the medical home approach in your community.

For practitioners, providers, and consumers supporting integrated physical health and behavioral health care, this opportunity to share our perspectives and ideas should not be missed. Also, please feel free to share this survey information with colleagues in health care, mental health, education, children and youth services, and families in your community.

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On April 27, 2017, the Centers for Medicare and Medicaid Services (CMS) released the display version of the fiscal year (FY) 2018 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

Some of the key provisions are provided below; a more detailed analysis of the proposed rule with be forthcoming following the publication of the proposed rule in the May 3, 2017 Federal Register. In addition, CMS published a Fact Sheet that highlights the major provisions of the proposed rule.

ICD-10-CM Presumptive Compliance Coding Changes
CMS is proposing to make refinements to the ICD-10-CM lists used in determining IRFs’ presumptive compliance with the 60 percent rule. The complete lists of proposed code revisions are available for download on the IRF PPS website. CMS notes that the version of these lists that is finalized in conjunction with the FY 2018 IRF PPS final rule will constitute the baseline for any future updates to the presumptive methodology lists. The codes include:

  • TBI and Hip Fracture Codes

The proposed rule addresses certain ICD-10-CM diagnosis codes for patients with traumatic brain injury (TBI) and hip fracture conditions. CMS proposes to include such codes in counting towards presumptive compliance when they are used as an etiologic diagnoses in the following IGCs effective October 1, 2017:

Brain Dysfunction – 2.21 Traumatic, Open Injury;
Brain Dysfunction – 2.22 Traumatic, Closed Injury;
Orthopedic disorders – 8.11 Status Post Unilateral Hip Fracture; and
Orthopedic disorders – 8.11 Status Post Bilateral Hip Fracture.

The complete list of TBI and hip fracture ICD-10-CM codes is available for download on the CMS IRF PPS website.

  • Major Multiple Trauma Codes

CMS also proposes changes to address major multiple trauma codes that did not translate exactly between ICD-9-CM and ICD-10-CM. Specifically, CMS proposes to count IRF Patient Assessment Instruments (PAIs) that contain 2 or more of the ICD-10-CM codes from the three major multiple trauma lists that can be downloaded here. In order for patients with multiple fractures to qualify as meeting the 60 percent rule requirement for IRFs under the presumptive methodology, codes from the following lists could be used if combined as CMS describes in the proposal whereby (a) at least one lower extremity fracture is combined with an upper extremity fracture and/or rib/sternum fracture or b) fractures are present in both lower extremities:

List A: Major Multiple Trauma—Lower Extremity Fracture
List B: Major Multiple Trauma—Upper Extremity Fracture
List C: Major Multiple Trauma—Ribs and Sternum Fracture

  • Removed Codes and Other Proposals

CMS proposes to remove certain non-specific and arthritis diagnosis codes that were inadvertently reintroduced through the ICD-10-CM conversion process, and removing one ICD-10-CM code (G72.89 – Other specified myopathies) that was identified as being inappropriately applied to patients with generalized weakness, instead of to patients with clinically identified myopathies. Specifically CMS is proposing to remove 15 codes related to rheumatoid polyneuropathy with rheumatoid arthritis.

Request for Information
CMS also included a Request for Information (RFI) for continuing feedback on the Medicare Program. Feedback is requested on potential regulatory, sub-regulatory, policy, practice and procedural changes to make the delivery system less bureaucratic and complex, reduce burden for clinicians and providers, and increases quality of care while decreasing cost. CMS asked to be provided with clear and concise proposals that include data and specific examples. CMS will not respond to RFI comment submissions in the final rule, but rather will actively consider all input in developing future regulatory proposals or future sub-regulatory guidance. Ideas addressing opioid use disorder and other substance use disorders is a big area of interest.

IRF Classification Criteria
CMS is also specifically seeking stakeholder input on the 60 percent rule, including but not limited to, the list of 13 conditions used to evaluate 60 percent rule compliance.

Proposed Future Measures
Transfer of Information Measures
CMS is developing two Improving Medicare Post-Acute Care Transformation (IMPACT) Act-required measures regarding post-acute care providers’ Transfer of Information. It intends to specify these measures by October 1, 2018 and propose them for adoption in the FY 2021 IRF QRP, with data collection beginning “on or about” October 1, 2019. The measures are 1) Transfer of Information at Post-Acute Care Admission, Start or Resumption of Care from other Providers/Settings, and (2) Transfer of Information at Post-Acute Care Discharge, and End of Care to other Providers/Settings. Experience of Care and Patient-Reported Pain
CMS is developing an experience of care survey for IRFs, and survey-based measures will be developed from this survey. The survey explores experience of care across five main areas: (1) beginning stay at the rehabilitation hospital/unit; (2) interactions with staff; (3) experience during the rehabilitation hospital/unit stay; (4) preparing for leaving the rehabilitation hospital/unit; and (5) overall rehabilitation hospital/unit rating. CMS is also considering a patient-reported pain measure, Application of Percent of Residents Who Self-Report Moderate to Severe Pain (Short Stay) (NQF #0676), for future rulemaking.

Public Reporting
CMS proposes to publicly report data on six additional measures:

  • Application of Percent of Long-Term Care Hospital (LTCH) Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631) (assessment-based);
  • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674) (assessment-based);
  • Medicare Spending Per Beneficiary-PAC IRF QRP (claims-based);
  • Discharge to Community-PAC IRF QRP (claims-based);
  • Potentially Preventable 30-Day Post-Discharge Readmission Measure for IRF QRP (claims-based); and
  • Potentially Preventable within Stay Readmission Measure for IRFs (claims-based).

Comments on the proposed rule will be accepted until June 27, 2017. Discussion on the provisions of this proposed rule will be included as an agenda topic at the June Medical Rehabilitation Committee meeting.

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RCPA will host its annual conference at the Hershey Lodge on October 10–13, 2017. At this large-scale, statewide event, the RCPA board of directors wants to continue the important tradition of recognizing individuals and organizations/facilities for their dedication and commitment to service. The following award categories have been created for this event and recognition:

  • RCPA Innovation Award. Presented to an individual or organization in recognition of significant innovation. Examples include cross-systems integration, physical/behavioral health integration, and implementation of new technologies.
  • Exemplary Service to RCPA Award. Presented to an individual or organization/facility that has shown a strong commitment and dedication in service to the association, its members, and related issues.
  • Legislative Leadership Award. Presented to an individual who has shown significant leadership and commitment to government affairs and legislative issues, on behalf of RCPA and its members.
  • Community Leadership Award. Presented to an individual in recognition of extending service and knowledge to the community at large, and efforts in helping the community understand the needs of individuals served by RCPA members. This can be for specific or short-term significant acts, or to recognize a career-long body of work.
  • Lifetime Achievement Award. Presented to an individual in honor of his/her significant, consistent, and enduring contribution throughout his/her career in support and furthering of the field.

At this time, RCPA is accepting nominations through an open solicitation of members (e.g., designated contact person, CEOs/executive directors, staff) and RCPA committees. Members may nominate one or more individuals/organizations in one or more categories. Nominations will be reviewed by a sub-group of the board of directors to make recommendations for final selection and approval by the full board.

Include the name/organization (if applicable) of the nominee, the award category, and a statement about why you believe the individual/organization should be honored. Nominations should be made by Friday, June 2, 2017. Please send nominations to Cindy Lloyd.

Award recipients are not limited to RCPA members and every award may not be presented annually. Please join the association in continuing this tradition and in offering nominations for those who deserve recognition for their significant contributions.

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The Centers for Medicare and Medicaid Services (CMS) will be hosting a live webcast for inpatient rehabilitation facilities (IRFs) on Tuesday, May 2, 2017, from 2:00 pm to 3:30 pm. The focus of the webcast will be to provide a better understanding of how Review and Correct Reports fit within the overall Quality Reporting Program (QRP). The webcast will also provide information about re-submitting data to correct errors prior to the quarterly submission deadlines to ensure the accuracy of the data which will be publicly displayed. Registration is required to participate. Those who register will be provided with a URL to access the training immediately upon completing the registration process.The webcast will be recorded and posted to the CMS YouTube site following the event.

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