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Medical Rehab

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The Office of Vocational Rehabilitation (OVR) is conducting a comprehensive statewide needs assessment designed to meet and satisfy the state plan requirements in the Rehabilitation Act of 1973, as amended, and the Workforce Innovation and Opportunity Act. As part of this assessment, the Institute on Disabilities at Temple University is asking Pennsylvania employers and workforce professionals to complete a brief survey to identify how OVR can better support employers and employees across Pennsylvania.

This project is being conducted in cooperation with the Pennsylvania Rehabilitation Council and with the assistance of the Institute on Disabilities. If you are an employer or a workforce professional you are encouraged to complete this brief survey by Monday, August 1. Once you’ve completed the survey, you can enter in a drawing to win a $20 Target gift card.

The Institute on Disabilities is also seeking employer stakeholders to participate in brief phone interviews and share their expertise with the Institute. Interested employers can email or call 215-204-9544.

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Your feedback is greatly needed. The US Department of Labor (DOL) has issued its final overtime rule which increases the threshold related to the overtime exemption. This has caused great concern among RCPA members as there is no additional funding being proposed to cover the cost of this change. RCPA will be submitting testimony and testifying in front of the Senate Labor and Industry and Senate Appropriations Committees on Tuesday, June 21 regarding this issue. In preparation for this important Senate hearing, we are asking members to complete this SURVEY no later than Wednesday, June 15, so that we have data to present in addition to our concerns.

If you have already taken the survey, you do not need to provide feedback again. We appreciate your attention and input regarding this very important issue. Thank you.

Please contact RCPA Director of Government Affairs Jack Phillips with any questions.

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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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The Centers for Medicare and Medicaid Services (CMS) will conduct a call on the key quality measures related to the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 and how they will affect providers. The IMPACT Act requires the reporting of standardized patient assessment data on quality measures, resource use, and other measures by Post-Acute Care (PAC) providers, including inpatient rehabilitation facilities, skilled nursing facilities, home health agencies, and long-term care hospitals. The call is scheduled for Thursday, July 7, 2016 from 1:30 to 3:00 pm ET. Those interested in participating are encouraged to register early as space is limited.

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On May 3, 2016, the Centers for Medicare and Medicaid Services (CMS) issued an update to the additional documentation request (ADR) limits for Medicare institutional providers under the Medicare fee-for-service (FFS) recovery audit program, which will allow recovery audit contractors (RACs) to request more documents from providers who have high claims denial rates.

For example, a provider with a 0 to 3 percent denial rate will receive no additional RAC document requests for three 45-day review cycles, while providers with denial rates between 91 percent and 100 percent could potentially receive RAC document requests of up to 5 percent of their paid claims. A baseline annual ADR limit is established for each provider based on the number of Medicare claims paid in a previous 12-month period. Using the baseline annual ADR limit, which is one-half of one percent (0.5%) of the provider’s total number of paid Medicare claims from a previous 12-month period, an ADR cycle limit is also established. After three 45-day ADR cycles, CMS will calculate (or recalculate) a provider’s denial rate, which will then be used to identify a provider’s corresponding “Adjusted” ADR limit. Recovery auditors may choose to either conduct reviews of a provider based on their adjusted ADR limit (with a shorter look-back period of six months) or their baseline annual ADR limit (with a longer look-back period of three years).

Questions concerning this update can be submitted via email.

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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.

Continue

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The Centers for Medicare and Medicaid Services (CMS) released a final rule in the May 4, 2016 Federal Register that updates health care facilities’ fire protection guidelines to improve protections from fire for Medicare beneficiaries in facilities.

The new guidelines apply to hospitals; long-term care (LTC) facilities; critical access hospitals; inpatient hospice facilities; programs for all-inclusive care for the elderly; religious non-medical health care institutions; ambulatory surgical centers (ASCs); and intermediate care facilities for individuals with intellectual disabilities (ICF-IID). This rule adopts updated provisions of the National Fire Protection Association’s (NFPA) 2012 edition of the Life Safety Code, as well as provisions of the NFPA’s 2012 edition of the Health Care Facilities Code.

Some of the main provisions in the final rule include:

  • Health care facilities located in buildings that are taller than 75 feet are required to install automatic sprinkler systems within twelve years after the rule’s effective date;
  • Health care facilities are required to have a fire watch or building evacuation if their sprinkler system is out of service for more than ten hours;
  • The provisions offer LTC facilities greater flexibility in what they can place in corridors;
  • Fireplaces will be permitted in smoke compartments without a one hour fire wall rating;
  • Cooking facilities now may have an opening to the hallway corridor;
  • For ASCs, all doors to hazardous areas must be self-closing or must close automatically; and
  • Expanded sprinkler requirements for ICF-IIDs.

Health care providers affected by this rule must comply with all regulations within 60 days of the May 4, 2016 publication date, unless otherwise specified in the final rule.

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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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