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RCPA’s Outpatient Rehabilitation Committee meeting on August 15 has been cancelled due to conflicts encountered by individuals scheduled to present at the meeting. The next meeting will take place as scheduled on November 14, 2024, from 12:00 pm – 1:00 pm. If you have any questions, please contact Melissa Dehoff.
The Centers for Medicare and Medicaid Services (CMS) released and published the fiscal year (FY) 2025 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule in the August 6, 2024, Federal Register. Some of the key provisions contained in the provider rule are noted below.
Payment Updates
CMS estimates aggregate payments to IRFs will increase by 2.8 percent in FY 2025, compared to the 4.0 percent payment update that CMS finalized for FY 2024. This update is the result of an annual market basket update, reduced by a productivity adjustment, budget neutrality adjustments for changes to CMG weights and labor/wage changes, and adjustments to the outlier case threshold.
As in previous years, CMS will adopt new delineations for the Core-Based Statistical Areas (CBSA) as identified by the Office of Management and Budget (OMB). [Additional and more detailed information on these new CBSAs can be found in OMB Bulletin No. 23-01] These changes will result in certain counties being reclassified from urban to rural and vice-versa, as well as some counties shifting to different CBSAs. As a result, CMS projects that approximately 10 percent of providers will have a higher wage index, but 16 percent will face a decrease in wage index values (primarily for those reclassified as urban, thus losing the rural adjustment). Thus, CMS finalized a transitional “phase-out” policy for those negatively impacted, such that IRFs set to lose their rural adjustment will retain two-thirds of the adjustment in FY 2025, one-third of the adjustment in FY 2026, and fully “lose” the rural adjustment in FY 2027. CMS estimates that 8 IRFs would be reclassified as urban and thus lose the 14.9 percent rural adjustment.
CMS increased the outlier threshold amount from $10,423 for FY 2024 to $12,043 for FY 2025 (slightly lower than the proposed rule’s projection). This change will account for an estimated 0.2 percent decrease to aggregate payments across the IRF PPS in FY 2025.
Quality Reporting Program (QRP) Updates
CMS finalized its proposal to adopt four new items as Standardized Patient Assessment Data Elements (SPADE) under the social determinants of health (SDOH) category beginning with the FY 2028 IRF QRP: one Living Situation item; two Food items; and one Utilities item. CMS notes that these new SPADES are intended to assist IRFs in “better addressing those identified needs with the patient, their caregivers, and community partners during the discharge planning process, if indicated.”
Transportation Item Modification Finalized Beginning with the FY 2028 IRF QRP (October 1, 2026 Implementation)
Consistent with the AHC HRSN Screening Tool, CMS finalized a proposal to modify the A1250. Transportation item currently collected in the IRF–PAI in two ways: (1) revise the look-back period for when the patient experienced lack of reliable transportation; and (2) simplify the response options.
Finalized Proposal to Remove the Admission Class Item From the IRF-PAI Beginning October 1, 2026, with Minor Modification
For additional information, CMS published a fact sheet that provides an overview of the provisions contained in the final rule.
In accordance with DHS rebranding and the Governor’s Office Customer Service Transformation Initiative, the Office of Medical Assistance Programs will be implementing changes to the old URLs to reach PROMISe hosted applications and websites. The old URLs, using a domain naming convention of dpw.state.pa.us, will be changing to dhs.pa.gov in phased implementations beginning August 7, 2024, and wrapping up in October 2024. Please review the PDF listed below, containing the impacted production environment URLs.
See document for specific PROMISE activity URL updates.
Who is Impacted?
When is this happening?
How will these changes be communicated?
What can I do to aid this transition?
If you have further questions, please contact the above OMPA Ra account or your respective RCPA Policy Director.
Early bird rates for the 2024 RCPA Conference Embracing Challenges, Empowering Success are ending August 23, meaning you won’t want to wait any longer to claim your seat, book that hotel room, and get ready to make new connections! Register today to gain access to over 60 thought-provoking workshops and speakers who are at the forefront of change in health and human services, including:
View our registration brochure for complete details on the conference schedule, current sponsors and exhibitors, and a word from RCPA President and CEO Richard Edley.
Time is also running out if your organization is interested in sponsoring or exhibiting at our conference — the deadline for items is August 23, 2024! Now is your chance to complete our Sponsors, Exhibitors, and Advertisers Brochure or contact Carol Ferenz, Conference Coordinator, for opportunities to showcase your organization.
We look forward to sharing more details in the near future and would like to extend a thank you to those organizations who have already pledged support for the conference! View our current sponsors and exhibitors on the RCPA Conference website!
The Centers for Medicare and Medicaid Services (CMS) has recognized traumatic brain injury (TBI) as a chronic health condition. TBI has been added to CMS’ list of chronic conditions for chronic special needs plans (C-SNPs) through its Medicare Advantage program, effective for the January 2025 plan year.
The addition of TBI to the list of chronic conditions was included in a final rule published by CMS in the June 2024 Federal Register, which will become effective on January 1, 2025. Obtaining official recognition of TBI as a chronic condition from CMS is a significant step forward and provides validation that brain injury should be more broadly recognized as a chronic condition.
In March 2024, the Brain Injury Association of America (BIAA) published a position paper requesting CMS, along with the Centers for Disease Control and Prevention (CDC), to designate brain injury as a chronic condition. Formal recognition, the paper states, has the potential to provide several advantages for people with brain injury, including the allocation of additional public health resources to focus on the lifelong effects of brain injury as well as health insurance plans, primarily Medicare and Medicaid, providing additional benefits and other supports as they do for other chronic health conditions. The greatest benefit, however, would be an increase in public awareness of the long-term effects of brain injury that affect the estimated 5 million Americans with a brain injury-related disability.
BIAA will be hosting a live Question and Answer (Q&A) session in the near future to discuss these changes and future tools and resources to assist survivors and their loved ones advocate for further expanding coverage.
RCPA is excited to once again host the RCPA PAC silent auction, which is to be held in conjunction with the RCPA conference. The silent auction will take place outside Connections Hall during the conference, and we are looking to attract the attention of over 700 attendees, including registrants, presenters, exhibitors, and sponsors. The money raised helps to support the RCPA PAC, which provides financial support to state legislators who have demonstrated a strong, consistent, and positive interest in our issues and priorities.
We are requesting your consideration in assisting us by providing a donation of an auction item. We are hoping to secure a variety of auction items that will be enticing to all members. All donations are greatly appreciated and can be something as simple as a gift certificate for a restaurant to a basket of sorts (candy, movie night, grilling items, cooking theme, etc.). We are also accepting items such as jewelry, designer handbags, tickets to college or professional sporting events, golf items, and sports memorabilia.
We would like to thank our donors to date, including the following:
Please contact Christine Tartaglione before September 6, 2024, if you would like to donate any items. Thank you for your consideration of our request. We hope we can count on your support, and we look forward to seeing you at the conference.

The Department of Human Services has released a new Request for Information (RFI) to assist in determining possible implementation needs for the Commonwealth’s proposed 1115 Demonstration Waiver titled, Bridges to Success: Keystones of Health for Pennsylvania. This RFI will help inform a potential scope of work for private, public, and nonprofit organizations that could serve in the future as a program administrator for the program. If approved and implemented, Keystones of Health would bring new resources to Pennsylvaniaʼs Medicaid program to address health-related social needs (HRSN) that have a direct impact on health care spending and health outcomes. Responses to the RFI are due August 19, 2024 by 12:00 pm.
The proposed Keystones of Health program seeks to expand tools available to address critical health care needs of Pennsylvanians in four main areas: reentry supports, housing resources, food and nutrition services, and continuous health coverage for children under the age of six. This RFI seeks information to assist DHS in implementing the proposed housing, food, and nutrition services for beneficiaries. Through this RFI, the department is seeking knowledge about potential program administrator responsibilities and capabilities for administering these HRSN services. The RFI will also inform aspects of the DHS implementation plan that is currently in development, while the Commonwealth collaborates with the Centers for Medicare & Medicaid Services to secure approval. The department encourages respondents and other interested parties to provide feedback by responding to the RFI.
Section 1115 of the Social Security Act gives the federal government the ability to waive certain federal rules that govern Medicaid to allow states to design and evaluate new state pilot projects that promote the general goals of the Medicaid program, helping people live healthier lives. Section 1115 waivers are a major pathway for state innovation in the Medicaid program that many states have leveraged. If approved, and the necessary state funds are appropriated, it would allow DHS to introduce innovative programs and services that address health-related social needs that can improve health and quality of life for Pennsylvanians who access health care through Medicaid.
Submit feedback to DHSʼ Request for Information. The full application, including information on feedback received through public comment, is available on the Keystones of Health web page.
RCPA is reviewing the RFI internally and will meet with interested members on the RFI in the coming week. If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.