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Medical Rehab

Immediate Action Required for Regulatory Compliance – Please Read Carefully

The Department of Human Services (DHS) is providing a critical update to those providers who hold a license to operate a facility licensed by DHS. On August 18, 2022, DHS and RCPA released an alert regarding changes in how licensed agencies provide information related to civil rights compliance. Since that time, DHS has received several questions and is providing further clarification.

  1. When sending the CRC form or the CRC attestation form, please send it as a PDF. Please do NOT send as a secure file, secure email, or link to a secure portal to retrieve the document. We are unable to access those forms, and they will be returned. When emailing the forms for submission:
    1. Use the following naming convention in the subject line when submitting Renewal HS2125:
      • Attestation – Program Office – Name of Facility or Agency – License number or APP number if assigned
        • Examples:
          • Attestation – OCYF – Apple Agency Home – 123450
          • Attestation – ODP – Apple Agency – APP-00123456
    2. Use the following naming convention in the subject line when submitting a new application HS2126:
      • New – Program Office – Type of Service – Name of Facility or Agency
        • Examples:
          • New – BHSL  – PCH – Apple Personal Care Home
          • New – ODP – Life Sharing – Apple Agency – APP-00223456
  2. In the Office of Developmental Programs (ODP) and the Office Mental Health and Substance Abuse Services (OMHSAS), there are providers who have one license that cover multiple locations. In this case, you only need to submit one form (either the HS2125 or the HS2126) and list the addresses of each satellite site/location that falls under that license.
  3. If in the past, you completed the Civil Rights Compliance Questionnaire (CRCQ) annually, as part of the renewal license process, you will need to complete the Civil Rights Attestation (HS2125) when you receive your next notice to complete the renewal application process.
  4. If you have a current license, your CRC was approved. You will need to complete the Civil Rights Attestation (HS2125) when you receive your next notice to complete the renewal application process.
  5. For Assisted Living and Personal Care Home providers, when submitting the renewal application for a license, the renewal application, the renewal application fee, and the Attestation (HS2125) must be sent in hard copy in one envelope to Licensing Administration in Harrisburg, as noted on the cover letter of the renewal application packet.
  6. Please ensure that the “Non-Discrimination in Employment” policy statement and the “Non-Discrimination in Services” policy statement issued by your facility contain updated contact information (as indicated below). If this administrative update is the only change that has occurred since the facility’s last license was issued, it is not necessary to provide updated copies to the Department as part of Form HS 2125.

Commonwealth of Pennsylvania
Department of Human Services
BEO/Office of Civil Rights Compliance
Room 225, Health & Welfare Building
P.O. Box 2675 Harrisburg, PA 17120
Inquiries: (717) 787-1127
Email

Office for Civil Rights
U.S. Department of Health and Human Services Centralized Case Management Operations 200 Independence Avenue, S.W.
Room 509F HHH Bldg
Washington, D.C. 20201
Customer Response Center: (800) 368-1019 TDD: (800) 537-7697

U.S. Equal Employment Opportunity Commission
801 Market Street, Suite 1000
Philadelphia, PA 19107-3126
Inquiries: (800) 669-4000
Complaint Process Overview

Pennsylvania Human Relations Commission
333 Market Street, 8th Floor
Harrisburg, PA 17101
Inquiries: (717) 787-4410

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RCPA has been in communication with the American Medical Rehabilitation Providers Association (AMRPA), who has been working with the Centers for Medicare and Medicaid Services (CMS) to ensure inpatient rehabilitation facilities (IRFs) do not face inappropriate non-compliance penalties related to the IRF Patient Assessment Instrument (PAI) version 4.0 that is set to go into effect tomorrow (October 1, 2022). One particular concern is new items in version 4.0 do not include a “skip logic” to account for unplanned discharges that classify as incomplete stays. This oversight could lead to many IRFs not meeting the 95 percent data completion threshold for the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP).

Yesterday, CMS released a statement on the issue along with a Question & Answer (Q&A) document. CMS also noted that the agency will determine if a permanent fix is necessary and will release any related guidance or data specifications in the coming weeks.

Image by Gino Crescoli from Pixabay

A reminder to providers who received Provider Relief Fund (PRF) payments during the period January 1, 2021, to June 30, 2021. You must use the PRF Reporting Portal to document the use of these funds by this Friday, September 30, 2022.

According to the HRSA website, “Recipients who do not report within the respective reporting time period will be considered out of compliance with payment Terms and Conditions, and funds may be subject to recoupment.”

If you have any questions, please contact your RCPA Policy Director.

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The Inpatient Rehabilitation Facility (IRF) Provider Preview Reports have been updated and are now available. These reports contain provider performance scores for quality measures, which will be published on Care Compare and the Provider Data Catalog during the Care Compare refresh in December 2022. For additional information, please visit the CMS IRF Quality Reporting Program (QRP) Public Reporting website. The deadline to review the information is October 17, 2022.

RCPA staff and the Conference Committee are gearing up for our long-awaited in-person conference to be held in Hershey, PA, October 11 – 14, 2022! We would like to highlight our current line-up of exhibitors, who will be showcasing their products in our Beacon Health Options Connections Hall October 12 – 13. Attendees will be able to connect with exhibitors face-to-face as well as through our mobile app and take part in a points-driven game to earn coveted prizes! Be sure to register here to attend the conference and participate in this exciting game! RCPA thanks our exhibitors for their support of our 2022 Conference!