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Medical Rehab

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The Centers for Medicare and Medicaid Services (CMS) finalized the fiscal year (FY) 2026 inpatient rehabilitation facility (IRF) payment rule and published it in today’s Federal Register.

The final rule is a fairly straightforward payment and coverage rule, similar to the April 2025 proposed rule. The payment and IRF Quality Reporting Program (IRF QRP) updates are outlined below.

Payment: CMS expects an aggregate increase of $340 million in payments to IRFs across the PPS. This reflects an increase of approximately 2.6% in estimated payments, including all relevant adjustments.

Quality Reporting Program (QRP):

  • CMS finalized the removal of two quality measures: (1) the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, beginning with the FY 2026 IRF QRP, and (2) the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure, beginning with the FY 2028 IRF QRP. IRFs will continue to have the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure data collection item in the IRF-PAI until October 1, 2026, with CMS making the data collection voluntary and removing Q4 2025 data for this measure from the FY 2027 IRF QRP Compliance Determinations. CMS took similar action in other recently finalized payment rules. CMS also finalized their proposals to end the public display of these measures following the September 2025 Care Compare refresh.
  • CMS finalized the removal of four Standardized Patient Assessment Data Elements (SPADEs) under the Social Determinant of Health (SDOH) category with the FY 2028 IRF QRP, specifically: Living Situation (R0310), Food (R0320A and R0320B), and Utilities (R0330).
  • CMS finalized its procedural and review-focused changes to the IRF QRP reconsideration process. First, CMS will permit IRFs to request, and CMS to grant, an extension to file a request for reconsideration of a non-compliance determination if, during the 30-day period to request a reconsideration, the IRF was affected by an extraordinary circumstance beyond the control of the IRF (for example, a natural or man-made disaster). Second, CMS is finalizing its proposed updates to the bases on which CMS can grant a reconsideration request, providing that CMS will grant a timely request for reconsideration, and reverse an initial finding of non-compliance, only if CMS determines that the IRF was in full compliance with the IRF QRP requirements for the applicable program year.
  • CMS noted that it received extensive feedback on its Requests for Information (RFI) in four separate domains: (1) future measure concepts for the IRF QRP; (2) potential revisions to the IRF Patient Assessment Instrument (IRF-PAI); (3) potential revisions to the data submission deadlines for assessment data collected for the IRF QRP; and (4) advancing digital quality measurement in IRFs.

Requests for Information:
The rule included four dedicated Requests for Information (RFI) related to the IRF QRP and IRF-PAI. The final rule summarized the comments they received on these topics but did not offer any commentary on what CMS plans to do in future work in these areas.

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September 9 will be here before you know it — don’t miss your opportunity to register for the RCPA 2025 Conference Strive to Thrive and claim your early bird discount! By registering today, you guarantee your spot for over sixty workshops, live updates from both state and national partners, and inspiring keynote and plenary speakers. View our Registration Brochure for complete details of the conference schedule and speakers.

Early bird registration ends August 8, and hotel room discounts end August 11, so reserve your seat and hotel room today!

A limited number of exhibit booths and sponsorship opportunities remain! Contact Carol Ferenz, Conference Coordinator, ASAP for details if your organization is interested in sponsoring or exhibiting at our conference. All information is available in our Sponsor, Exhibit, and Advertise Brochure. The deadline for being recognized in conference materials and onsite displays is August 10, so be sure to complete your contract as soon as possible!

View our sponsors and exhibitors at our Conference website!

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The Pennsylvania Rural Health Association (PRHA) has released the 2025–2030 Pennsylvania Rural Health Plan, which is a comprehensive roadmap to improve the health and well-being of rural residents across the state.

The plan was developed with input from rural community leaders, health professionals, academic institutions, and policymakers to identify key priority and action steps to address the unique health challenges and opportunities in Pennsylvania’s 48 rural counties. Primary focuses include access to care, behavioral health, oral health, maternal health, workforce development, broadband connectivity, and health equity.

The 2025–2030 Pennsylvania Rural Health Plan can be found here.

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Included in the July 7, 2025, Pennsylvania Bulletin was a notice from the State Board of Physical Therapy (PT) regarding the final-form rulemaking that allows physical therapist students and physical therapist assistant (PTA) students to sit for requisite examinations up to 90 days prior to graduation from their respective programs. It also allows PTs and PTAs to receive a limited amount of continuing education credit for providing clinical instruction to student PTs and student PTAs at clinical facilities affiliated with accredited programs.

In addition, this final-form regulation allows applicants to directly register for the national examination with the examination provider by removing the requirement that the applicant first seek the Board’s permission, and it allows applicants to sit for a third or successive examination, after two failures, without first seeking the Board’s permission.

This final-form regulation became effective on July 7, 2025.

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On Tuesday, July 29, the Governor’s Office of the Budget provided an update on the status of the Fiscal Year (FY) 2025/26 state budget. The update outlines projected impacts across various departments within the Department of Human Services (DHS) over the next six weeks resulting from the ongoing budget impasse. Although the Governor, Senate, and House leadership have described ongoing negotiations as respectful, they have also been described as inching along. The letter from Secretary Monson cites funding for public schools and mass transit as top challenges in finalizing a budget.

Following is a summary of payments from Pennsylvania health and human services departments that will be delayed without a budget.

Department of Aging cannot distribute:

  • $12.88 million in payments to the Area Agencies on Aging, for July and August.

Department of Drug and Alcohol Programs cannot distribute:

  • $9.95 million quarterly payments to the Single County Authorities.
  • $187,000 quarterly payments for training of substance use disorder and problem gambling service professionals.
  • $21 million quarterly payments for State Opioid Response funding.

Department of Health cannot distribute:

  • $9.405 million in anticipated quarterly reimbursements to County Municipal Health Departments.
  • More than $4.7 million in quarterly funding to support operation and administration of EMS services.
  • $9.405 million in quarterly funding to school districts for health services.
  • More than $3.466 million in quarterly payments for the Prescription Drug Monitoring Program, beginning in July.
  • Payments for critical health services, including, but not limited to: Tuberculosis screening, Cystic Fibrosis, Lyme Disease and Cancer Screening, beginning in July.
  • More than $1 million in quarterly payments for Maternal and Child Health services and $1.8 million in quarterly for Newborn Screening.

Department of Human Services cannot distribute:

  • $15 million in quarterly advances for Behavioral Services, beginning in July.
  • Quarterly advances for Breast Cancer Screening services.
  • $390 million in County Child Welfare payments for July and August.
  • $8.5 million in payments for Domestic Violence for July and August.
  • $3.5 million in quarterly advances from the Human Services Development Fund.
  • An estimated $33 million in Child Support Enforcement payments, for July and August.
  • $3.4 million in payments for Rape Crisis for July and August.
  • Approximately $10 million for Community-Based Family Centers for July and August.
  • $5.6 million in quarterly advance payments for Homeless Assistance.

Read the letter from Secretary Monson here. If you have any questions, please contact your respective RCPA Policy Director.

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The Payroll Audit Independent Determination (PAID) program is back!

Originally launched in 2018, PAID is returning with new enhancements, resources, and tools. Plus, it has now been expanded to include the Family and Medical Leave Act (FMLA).

The program has several of the same objectives as before:

  • Resolve wage violations under the Fair Labor Standards Act (FLSA) and identified violations under the Family and Medical Leave Act (FMLA) quickly and without any litigation costs,
  • Improve employer compliance, and
  • Ensure employee back wages and FMLA remedies are paid to them – accurately and quickly.

In addition, FMLA violations can now be addressed through PAID so employers can correct errors made and employees can receive job-protected leave according to the law.

With this relaunch, DOL is encouraging proactive compliance through accessible, user-friendly resources, and web content.

DOL knows running a business is hard work. Balancing payroll, scheduling, and compliance can be a juggling act, and sometimes mistakes are made. If you’ve had errors lead to unpaid wages or FMLA leave issues, now is the chance to make it right.

For more information, visit the Division’s page on the PAID program.

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RCPA may be based in Pennsylvania, but our conference covers topics and features speakers from across the country! Register today, join us at the Hershey Lodge September 9 – 12, 2025, and reserve your room online while the room block is available. By registering, you gain the opportunity to engage with these provocative keynote speakers as they touch on topics that affect all facets of health and human services across the nation:

  • Karen Weeks, Founder of Shine at Work, will analyze how to create an organizational culture that supports people’s wellbeing;
  • Judge Victor Reyes, Retired Judge and Master Life Coach, will define mindfulness and evaluate its impact in leadership roles;
  • Michael Cohen, Duane Morris LLP, will provide insights on how to make one’s workplace open and accessible for as many as possible to prevent workplace harassment; 
  • Kory Shrum, Bestselling Author and Podcast Host, will deconstruct common self-care myths and provide a practical framework for sustainable self-care practices; and
  • Donna Martin, Vice President, State Partnerships & Innovation, ANCOR, and Mohini Venkatesh, Chief of Staff, Strategic Leadership, National Council for Mental Wellbeing, will dive into national trends in health and human services policies and workforce issues.

View our Registration Brochure for complete details of the conference schedule and speakers. Be sure to check the RCPA Conference website regularly for details and updates to the schedule, registration, and sponsors/exhibitors. Register today!

In addition to registration, there are still many opportunities available for sponsorship and exhibit booths, so don’t delay! We are grateful to all our sponsors and exhibitors who help make the conference happen. If your organization is interested in sponsoring or exhibiting at our conference, all information is available in our Sponsor, Exhibit, and Advertise Brochure. Contact Carol Ferenz, Conference Coordinator, for more details.

Thank you to our Sponsors and Exhibitors! We are grateful for your support!

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On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.

If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:

Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.

RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:

Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the ‎reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.

Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following ‎information:‎

  • A copy of the CMS non-compliance letter;
  • A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of ‎calendar year 2024; and
  • If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the ‎monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract ‎Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among ‎Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.

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The Bureau of Human Services Licensing (BHSL) has received a small number of reports of issues with faxing the updated Documentation of Medical Evaluation (DME) forms. These reports indicate that some fax machines cannot pick up the contrast in the grey shaded areas. You will find both DME forms with the grey areas lightened significantly. These forms are also being added to the BHSL website.

Please note, BHSL has fax-tested both versions of these forms and did not encounter any issues. Issues with faxing may be related to the age/condition or settings of individual fax machines. Online faxing services that do not require the use of a fax machine are widely available, as are alternative methods of form transmission, such as in-person drop off, email, online drop boxes, or the United States Postal Service.

Questions about this communication may be sent electronically.

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