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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.

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The Office of Developmental Programs (ODP) has shared ODPANN 24-073, which announces that the Department-approved Supports Broker recertification training is available for the first seven months of Fiscal Year (FY) 2024/25. The Office of Developmental Programs (ODP) requires that Support Service Professionals/Supports Brokers under the Consolidated, Person/Family Directed Support (P/FDS), and Community Living (CL) Waivers must successfully complete a Supports Broker Certification Program provided by ODP or its designee every three years following their initial certification. Please view the announcement for details.

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Photo by Markus Winkler on Unsplash

The Office of Developmental Programs (ODP) presented updates for residential providers on Performance-Based Contracting (PBC) this morning, July 29. The Deputy Secretary also reminded residential providers that ALL providers must submit a Residential Provider agreement to ODP by August 31, 2024. Those who have not yet submitted an agreement will be receiving a warning letter.

An overview of updates included revisions to proposed waiver submissions, an implementation plan, supporting documents, instructions for tier determination, and provider data submission. Additional information was also shared on the following:

  • Adjusted Timeline: Residential providers with a signed and submitted Agreement for Provision of Residential Services may choose when to submit data and documentation to determine the PBC tier. Providers may submit information between August 1–31, 2024, or between February 15–March 15, 2025.
  • Clarification on Staff Credentialing: ODP noted that the credentialing standard is the National Alliance for Direct Support Professionals (NADSP) for Primary and Select tiers and NADSP and/or the National Association for the Dually Diagnosed (NADD) for the Clinically Enhanced tier.
  • Reduction of Measures: Measure changes were highlighted in red on the presentation.
  • Pay for Performance and Use of ARPA Funds: ODP clarified that Pay for Performance is available for Select and Clinically Enhanced providers. Use of ARPA funds has been extended for the department through June 2026 and will be available for P4P.
  • Preparedness Tools and Scoring: ODP will be using a scoring document for provider’s submitted data, which has composite scoring ability. If a provider falls short, they will have the opportunity to prove they met the measure.

View the full presentation here.

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The Office of Developmental Programs (ODP) shared ODPANN 24-072. This communication is to inform all interested parties of the submission of a proposed amendment to the Adult Autism Waiver (AAW) to the Centers for Medicare & Medicaid Services (CMS). The amendment includes all proposed changes as well as clarifications to the proposed new American Sign Language-English Interpreter service. The clarifications were added as a result of public comment.

Please view the announcement for details.

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ODP Announcement 24-071 informs stakeholders of the submission of the Performance-Based Contracting (PBC) 1915(b)4 Waiver and 1915(c) Waiver amendments to the Centers for Medicare and Medicaid Services (CMS). The Office of Developmental Programs (ODP) has included with this announcement multiple documents and resources that are essential for understanding and implementing PBC. The documents are:

Submitted amendments for Consolidated and Community Living 1915(c) and 1915(b)(4) Selective Contracting Waiver for Residential Services are available online. All significant changes resulting from public comments can be found in the PBC Implementation Guide under Appendix A, titled, “Significant Changes to Performance-Based Contracting Proposal as a Result of Public Comment April 20-June 4, 2024.”

As a reminder, all residential providers must sign and return the Residential Provider Agreement to ODP by July 31, 2024. Please direct any questions about this information to ODP electronically.

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ODP Bulletin 00-24-01 Performance-Based Standards for Residential Services has been published, providing detailed information regarding the standards that will be utilized to evaluate performance of residential providers in PA. An expected timeline for implementation of residential performance standards and tier assignment and the evaluation standards that will be used to assign tiers to providers have also been published.

ODP submitted waiver amendments for the 1915(c) waiver and the new 1915 (b)(4) waiver to the Centers for Medicare & Medicaid Services (CMS) on July 26, 2024. RCPA anticipates the fee schedule rates will be published in the PA Bulletin on August 31, 2024. Implementation of the new rates will happen October 1, 2024, with an effective date of July 1, 2024.

All non-residential services, including participant directed services, will receive an 8% increase. All residential services will receive a 6% increase. Implementation of PBC will include rate add-ons of:

  • Select Providers: 3%
  • Clinically Enhanced Providers: 5%

Pay for Performance will also be available.

ODP will hold a webinar on Monday, July 29, to provide an overview of these changes. You can register for the meeting here. Please direct any questions about this information to ODP electronically.

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RCPA was honored to have Stacy DiStephano of Consulting for Human Services, LLC and Ross Harper of Limbic AI join us for a discussion regarding the use of clinical AI in behavioral health care. The recording is now available on RCPA’s website; you will need to log in to your RCPA member account to access. If you have any questions regarding the content or recording, please contact Carol Ferenz. You can find more information below on the speakers and their respective organizations.

Speaker Bios:

Stacy DiStefano, Founder and CEO of Consulting for Human Services, LLC, is a passionate and dynamic healthcare and human services executive advisor, strategist, and retained leader. She has worked on high level strategic initiatives for behavioral health provider organizations, private equity firms, state departments, and tech vendors. Stacy is a visionary with a clinical background, enabling growth and mission achievement. She also works as a trusted advisor who easily builds rapport and works in collaboration with key stakeholders. A resilient and creative problem-solver with an eye on efficiency and a track record of improving financial performance, Stacy always strives to solve complex challenges.

Ross Harper, PhD, CEO of Limbic AI, is a distinguished computational neuroscientist with a rich academic background. Holding a PhD in Computational Neuroscience and a Master’s in Mathematical Modeling from University College London as well as a Master’s in Natural Sciences from the University of Cambridge, Ross possesses an intricate understanding of the overlap between mathematics, technology, and the human mind. He launched Limbic AI in 2020 to enable large language models and generative AI to aid and assist processes in the mental health space, supporting clinicians and their patients within the NHS during the pandemic. Used by over 230,000 patients and mental health professionals within the NHS, Ross is leading a company that is improving patient access to mental health resources, speeding up diagnosis, and supporting mental health professionals to avoid burnout as the company prepares to expand into the US.

Limbic AI:

Limbic is a clinically-validated AI copilot to drive quality and efficiency in behavioral healthcare, drastically improving service operating margins while demonstrably improving patient outcomes. Limbic has been proven at scale in the UK, currently working with 40% of the National Health Service, which now implements Limbic as part of routine care (used by 320,000 patients already). In 2024, Limbic has published 3 large-scale clinical studies, showing improved patient outcomes, lower cost-per-recovery, expanded provider capacity, enhanced access for underserved communities, reduced patient wait times, and elevated satisfaction for patients and clinicians (Nature Medicine, JMIR, British Medical Journal). The company is now working with community health providers in the United States to deliver economic and clinical ROI.

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