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Policy Areas

Again this year the Pennsylvania Youth Suicide Prevention Initiative (PAYSPI) and its partners will be hosting Suicide Prevention Nights at the Ballparks this year. These are the events where the students selected as the winners of the state’s youth suicide poster and public service announcement contest are publicly recognized for their work. The Philadelphia Phillies, Pittsburgh Pirates, and Harrisburg Senators have offered discount pricing, with a portion of the ticket sales through the PAYSPI links going toward suicide prevention in Pennsylvania. The Suicide Prevention Night In Philadelphia will be on April 22 (Phillies vs Atlanta Braves). For tickets at a special discount rate, with a contribution going to suicide prevention, visit this web page.

Look for information on similar events in both Pittsburgh and Harrisburg as information becomes available. In years past, provider organizations, managed care organizations, advocacy groups, and community businesses have made Suicide Prevention Nights at the Ballpark group outings for staff, consumers, and families.

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On January 12, 2017, the Centers for Medicare and Medicaid Services (CMS) published in the Federal Register a proposed rule on requirements for qualified practitioners/suppliers for prosthetics and orthotics that interprets Section 427 of the Benefits Improvement and Protection Act (BIPA) of 2000. Some of the provisions included in this proposed rule include:

  • Qualifications required for practitioners to furnish and fabricate, and qualified suppliers to fabricate prosthetics and custom-fabricated orthotics;
  • The accreditation requirement that qualified suppliers must meet in order to bill for prosthetics and custom-fabricated orthotics;
  • The timeframe in which qualified practitioners and qualified suppliers must meet applicable licensure, certification, and accreditation requirements;
  • The requirements that an organization must meet in order to accredit qualified suppliers to bill for prosthetics and custom-fabricated orthotics;
  • Removal of the current exemption from accreditation and quality standards for certain practitioners and suppliers; and
  • The sanction for submitted claims for payment of custom-fabricated orthotics or prosthetics without the required qualifications.

Essentially, the proposed rule would require physical therapists and occupational therapists to meet the Durable Medical Equipment, Prosthetics/Orthotics, and Supplies (DMEPOS) quality and accreditations when they furnish and fabricate prosthetics or custom orthotics under the Medicare program. Additionally, therapists who furnish and fabricate custom orthoses must be licensed by the state (as a qualified provider of prosthetics and custom orthotics), or certified by the American Board for Certification in Orthotics and Prosthetics or by the Board for Orthotists/Prosthetists Certification.

Comments on this proposed rule are due by Monday, March 13, 2017.

The American Society of Hand Therapists (ASHT) has developed a detailed summary of this proposed rule, as well as a sample letter that members can reference to pull relevant facts when developing comment letters in response to this proposed rule.

On February 23, 2017, the Pennsylvania Department of Health (DOH) released guidance to Home Care Agencies and Registries in follow-up to a policy clarification issued on November 23, 2016 regarding Direct Care Workers Non-Skilled Services in Home and Community-Based Services Settings.

The guidance includes a tool for organizations to use to comply with the Department of Health’s Home Care Agency and Registry regulations. The tool describes the consumer characteristics of individuals who can receive non-skilled activities/services, defined as Specialized Care. In addition, it describes the Home Care Agency/Registry responsibility for training and documentation of the direct care worker’s competency prior to delivering the Specialized Care. The guidance also establishes guidelines for the inclusion of Specialized Care into an individual’s care or service plan. RCPA’s policy statement in support of this clarification and guidance for expanded service options is available here.

The American Academy of Pediatrics (AAP) has issued updated screening and assessment recommendations for children’s preventive health care. The AAP also continued to emphasize the need for “unfragmented continuity of care” in comprehensive health supervision. Published online in Pediatrics, the 2017 policy statement contains changes to 11 areas of care, relative to the 2016 revision of the Bright Futures Periodicity Schedule, which cover care from birth to age 21. The recommendations note that “developmental, psychosocial, and chronic disease issues for children and adolescents may require frequent counseling and treatment visits separate from preventive care visits,” they caution, adding that unusual family circumstances may necessitate additional visits.

Changes include such care areas as:

  • Depression: Screening for adolescents should begin at age 12 years. In addition, physicians should ask about maternal depression at infants’ 1-, 2-, 4-, and 6-month medical visits.
  • Psychosocial-behavioral: The update underscores that assessment should be family-centered and, in addition to a child’s social and emotional health, may include evaluation of caregivers and social determinants of health.

Department of Human Services (DHS) Secretary Ted Dallas spoke at the RCPA Board of Directors meeting on February 22 regarding Governor Wolf’s proposal to consolidate four state health and human service agencies. If approved by the legislature, the plan would be launched on July 1, 2017.

Although the Secretary referenced approximately $90 million in savings from this process, he also affirmed that this “cannot be just about saving money.” Dallas remarked that time spent dealing with the bureaucracies as currently constructed takes time away from providing services, and so the goal is to eliminate redundancies.

RCPA members brought up key topics such as population health, licensing, and services for persons with co-existing conditions. When asked how this consolidation will affect addressing the opioid crisis, Secretary Dallas responded that the focus would be shifted to treating the whole person, rather than each individual condition.

The meeting concluded with the Secretary requesting ideas for continued efficiencies and how to ultimately better serve members. On the day of the Governor’s announcement, RCPA issued a statement expressing support for the proposal and committing to working with the administration to implement the plan in a smart and cost-effective manner.

The next OMHSAS Mental Health Planning Council (MHPC) is taking place on Thursday, March 2, 2017, from 10:00 am – 3:00 pm at the Child Welfare Resource Center (403 East Winding Hill Road, Mechanicsburg). The joint session will run from 10:00 am – 12:00 pm. The individual committees (Children’s, Adult, and Older Adult) will meet separately from 12:00 pm – 3:00 pm. A map and directions are available for your convenience.

The agenda and PowerPoint for the joint session are available as well, in addition to the agendas for the individual committee meetings, as well as the outcomes from the December 1, 2016 MHPC meetings, listed below:

Outcomes:

Agendas:

This meeting is open to the public. There is no need to RSVP; feel free to bring anyone you think would be interested in attending. Please contact Cristal Leeper with any questions.

The Centers for Medicare and Medicaid Services (CMS) published a final rule; delay of effective date notice in the February 17, 2017 Federal Register that delays the effective date of the rule, “Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement (CJR) model.” This notice clarifies that, in accordance with the White House’s regulatory freeze, provisions of CMS’ bundled payment final rule that were to become effective on February 18, 2017, are now delayed until March 21, 2017.

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The Centers for Medicare and Medicaid Services (CMS) recently announced that due to system issues, the February submission deadline for the inpatient rehabilitation facility (IRF) quality reporting program (QRP) data submitted via the Centers for Disease Control and Prevention (CDC) National Health and Safety Network (NHSN) has been extended to May 15, 2017.

The deadline has been extended for the following IRF quality reporting programs, measures, and reporting programs:

May 15, 2017 IRF QRP for Quarter 3 2016

  • CDC NHSN Healthcare-Associated Infection (HAI) Measures for quarter 3 2016
    • Catheter-associated Urinary Tract Infection (CAUTI)
    • Methicillin-resistant Staphylococcus aureus (MRSA)
    • Clostridium difficile Infection (CDI)

CMS is granting this extension to provide facilities additional time to submit quality reporting data and run applicable reports to ensure accurate submission. For further assistance regarding the IRF & long-term care hospitals (LTCH) quality reporting programs and policy information, visit the IRF Quality Reporting Data Submission Deadlines web page.

On February 8, the Department of Human Services (DHS) Secretary Ted Dallas announced the availability of onboarding grant funds to help connect hospitals and ambulatory practices to the Authority’s Pennsylvania Patient & Provider Network, or P3N.

The P3N enables electronic health information exchange (eHIE) across the state through the connection of health care providers to health information organizations (HIO), and the participation of the HIOs in the P3N.

“These grants will assist providers in the efficient delivery of quality services to the individuals we serve across the commonwealth,” said DHS Secretary Ted Dallas. “As more providers participate, individuals will experience better coordination of care and a better quality of health care.”

The grant program, available to Pennsylvania HIOs to enable the connection of inpatient hospital/facilities and outpatient practice or other outpatient provider organizations participating in the Medicaid Electronic Health Records (EHR) Incentive Program, includes:

  • Up to $75,000 to connect each eligible inpatient hospital or other inpatient facility to an HIO;
  • Up to $35,000 to connect each eligible outpatient practice or other outpatient provider organization to an HIO; and
  • Up to $5,000 to enable other eligible providers that do not fit into the two categories above, but want to enable HIE participation and connect to an HIO via a portal.

Each eligible provider will connect via an HIO to the P3N.

Only a single award is permitted to any one hospital/facility or outpatient practice. The anticipated performance period for this grant runs through September 30, 2017.

The grant will:

  • Help providers deliver higher quality and more efficient care, particularly through better care coordination for patients covered by Medicaid;
  • Support provider participation in private-sector HIOs by offsetting connection costs;
  • Incentivize HIOs to join the P3N, a precondition for receiving funding;
  • Support rapid movement toward the participation in eHIE, and support various care reform efforts currently underway across the Commonwealth; and
  • Defray up-front costs for individual providers to join an HIO, thus helping to achieve meaningful use and satisfy obligations under the Medicaid EHR Incentive Program.

This program will be made possible through an $8.125 million grant from the federal Centers of Medicare & Medicaid Services (CMS). Under the terms of the federal grant, CMS will provide 90 percent of the onboarding grant, with the remaining 10 percent funded by the Commonwealth. The grant applications and supporting materials are available online here.

(Information courtesy of DHS)

The Department of Human Services (DHS) has announced the recent changes to the OBRA Waiver that have been approved by the Centers for Medicare and Medicaid Services (CMS). Some of the waiver amendments include:

  • Adds five new employment-related service definitions that are replacing two existing employment service definitions. Five employment services have been added (benefits counseling, career assessment, employment skills development, job coaching, and job finding) (C-1/C-3).
  • Corrects the regulatory citation for an Outpatient or Community-Based Rehabilitation Agency provider type in the Occupational Therapy (OT), Physical Therapy (PT), Speech and Language Therapy (SLP) service definitions (C-1/C-3).
  • Clarifies that Personal Assistance Services (PAS) are only available to individuals in the waiver 21 years of age and over. All medically necessary Personal Assistance Services for children under age 21 are covered in the state plan pursuant to the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) benefit (C-1/C-3).

The complete service definitions and requirements are now included in an updated OBRA Waiver document. The effective date of these changes is February 1, 2017.

The OBRA Waiver PROPOSED rates for the new Employment Services have also been released. Questions regarding these rates should be directed to (717) 783-8412.