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Policy Areas

The RCPA Board of Directors recently approved full membership for the association with the American Network of Community Options and Resources (ANCOR), which in turn will benefit all members of RCPA. ANCOR represents over 1,400 service providers and 52 state provider organizations who support more than one million Americans with intellectual and developmental disabilities through the Medicaid Program. ANCOR provides advocacy on a federal level and represents the workforce of community providers across the country who empower people with developmental disabilities including Down Syndrome, cerebral palsy, and autism, to live and work with dignity in their own communities.

Effective in January 2019, all RCPA members will be considered members of ANCOR, and will enjoy the benefits of their membership. There is no additional charge to our members for this; you will receive a welcome email and may choose to opt out or sign up for pertinent email lists.

ANCOR membership offers a multitude of benefits, including:

  • Up to date information regarding federal policy;
  • Opportunities to be involved in shaping public policy;
  • Access to the ANCOR Amplifier – an interactive website that enables members to easily and efficiently communicate with elected officials on important issues;
  • Collaboration with other providers through the use of a private, professional networking community, sharing information and advice with peers across the country;
  • National Advocacy Campaign working to advance the professionalism, recognition of, and improved wages for Direct Support Professionals;
  • Educational offerings including webinars;
  • Technical assistance including guidance on HIPAA, Wage and Hour, and other regulations, including (limited) free access to legal consultation with Gilliland, Maguire & Harper, PC;
  • Shared Resource Purchasing Network that also offers some benefits to employees of organizations; and
  • Publications including weekly updates, Capitol Correspondence, and bi-monthly newsletters.

For a full description of benefits now available to you as members:

RCPA will notify members once this agreement is in full effect. Please contact Carol Ferenz, RCPA IDD Division Director, with questions.

The Office of Developmental Programs issued ODP Communication Number 102-18 announcing delays in two areas that were scheduled to go into effect for ODP Waiver programs. Amendments to the Consolidated, P/FDS, and Community Living Waivers were recently approved by the Centers for Medicare and Medicaid Services (CMS) effective November 1, 2018. This communication is regarding the following two changes in the amendments that were scheduled to take effect on January 1, 2019:

  1. Transportation Trip was to transition from a cost-based rate to a fee schedule rate

Implementation of the changes to Transportation Trip will be delayed until July 1, 2019. This delay includes all of the following changes associated with transitioning Transportation Trip from a cost-based service to a fee schedule service:

  • Changes to the number of miles covered in each zone designation;
  • Expanding the service to be provided by relatives, legal guardians, and Organized Health Care Delivery Systems; and
  • Expanding the service to be self-directed through the Agency With Choice or Vendor  Fiscal/Employer Agent participant-directed services models.

These changes are not to be included in a person’s Individual Support Plan effective January 1, 2019. ODP has submitted an amendment to CMS to maintain the Transportation Trip service definition and cost-based rate methodology in its current approved state with no changes effective January 1, 2019.

  1. As part of qualification requirements, staff were to complete the Certified Employment Support Professional (CESP) credential, Basic Employment Services Certificate of Achievement or a Professional Certificate of Achievement in Employment Services certification for certain employment services and components of Community Participation Support.

ODP has received feedback that providers are struggling to have all required staff complete the Basic Employment Services Certificate of Achievement or Professional Certificate of Achievement in Employment Services prior to the pending January 1, 2019 deadline. As a result, the requirement for staff to have one of those qualifications will be delayed until July 1, 2019.

It is imperative that all impacted providers and common law employers that have staff who are required to have one of these employment credentials or certificates start the process now if they have not already done so. There will be no further delays granted in implementation of this qualification criteria.

ODP is drafting another set of amendments to the Consolidated, P/FDS, and Community Living Waivers that will be effective July 1, 2019. Both the changes to transition Transportation Trip to a fee schedule rate and the delay of the qualification criteria regarding employment credentials and certificates discussed in this communication will be included in those amendments with other proposed changes. ODP anticipates that the proposed amendments will be released for public comment in February or March of 2019.

All other changes contained in the waiver amendments effective November 1, 2018 remain effective and must be followed. The current approved waivers can be accessed here.

Contact RCPA IDD Division Director Carol Ferenz with questions.

In June of this year, the Office of Developmental Programs (ODP) established a new Special Populations Unit within the Bureau of Autism Services. This unit oversees the management of the Harry M. Settlement and supports efforts to build system-wide capacity to support individuals with communication challenges. A focus of the work will align with the Everyday Lives recommendation that emphasizes the need to build communication supports for the individuals assisted by ODP programs.

ODP has announced a kickoff series of training webinars presented by the Special Populations Unit in the month of December. These trainings will focus on specific topics related to communication. ODP Communication Number 101-18 includes a listing of the training topics, dates and times, and intended audience; this is the reissue of 101-18 which has the correct dates. To register, click on the linked title of each training you plan to attend. Once you pre-register, you will receive an email with instructions to participate, including a new link to join the meeting.

Questions about this ODP Communication should be directed to the ODP Deaf Services Mailbox.

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During the question and answer segment of the Centers for Medicare and Medicaid Services (CMS) National Provider call that focused on the inpatient rehabilitation facility (IRF) payment and coverage policies for the fiscal year 2019 final rule on November 15, 2018, there was a response from CMS on the role of therapy students in providing care to patients in IRF hospitals and units that caused a great deal of confusion. The question related to counting minutes of therapy provided by a therapy student with guidance. The response was that these minutes would not count, regardless of the level of supervision.

Due to the amount of confusion this call has triggered, the therapy professional associations will be working with CMS on this issue and clarification will likely be forthcoming. RCPA will provide this clarification to members once this is received. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

All Community HealthChoices (CHC) participants have access to emergency and non-emergency medical transportation.  Emergency medical transportation is provided by an ambulance in the event of a medical emergency. Non-emergency medical transportation can help participants travel to and from a medical facility, doctor’s office, hospital, clinic, pharmacy, or medical equipment vendors.

The attached fact sheet outlines transportation options and how transportation is billed and coordinated for CHC participants based on where the participant resides and the type of transportation needed.

CHC goes live January 1, 2019 in the Southeast. To learn more about CHC, take the 30 minute online training. If you have any questions, please visit www.HealthChoices.pa.gov or email [email protected].

A listserv has been established for ongoing updates on the CHC program. It is titled OLTL-COMMUNITY-HEALTHCHOICES, please visit the ListServ Archives page at http://listserv.dpw.state.pa.us to update or register your email address.

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The Implementation Report for the Community Mental Health Services Block Grant (CMHSBG) is submitted to the Substance Abuse and Mental Health Services Administration (SAMHSA) annually to report the outcomes of the grant. The report includes both financial reporting and updates on the priorities set forth in the CMHSBG Application. Changes to the priorities can only be made in the biannual application; the Implementation Report only tracks the progress of those priorities already set. The majority of the Implementation Report requires charts that are submitted separately through the National Research Institute and are not available for review at this time.

The OMHSAS Bureau of Policy, Planning, and Program Development submits the attached sections through the SAMHSA Grant site (WebBGas). Any comments or questions regarding the CMHSBG 2019 Implementation Report may be directed to Wendy Tucker or 717-705-8280.

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On Tuesday, November 27, 2018, the RAND Corporation (a contractor for the Centers for Medicare and Medicaid Services), will hold a stakeholder meeting to discuss their results from the Improving Medicare Post-Acute Care Transformation (IMPACT) Act national beta test of candidate standardized patient assessment data elements (SPADEs). They will also discuss areas of support and key concerns raised by stakeholders during prior engagement activities and answer questions from attendees.

The meeting will be held at the RAND offices, 1200 South Hayes St., Arlington, VA 22202-5050, from 12:00 pm to 4:00 pm.

Attendees can register to attend in person or by phone using the links below. The limited number of in-person spaces will be available on a first-come, first-served basis.

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

In order to promote improved coordination between Medicare and Medicaid as the rollout of Community HealthChoices (CHC) in the Southeast portion of the state gets closer, the Office of Long-Term Living (OLTL) released a CHC Medicaid/Medicare billing fact sheet. The fact sheet includes information and answers to frequently asked questions (FAQs) regarding coverage and how billing works under CHC.

Contact Melissa Dehoff with questions.

OLTL outlines the requirements for Electronic Visit Verification (EVV) roll out and the services impacted by it. EVV is required by Managed Care Organizations (MCOs) in the Community HealthChoices SW and SE roll out zones, effective January 1, 2019.

Electronic Visit Verification (EVV) Implementation Update:

The 21st Century Cures Act requires implementation of EVV for personal care services (PCS) and home health services.  For Office of Long-Term Living (OLTL) waivers, including agency and participant-directed services, PCS includes:

  • Personal Assistance Services
  • Respite (unlicensed settings only)

As shared previously, the Department of Human Services (Department) will utilize an open system for EVV.  This means that providers who already have an EVV system will be able to use their existing systems to submit information to the Department’s EVV vendor.  The Department is using the existing PROMISe™ fiscal agent contract with DXC for EVV.

Providers who do not have their own EVV system will be able to utilize the Department’s system for compliance. Providers participating in Community HealthChoices (CHC) can also reach out to the CHC-MCOs they are contracted with to discuss potential opportunities to meet compliance requirements with the CHC-MCO- contracted EVV system, HHAeXchange.

For participant-directed programs in the OLTL waivers, the vendor fiscal agent, Public Partnerships, LLC (PPL), will be utilizing their EVV system, Time4Care, to satisfy EVV requirements.

EVV Implementation Timeline Reminder:

The 21st Century Cures Act requires implementation of EVV by January 1, 2019 for personal care services (PCS).  On July 30, 2018, the President signed a law delaying penalties for implementation to January 1, 2020 for PCS.  The requirement for implementation of EVV for home health services by January 1, 2023 has not changed.

This delay will allow Pennsylvania an opportunity to extend implementation activities and training, to make sure that providers are fully ready for the implementation of EVV.  The tentative plan for Pennsylvania’s implementation of EVV is:

  • January 2019 – PA guidance will be distributed
  • Spring 2019 – provider training will be offered with phased-in system use
  • Summer 2019 – full implementation of system

Additional information will be shared when it becomes available.  You may also look for information on our website.

For further questions regarding EVV, please email [email protected].