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Policy Areas

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On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that announces and solicits public comments on proposed policy changes for Medicare payments under the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) and other Medicare Part B issues, effective on or after January 1, 2024.

The calendar year (CY) 2024 PFS proposed rule is one of several proposed rules that reflect a broader Administration-wide strategy to create a more equitable health care system that results in better access to care, quality, affordability, and innovation.

The proposed modifications include several pertaining to telehealth policy in the Medicare program for 2024. One of the major takeaways from the proposed 2024 PFS is the clarification that certain telehealth flexibilities that were previously extended until 151 days after the end of the public health emergency (PHE) have now been extended until December 31, 2024, in accordance with amendments made by the Consolidated Appropriations Act, 2023. These extensions have been known since the CAA’s passage in December last year and has also been addressed in a series of fact sheets and FAQ documents.

However, there were also some new changes addressed in the 2024 PFS. For example, every year CMS will consider adding new services to their list of codes that are reimbursable via telehealth. While they did not decide to add any new codes on a permanent basis to the list (though many remain on the list temporarily through the end of 2024), they did propose to add a number of codes to Category 3 (CMS’ current temporary list), including certain codes for health and well-being coaching services. Additionally, CMS announced a proposed revision to their telehealth code classification process, moving from a Category 1, 2 and 3 classification system to a binary ‘permanent’ or ‘provisional’ classification in an attempt to simplify the process beginning in CY 2025. In order to make the steps for getting a code accepted for inclusion in either the permanent or provisional telehealth lists transparent, CMS proposes a five-step process that is detailed in the proposed 2024 PFS, which includes consideration of the evidence of clinical benefits.

A few additional changes proposed in the document are listed below:

  • The list of telehealth practitioners is amended to recognize marriage and family therapists and mental health counselors as telehealth practitioners, effective Jan. 1, 2024.
  • CMS will pay for place of service (POS) 10 at the non-facility PFS rate, while 02 will be paid at the facility rate beginning Jan. 1, 2024.
  • Frequency limitation would be removed for subsequent inpatient visits through the duration of CY 2024.
  • Multiple clarifications are provided for billing both remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) codes.
  • Direct supervision is allowed to include real-time audio video interactive telecommunication through Dec. 31, 2024 (including for FQHCs and RHCs). Direct supervision requirements are also addressed for occupational therapists in private practice (OTPP) and physical therapists in private practice (PTPP) for unenrolled physical and occupational therapists when providing remote RTM.

CMS will be accepting comments on their proposals until 5:00 pm EST on September 11, 2023, and RCPA will review the document and work with the National Council for Mental Wellbeing in drafting recommendations. We welcome provider feedback and comments to be included and ask that you contact and share these with your RCPA Policy Director.

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The Office of Developmental Programs (ODP) has shared ODPANN 23-067: Fiscal Year (FY) 2023-2024 Supports Broker Recertification Training. The purpose of this communication is to announce that Department-approved Supports Broker recertification training is available for the first seven months of Fiscal Year 2023/24. Please review the announcement for the available dates, and note that registration information will be forthcoming.

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The Centers for Medicare and Medicaid Services (CMS) released a revised Medicare Learning Network (MLN) fact sheet on telehealth services. A number of changes have been made due to the end of the public health emergency (PHE), including the following items:

  • Information on the end of the COVID-19 public health emergency as well as CY 2023 and telehealth policies.
  • Status of Ongoing Flexibilities:
    • Through December 31, 2024, all patients can get telehealth wherever they are located. They do not need to be at an originating site, and there are no geographic restrictions.
    • Through December 31, 2024, all providers who are eligible to bill Medicare for professional services can provide distant site telehealth.
    • For behavioral or mental health telehealth, you may use 2-way, interactive, audio-only technology. This is also part of the PA Telehealth Statute under Act 98.
  • Additional Resources Provided:
    • Chapter 12, Section 190 of the Medicare Claims Processing Manual
    • Telehealth Policy Changes After the COVID-19 PHE
    • Tips for Telehealth Success
  • Added information on:
    • New G-codes. Starting January 1, 2023, you may voluntarily report the use of telehealth technology in providing home health (HH) services on HH payment claims. See MLN Matters Article MM12805 for more information.
    • Consent for care management and virtual communication services.

Providers are encouraged to review this document closely and bookmark it for future reference.

As RCPA continues its efforts to expand access via telehealth in Pennsylvania, we will be submitting comments on the new Calendar Year (CY) 2024 Physician Fee Schedule (PFS). RCPA will be sending out a communication on this in the coming days.

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The Centers for Medicare and Medicaid Services (CMS) has released a number of additional and updated documents related to the inpatient rehabilitation facility (IRF) review choice demonstration (RCD). Included in these documents are:

  • An updated and revised Operational Guide — Clarifies key programmatic details regarding the different review choices and other facets of the demonstration.
  • Frequently Asked Questions Document — The FAQ focuses on major areas of confusion on the choice selection and submission processes, the Pre-Claim Review Track, and medical necessity determinations.
  • Transcript and Recording — From the June 27, 2023, special open-door forum on the IRF RCD.

Additional information about the IRF RCD can be found on the CMS IRF RCD web page.

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This year, Direct Support Professional Recognition Week is September 10–16, and ANCOR has all you need to plan your thank-yous and celebrations!

One of the most popular ways to customize celebrations is by browsing and purchasing from the 2023 Direct Support Professional Recognition Week Store!

ANCOR has updated the DSP Recognition Week Store with NEW items, they’re bringing back some of their most popular items, and more items will be added throughout this week!

In addition to everything below, there are even more bag options, water bottles, travel mugs and tumblers, notebooks, coolers, and more. Start browsing today!

Make sure to place your orders by August 20 to ensure receipt by the start of DSP Recognition Week.

DSP Recognition Week is one of our favorite times of year, and we can’t wait to celebrate with you and see all of your celebrations! Thank you, DSPs!

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Join us at the 2023 RCPA Annual Conference A Decade of Unity for the latest in strategies and innovations within the health and human services sector. Held at the Hershey Lodge October 10 – 13, participants can earn CEs through workshops that will cover a wide variety of topics. Our full brochure is available, and we’ll be rounding out our first day at the lodge with:

  • Driving Pennsylvania’s Health Care Transformation: Integrating Perspectives for Advanced Patient-Centered Care
    • Discuss strategies and methods of health care system integration, including designing a roadmap for practical applications.
  • Purpose and Growth: Engaging and Retaining Your Teams in Challenging Times
    • Learn to retain employees in the face of generational gaps, the effects of the pandemic, and the economy by focusing on what they most want: purpose and growth.
  • Why Your Agency Needs A Specialized Telehealth Solution: Improving Health, Provider Cost Saving, Increased Satisfaction
    • Hear about StationMD and Mainstay Life Services’ telehealth partnership and how having a specialized telehealth solution can improve outcomes while lowering costs.
  • Data Strategies for Impact and System Transformation
    • Do more with your data by learning the stages of organizational development for data-informed decision-making.
  • Value-Based Purchasing: A Survival Guide
    • Review value-based purchasing and how it is a tool to be used to improve quality health care. This discussion will include best practices for utilizing data in real time.
  • Current Steps in Implementing Trauma-informed Care in Children’s MH RTFs
    • Learn about OMHSAS’s TIC Initiative for children’s mental health residential treatment facilities, which serves as part of PA’s commitment to becoming a trauma-informed state.
  • Individual Operations: Owning Your Own Influence
    • Understand what it means to be a leader and implement strategies that will strengthen your team, including utilizing and recognizing scheduling patterns, planning ahead, and knowing when to set and break boundaries.
  • Condition Support: Addressing Escalated Situations in the Health Care Setting
    • Analyze an overview of UPMC’s Conditional Support Process, which addresses patients or visitors who exhibit aggressive or hostile behaviors in order to protect medical professionals.
Register today!

In addition to an impressive roster of speakers, our 2023 Conference will have an exciting array of sponsors and exhibitors. We thank those who have signed on thus far! If you are interested in sponsoring or exhibiting, visit here for more details or contact Carol Ferenz, Conference Coordinator, with any questions you may have. Keep up-to-date and register today for #rcpaconf!

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The Department of Human Services (DHS) recognizes that the corrective action process is a cornerstone of human services licensing. In 2019, the Department released a webinar, Developing a Plan of Correction, to assist providers with the successful development and implementation of acceptable Plans of Correction. Likewise, the Plan of Correction Quick Reference Guide was issued as a tool to assist our providers with this process.

The Department is seeking your feedback on these resources. Please complete this survey by July 26, 2023, in order to assist DHS in determining what additional steps are needed to ensure that our providers are sufficiently educated and supported in the Plan of Correction process.

If you have further questions, please contact your respective RCPA Policy Director for guidance.

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Image by photosforyou from Pixabay

Life Unites Us is hosting a webinar at 12:00 pm on Tuesday, July 25, titled “Uniting Provider Communities: Improving Access to Behavioral Health and Substance Use Disorder Services for Older Pennsylvanians.” The webinar will cover Pennsylvania aging programs and services, the integration of behavioral health and addiction services, their delivery methods, and available resources within the aging network. Registration is available.

Life Unites Us is a collaboration between the Pennsylvania Department of Drug and Alcohol Programs, the Douglas W. Pollock Center for Addiction Outreach and Research at Penn State Harrisburg, and the nonprofits Shatterproof and The Public Good Projects. It aims to end stigma and improve access to addiction treatment and recovery by bringing together organizations fighting the opioid epidemic.

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Photo by Markus Winkler from Pexels

FOR IMMEDIATE RELEASE

Step By Step, Inc. Acquires 10 Residential Programs Formerly Operated by Goodwill Industries of NEPA, Expanding Services for Individuals with Disabilities

Wilkes-Barre, PA– Step By Step, Inc., a leading provider of services for individuals with intellectual and developmental disabilities, is pleased to announce the successful acquisition of 10 Residential Programs formerly operated by Goodwill Industries of NEPA. This acquisition includes 10 residential properties, enabling Step By Step to serve 35 individuals in Luzerne and Lackawanna counties. The completion of this acquisition represents a significant milestone in Step By Step’s growth and reinforces their dedication to fostering independence and opportunity for their clients.

Eric Lindey (CEO/President of Step By Step) expressed his excitement about the acquisition, stating, “We are honored to have the opportunity to serve and support these individuals and their families. This acquisition aligns perfectly with our mission of helping each individual succeed in life. We are dedicated to maintaining the continuity and quality of care that Goodwill has provided, ensuring a seamless transition for everyone involved.”During the acquisition process, Step By Step prioritized minimizing disruptions for the individuals and their families. The agency successfully preserved their homes, furnishings, and retained the trusted and familiar staff. The focus is to create a nurturing environment where these individuals can continue to thrive and lead fulfilling lives.

“We are deeply committed to upholding the highest standards of care and ensuring that every individual receives the support they need to reach their full potential,” added Eric Lindey. “We are excited about the growth opportunities this acquisition brings for Step By Step, as we continue to make a positive impact in the lives of those we serve.”

The acquisition was finalized on June 30, 2023, and as of July 1, 2023, Step By Step officially assumed the role of service provider for the acquired residential programs. Step By Step would like to express gratitude to the staff, board of directors, and executive team for their dedication and hard work throughout the process.

About Step By Step:
Step By Step, Inc. is a private, non-profit corporation devoted to providing community support services to children and adults in Pennsylvania with intellectual disabilities, physical disabilities, autism, mental health disorders, and/ or substance use disorders.

Established in 1977, the agency today provides services to over 2,000 individuals in four regions across more than a dozen Pennsylvania counties.  Throughout its history, Step By Step, Inc. has maintained a progressive view of the potential of individuals with disabilities.

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