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CMS

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Image by Dirk Wouters from Pixabay

In today’s Federal Register, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that included updates to the Medicare Advantage program. Contained within this proposed rule is a Request for Information (RFI): Prior Authorization for Hospital Transfers to Post-Acute Care (PAC) Settings During a Public Health Emergency (PHE). The RFI highlights several concerns, including the fact that providers often wait up to three days for authorization determinations, and that a high rate of MA requests are initially denied, all of which hinder the ability of hospitals to maximize capacity during a public health emergency (PHE). The RFI requests several areas for feedback, including the overall impact of prior authorization on hospitals and patient care, the denial rates and associated burden on providers, and the consequences of delayed patient transfers.

Members are encouraged to share any direct examples of these prior authorization issues with Melissa Dehoff, Director, Rehabilitation Services Division. In addition, this issue will be discussed during the upcoming Outpatient Rehabilitation Committee and Medical Rehabilitation Committee meetings.

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The Centers for Medicare and Medicaid Services (CMS) has released guidance on the Omnibus COVID-19 health care staff vaccination interim final rule that was published on November 5, 2021. The emergency regulation helps safeguard health care workers and the people they serve from COVID-19 and its variants for all individuals seeking care. This is done by imposing requirements regarding vaccinations for eligible staff at health care facilities participating in the Medicare and Medicaid programs.

This guidance provides important information on implementation as well as guidelines to assess and maintain compliance with the COVID-19 vaccination requirements for health care workers at facilities participating in the Medicare and Medicaid programs.

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The Office of Long-Term Living (OLTL) has outlined its plan to the Centers for Medicare and Medicaid Services (CMS) to strengthen the workforce and assist Adult Day Services (ADS) providers. This plan is in response to the American Rescue Plan Act of 2021 (ARPA), which provides a temporary 10 percent increase to the federal medical assistance percentage (FMAP) for certain Medicaid expenditures for home and community-based services (HCBS). The funding must be used to enhance, expand, or strengthen HCBS.

The OLTL ARPA plan directs $46.5 million to Personal Assistance Service (PAS), Community Integration (CI), and Residential Habilitation (Res Hab) providers to assist with recruitment and retention of direct care workers. The plan directs an additional $13 million to ADS providers to strengthen ADS. To qualify for these payments, providers must have been in operation as of November 1, 2021.

OLTL sent letters to providers with details about the payments, including information about the approved use of and reporting on these funds. For reference, samples of the letters, a list of qualifying entities and payment amounts, and a blank copy of the Provider Attestation Form are available on the DHS Long-Term Care Providers page under the heading “American Rescue Plan Act (ARPA) Funding.”

To receive a Strengthening the Workforce or Adult Day Services payment, providers must complete the OLTL Provider Attestation form and return via email or fax it to the OLTL Bureau of Finance at (717) 787-2145.  Providers who return completed forms by January 7, 2022, will receive payment in February 2022.

Strengthening the Workforce Payments

  • The total available for a one-time payment to PAS, Res Hab, and CI providers is $46,500,000. Of that, $44 million is allocated to PAS and CI, and $2.5 million is allocated to Res Hab. Amounts allocated to providers in each category were based on fee-for-service claims and managed care encounters for services provided between July 1, 2020, and March 30, 2021.
  • To calculate each PAS and CI provider’s Strengthening the Workforce payment, OLTL first divided the $44 million allocation by the total number of fee-for-service and managed care PAS and CI units billed between July 1, 2020, and March 30, 2021, to determine a per unit amount. Each provider’s payment was then calculated by multiplying the per unit amount by the provider’s number of fee-for-service and managed care PAS and CI units billed during the same period.
  • To calculate each Res Hab provider’s Strengthening the Workforce payment, OLTL first divided the $2.5 million allocation by the total number of fee-for-service and managed care Res Hab units billed between July 1, 2020, and March 30, 2021, to determine a per unit amount. Each provider’s payment was then calculated by multiplying the per unit amount by the provider’s number of fee-for-service and managed care Res Hab units billed during the same period.

Strengthening ADS Payments

  • The total funds available for a one-time payment to ADS providers is $13 million. Amounts allocated to ADS providers were based on fee-for-service claims and managed care encounters for services provided between January 1, 2019, and December 31, 2019.
  • To calculate each ADS provider’s Strengthening Adult Day Services payment, OLTL first divided the $13 million allocation by the total number of fee-for-service and managed care ADS units billed between January 1, 2019, and December 31, 2019, to determine a per unit amount. Each provider’s payment was then calculated by multiplying the per unit amount by the provider’s number of fee-for-service and managed care ADS units billed during the same period.

Acceptable Uses of ARPA Funding

ARPA funding must be used for things such as sign on bonuses, retention payments, COVID-19 related leave benefits and paid time off, vaccination incentives, or the purchase of personal protective equipment and testing supplies. Additionally, ADS providers can use the funding for retrofitting adult day centers, expenses to re-open the centers, and expenses to develop alternative models to provide ADS.

Questions about this information should be directed to the OLTL Provider Helpline at 800-932-0939.

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Message from the Department of Human Services (DHS):

FOR IMMEDIATE RELEASE
December 20, 2021 

Department of Human Services Discusses Spending Plan for Home and Community-Based Services Enhanced Federal Funding to Support Mental Health Services, Children 

Harrisburg, PA — Pennsylvania Department of Human Services (DHS) today highlighted Pennsylvania’s spending plan for approximately $1.2 billion in enhanced federal Medicaid funding made available to states through the American Rescue Plan Act (ARPA). This funding will support Medicaid’s home and community-based services (HCBS) system throughout the commonwealth, which helps seniors, people with disabilities, children with complex medical needs, and many other groups safely live in their community among their family and peers. This funding will strengthen Pennsylvania’s home and community-based services system by allowing more Pennsylvanians access to critical services in their communities and supporting service providers that perform this work every day.

“We owe a huge debt of gratitude to the professionals who care for our most vulnerable, including children, seniors, people with disabilities, and those needing mental health services,” said Acting Secretary Meg Snead. “This enhanced funding through the American Rescue Plan Act will allow employers to recruit and retain skilled workers and allows them to plan for the future to provide training, certification, technology access, and much more.”

DHS received conditional approval of its spending plan on December 1 from the Centers for Medicare & Medicaid Services. On today’s call, DHS outlined how funding will be used through the Office of Mental Health and Substance Abuse Services (OMHSAS), the Office of Child Development and Early Learning (OCDEL), and the Office of Medical Assistance Programs (OMAP).

  • OMHSAS will prioritize funding for workforce recruitment and retention to qualifying providers, specifically mobile crisis mental health services, intensive behavioral health services (IBHS), psychiatric rehabilitation, and family-based mental health services. While many mental health services are not considered HCBS under ARPA, within the parameters of this funding opportunity, OMHSAS also will invest in training clinicians in trauma-informed treatment modalities, technology and training for telehealth, and updating the state hospital system’s technology infrastructure and providing staff training for use of electronic health records to facilitate more efficient transitions to community-based placements and services.
  • OCDEL supported a 3 percent rate increase for Infant/Toddler Early Intervention services, which allows all providers of Early Intervention services, including Service Coordination, to receive a 3 percent rate increase for services. This rate increase went into effect on July 1, 2021.
  • OMAP will use the recommendations of its pediatric shift care nursing work group to inform ARPA spending with a focus on achieving the following goals: improve care and service coordination for children with complex medical needs; support training of private duty nurses; leverage health information technology to allow for the sharing of clinical information; use a value-based payment structure for managed care organizations to improve outcomes of children receiving pediatric shift care nursing services; and facilitate co-training opportunities for both shift nurses and families to help improve coordination, continuity, and support among caregivers.

“When we invest in the caring workforce, Pennsylvania benefits both socially and economically,” said Acting Secretary Snead. “Having care provided in your own home or within your community allows family caregivers to be part of the workforce themselves and it allows those needing home and community-based services to stay safe, healthy, and to thrive.”

More information about Pennsylvania’s home and community-based services spending plan is available on DHS’s website.

RCPA continues to meet with DHS advocating for members on the spending plan and distribution strategies to ensure the workforce issues are front and center of the plan. If you have any questions, please contact your RCPA Policy Director.

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The Centers for Medicare & Medicaid Services (CMS) has approved the Office of Long-Term Living’s (OLTL) Community HealthChoices (CHC) Waiver amendment. The amendment is effective January 1, 2022.

The changes in the approved amendment include:

  • Revised service definitions, service limitations, and/or provider qualifications for the following CHC waiver services:
    • Adult Daily Living;
    • Home Adaptations;
    • Participant-Directed Community Supports;
    • Personal Assistance Services;
    • Personal Emergency Response System (PERS);
    • Specialized Medical Equipment and Supplies; and
    • Vehicle Modifications.
  • Revised waiver performance measures.
  • Revised number of unduplicated recipients for Waiver Years 3–5 and revised corresponding cost neutrality estimates.
  • Revised Service Coordinator selection or assignment time frame from 14 days to 7 days to be consistent with the CHC Agreement.

Questions about the 2022 CHC amendment can be submitted electronically.

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