State of the Union Address and Impact on IDD Services
CMS
HHS Releases Statement on Cyberattack on Change Healthcare
As noted in a previous alert from the Department of Human Services (DHS), the Department of Health and Human Services (HHS) has also been providing updates regarding the recent cybersecurity incident that impacted Change Healthcare (a unit of UnitedHealth Group). HHS has noted that their first priority is to help coordinate efforts to avoid disruptions to care throughout the health care system.
On March 5, 2024, HHS announced immediate steps that the Centers for Medicare and Medicaid Services (CMS) is taking to assist providers to continue to serve patients. CMS will continue to communicate with the health care community and assist, as appropriate. Providers should continue to work with all their payers for the latest updates on how to receive timely payments.
CMS Announces Review Choice Demonstration to Start in PA on June 17, 2024
On March 1, 2024, the Centers for Medicare and Medicaid Services (CMS) posted an update on the Review Choice Demonstration for Inpatient Rehabilitation Facility (IRF) Services web page that announced they will be expanding the Review Choice Demonstration for IRF services in Pennsylvania on June 17, 2024. The demonstration will apply to IRF admissions occurring on or after June 17, 2024. IRF admissions prior to the June 17 date are not part of the demonstration, and IRF providers must select either 100% pre-claim review or 100% post-payment review between May 3, 2024, and June 2, 2024.
Medicare Administrative Contractor (MAC) for Jurisdiction L (which includes the state of Pennsylvania) is Novitas Medicare Solutions, who processes claims for IRFs located in Pennsylvania. Novitas will be directly involved in the RCD and created a dedicated RCD page on their website. The page includes additional information on background and general information, timelines, the two choices for claims review (pre-payment and post-payment), IRF RCD contact information, educational events, and other resources.
The IRF RCD began in Alabama in August 2023. CMS has cited that creating a review choice process will ensure Medicare coverage and documentation requirements are likely met. CMS feels this program will reduce the number of Medicare appeals, improve provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.
RCPA will continue to update members as additional information is received. Members are encouraged to review the information on the CMS RCD web page and Novitas RCD web page. Questions regarding this information can be directed to Melissa Dehoff.
CMS Hospital Open Door Forum Planned for March 12
The Centers for Medicare and Medicaid Services (CMS) will conduct their next hospital open door forum on Tuesday, March 12, 2024, from 3:00 pm – 4:00 pm. Note that the call has been rescheduled from March 5. Register to participate here.
Medicare Enrollment Update: Supervision Hours Documentation Available
IRF Quality Reporting Program Data Submission for Quarter 3 2023 Deadline is Tomorrow
In order to avoid a potential 2 percent decrease in the annual payment update for fiscal year (FY) 2025 (October 2024 – September 2025), inpatient rehabilitation facilities (IRF) are reminded that they must submit complete data in calendar year (CY) 2023 for all quality measures that are a part of the IRF Quality Reporting Program (QRP).
IRF Patient Assessment Instrument (IRF-PAI) assessment data and data submitted via the Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN) for July 1 – September 30 (Q3) of calendar year 2023 must be submitted no later than 11:59 pm on February 15, 2024.
The Centers for Medicare and Medicaid Services (CMS) contractor Swingtech sends informational messages to IRFs that are not meeting Annual Increase Factor (AIF) thresholds on a quarterly basis ahead of each submission deadline. These messages were sent late last week. IRFs are encouraged to check to see if any members of their QRP team received a message from the email address “[email protected].” If members need to add or change the email addresses to which these messages are sent, please email QRP Help and be sure to include your facility name and CCN along with any requested email updates. Any IRFs who receive a Swingtech email message are encouraged to identify and review the measures stated as missing data for Q3 2023 ASAP, and resolve any data issues by the February 15 deadline.
PA 1115 Demonstration Post-Award Forum to Provide Updates on FFCY and SUD Services on March 8
The Pennsylvania Department of Human Services (DHS) is hosting a post-award forum regarding the federal Section 1115 Demonstration, which includes Medicaid coverage for out-of-state former foster care youth and substance use disorder (SUD) services. It will take place at 1:00 pm – 2:30 pm on Friday, March 8, 2024, via WebEx. The forum aims to gather public feedback on the progress of these initiatives, both of which were approved by the Centers for Medicare & Medicaid Services (CMS). The Former Foster Care Youth (FFCY) component allows Medicaid coverage for individuals under 26 who were in foster care in another state upon turning 18. The SUD component provides funding for essential SUD services, including residential care.
Register for the forum here. Written comments are also acceptable until the same date. For inquiries, contact Shivani Patel. Further details and the announcement can be found here. Please contact RCPA Policy Director Jim Sharp for any further questions.
OMHSAS Announces Updated Eligibility for Certified Peer Specialist Role
The Office of Mental Health and Substance Abuse Services (OMHSAS) successfully collaborated with the Centers for Medicare & Medicaid Services (CMS) to revise Pennsylvania’s State Medicaid Plan for Certified Peer Specialists (CPS). The changes aim to enhance workforce opportunities, break down barriers, and establish a robust crisis system. The updated qualifications for aspiring CPS include:
- Elimination of the self-identification requirement for Serious Mental Illness, replaced with an attestation of a mental health diagnosis and a stage of recovery to support others;
- Removal of the high school diploma requirement and instead, as part of the Pennsylvania Certification Board (PCB) application, applicants will be providing narratives on how they achieved recovery and wellness; and
- The mandatory recent employment or volunteer experience within the last three (3) years has been removed.
Details on these changes can be found in the updated State Plan here (scroll down to 0013 Attachment 3.1A-3.1B, page 88). OMHSAS will issue a forthcoming bulletin, and inquiries can be sent electronically.
If you have further questions, please contact RCPA Policy Director Jim Sharp.
Final Medicaid Access Rule Sent to OMB for Review
On January 26, 2024, the Centers for Medicare & Medicaid Services (CMS) forwarded the final Medicaid Access Rule (CMS-2442-F) to the Office of Management and Budget (OMB) for the last review step before Federal Register publication.
The proposed Medicaid Access Rule contained a number of policies, including the much-discussed 80/20 provision that would require 80 percent of all Medicaid payments to be spent on direct care workers and direct service professionals compensation for personal care services.
RCPA commented on these proposed regulations and will continue to monitor progress with our federal partners. The OMB is expected to issue its comments in April. If you have questions, please contact RCPA Policy Director Fady Sahhar.
CMS Allocates $50M for School-Based Health Services Expansion
The Centers for Medicare & Medicaid Services (CMS) has announced $50 million in grants to enhance school-based health services for children, particularly focusing on mental health. The grants, made possible by the Bipartisan Safer Communities Act (BSCA), will provide up to $2.5 million each to 20 states through Medicaid and the Children’s Health Insurance Program (CHIP). CMS aims to connect millions of children to critical healthcare services, emphasizing the convenience of school-based care and its impact on children’s health and educational outcomes. The grants, supporting preventive, behavioral, and physical healthcare, hope to encourage more states to cover school-based health services and enhance existing programs. The application deadline for the grants is March 25, 2024. For further details, visit the grant’s information web page. The full press release is available on the CMS website.
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