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RCPA, along with The Alliance CSP, The Arc of Pennsylvania, MAX Association, PAR, and The Provider Alliance, submitted a joint letter to ODP Deputy Secretary Kristin Ahrens outlining recommended improvements to Community Participation Support (CPS). The letter highlights policy and regulatory barriers affecting person-centered services, workforce stability, and provider sustainability, and urges ODP to pursue near-term solutions through policy clarification or regulatory waivers.

Key recommendations include:

  • Planning and Coordination Billing: Allow billing for planning and coordination while CPS services are delivered and permit billing at ratios aligned with individuals’ actual support needs (e.g., 1:1, 1:2, 1:3). Associations recommend a new billing code/modifier or a statewide ODP announcement.
  • Program Specialist Education Requirements: Align education requirements for program specialists in Chapters 2380 and 2390 with Life Sharing and unlicensed residential models by permitting a high school diploma plus six years of ID/A experience, ideally through a blanket waiver announced via ODP Bulletin.
  • Dual Licensure for Chapter 2380 Programs: Eliminate dual licensure with the Department of Aging for providers billing exclusively to ODP when serving individuals age 60 and over, and remove the age cap of 59 in Chapter 2380 through regulatory change or waiver.
  • Rounding of 15-Minute Units: Allow rounding of 15-minute service units to reduce administrative burden and align with Office of Long-Term Living practices.

The associations stress that these changes are essential to sustaining safe, meaningful, and person-centered CPS services. RCPA will continue advocacy with ODP and provide updates as they are available.

For Questions or Additional Information
Please contact Tim Sohosky for any follow-up or inquiries related to this update.

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RCPA, as part of a statewide provider and association coalition, has sent a letter to the PA Congressional Delegation regarding the extension of the Enhanced Premium Tax Credit (EPTC). The coalition urges Congress to move quickly to pass legislation extending EPTCs that make marketplace plans more affordable for people who purchase their own health insurance; these are set to expire at the end of 2025.

If EPTCs are not extended, an estimated 270,000 Pennsylvanians are likely to become uninsured. Pennsylvania taxpayers end up paying for their care in one way or another because uninsured people are often forced to delay or avoid care for treatable conditions. They ultimately end up sicker and require more expensive care in hospitals, which leads to higher, uncompensated care costs for both hospitals and providers. In addition, they acquire medical debt and experience health complications that can jeopardize their employment or employability.

Read the letter here. If you have any questions, please contact RCPA COO Jim Sharp.

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Young Girl Talking With Counselor At Home

The Pennsylvania Department of Education and the Pennsylvania Department of Human Services are pleased to share a Dear Colleague letter regarding important updates to federal non-regulatory guidance for students in foster care placement.

This updated guidance, issued jointly by the U.S. Department of Education (ED) and the U.S. Department of Health and Human Services (HHS), represents the first significant update to federal guidance since the enactment of the Every Student Succeeds Act (ESSA) in 2015.

Please see the letter for details about this announcement, and thank you for your continued dedication to supporting students in foster care.

Please contact Emma Sharp with any questions.

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On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.

If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:

Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.

RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:

Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the ‎reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.

Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following ‎information:‎

  • A copy of the CMS non-compliance letter;
  • A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of ‎calendar year 2024; and
  • If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the ‎monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract ‎Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among ‎Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.

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On July 2, the U.S. Department of Labor (DOL) took an important step to restore fairness and flexibility in the home care industry by issuing a proposed rule that would rescind restrictive provisions introduced in 2013 under the Obama administration. Those earlier changes, fully enforced in 2015, significantly narrowed the “companionship services” exemption under the Fair Labor Standards Act (FLSA), adding complex and costly wage requirements for home care agencies and Medicaid-funded services.

The 2013 rule redefined key terms, eliminated the exemption for third-party employers, and imposed overtime obligations on agency-employed direct care workers — contributing to increased costs and administrative burdens. These unintended consequences have strained both providers and public programs, particularly in Medicaid-funded home and community-based services (HCBS).

Now, DOL is proposing to correct course. In its justification, the Department noted that the previous regulations “might not reflect the best interpretation of the FLSA and might discourage essential companionship services by making these services more expensive.”

Why This Matters
This proposed rule is a welcome change for providers, participants, and state Medicaid leaders alike. Overtime costs are a major driver of financial pressure in long-term services and supports. When direct care workers live in the same home as the individuals they serve, current law allows participant-directed employers to avoid overtime pay. However, because of the 2013 changes, agency-employed workers doing the exact same job do not receive the same treatment — creating an inequitable and unsustainable two-tiered system.

If finalized, the proposed rule would allow third-party agency employers to once again access the same companionship exemption. This would create consistency across employer types and make it easier to recruit and retain direct care staff — particularly in shared living or live-in arrangements that are vital to participant independence and stability.

Act Now: Submit a Letter of Support
The DOL is accepting public comments on this proposed rule, and it is crucial that the provider community raise its voice. RCPA encourages home care agencies, managed care partners, and Medicaid stakeholders to submit letters of support highlighting how this change will:

  • Increase flexibility in service delivery;
  • Align federal and state wage policy;
  • Promote cost-effective care models;
  • Support direct care worker retention; and
  • Sustain vital programs that keep individuals in their homes.

Your voice matters. Together, we can ensure federal policy reflects the realities and needs of today’s home and community-based care system. View a sample letter for public comments here.

How to Submit Your Letter of Support
Visit the Regulations government website and search for the DOL proposed rule on companionship services. Comments must be submitted by July 31, 2025

If you have any questions, contact Fady Sahhar, RCPA PD&A Division Director.

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