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Medicare

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The next phase of the Centers for Medicare and Medicaid Services (CMS) inpatient rehabilitation facility (IRF) review choice demonstration (RCD) is scheduled to be implemented in Pennsylvania on June 17, 2024, and will last for five years. This demonstration applies to only IRF providers physically located in Pennsylvania.

Between May 3, 2024, and June 2, 2024, IRFs must select either 100% pre-claim review or 100% post-payment claim review.

CMS has stated that creating a review choice process will ensure Medicare coverage and documentation requirements are likely met. This program reduces the number of Medicare appeals, improves provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.

Novitas Solutions is the Medicare Administrative Contractor (MAC) for Pennsylvania and will process the IRF claims. In preparation for the implementation of IRF RCD, Novitas Solutions will be conducting their first webinar on April 24, 2024, from 1:00 pm – 2:30 pm. Registration to participate in this webinar is now open. Members are strongly encouraged to participate in this webinar to prepare for this demonstration. If the registration link does not work, please copy and paste the below link into your browser to register:
https://fcso.webex.com/webappng/sites/fcso/meeting/register/0fd87e2111f7446fa477d0a25f78674c?ticket=4832534b000000073a942d9e6f94601b6b106adc8f502bcee359653432e8c326edb0f50ebc253329&timestamp=1711559626291&RGID=re6663754d2fe70defe3195e29c69465a

In addition to information on the CMS website, Novitas Solutions has a dedicated website that provides a great deal of information and resources on IRF RCD.

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Message from The Centers for Medicare & Medicaid Services (CMS):

The Centers for Medicare & Medicaid Services (CMS) is continuing to monitor and assess the impact that the cyberattack on UnitedHealth Group’s subsidiary Change Healthcare has had on all provider and supplier types. Today, CMS is announcing that, in addition to considering applications for accelerated payments for Medicare Part A providers, we will also be considering applications for advance payments for Part B suppliers.

Over the last few days, we have continued to meet with health plans, providers and suppliers to hear about their most pressing concerns. As announced previously, we have directed our Medicare Administrative Contractors (MAC) to expedite actions needed for providers and suppliers to change the clearinghouse they use and to accept paper claims if providers need to use that method. We will continue to respond to provider and supplier inquiries regarding MAC processes.

CMS also recognizes that many Medicaid providers are deeply affected by the impact of the cyberattack. We are continuing to work closely with States and are urging Medicaid managed care plans to make prospective payments to impacted providers, as well.

All MACs will provide public information on how to submit a request for a Medicare accelerated or advance payment on their websites as early as today, Saturday, March 9.

CMS looks forward to continuing to support the provider community during this difficult situation. All affected providers should reach out to health plans and other payers for assistance with the disruption. CMS has encouraged Medicare Advantage (MA) organizations to offer advance funding to providers affected by this cyberattack. The rules governing CMS’s payments to MA organizations and Part D sponsors remain unchanged. Please note that nothing in this statement speaks to the arrangements between MA organizations or Part D sponsors and their contracted providers or facilities.

If you have any questions, please contact Fady Sahhar.

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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.

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RCPA and the National Council for Mental Wellbeing have worked together to resolve the recent concern with Medicare enrollment rejections for Marriage and Family Therapists as well as Mental Health Counselors. There have been many cases where the applications were rejected because applications did not include documentation or verification of the required 3,000 hours of supervision or the 2 years’ experience. RCPA met with the Centers for Medicare and Medicaid Services (CMS) on several occasions, outlining that the applications that meet the Medicare enrollment criteria have met this standard as part of the PA State License.

Initially, CMS cited that it was a requirement to provide the documentation. After communicating with CMS leadership, however, CMS responded that RCPA was correct and clarified that if a provider is licensed and the hours are a requirement for the licensure, said provider does not require the verification.

If your agency has received a rejected application, please contact RCPA Policy Director Jim Sharp, who will connect your agency to the proper department that will address the denial.

SUD Addiction Counselors Eligible for Medicare Enrollment

There have been several members who have attempted to enroll their SUD counselors who have met the enrollment qualification being told by CMS that the enrollment does not include these SUD professionals.

RCPA has confirmed with CMS leadership that if the provider is licensed as an addiction counselor or alcohol and drug counselor (ADC) by the state in which the services are performed, they can also enroll as an MHC as long as all other requirements are met.

MHCs are defined as individuals who:

  • Possess a master’s or doctor’s degree, which qualifies for licensure or certification as an MHC, clinical professional counselor, or professional counselor under the state law of the state in which such individual furnishes the services defined as mental health counselor services;
  • After obtaining such a degree, have performed at least 2 years or 3,000 hours of post-master’s degree clinical supervised experience in mental health counseling in an appropriate setting, such as a hospital, SNF, private practice, or clinic; and
  • Is licensed or certified as an MHC, clinical professional counselor, professional counselor, addiction counselor, or alcohol and drug counselor (ADC) by the state in which the services are performed.

RCPA is recommending that this language accompany any future enrollment applications to CMS for SUD Addictions Counselors enrollment documentation.

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Image by Dirk Wouters from Pixabay

The Centers for Medicare and Medicaid Services (CMS) is conducting a study to help them improve your experience with Medicare program and billing resources. Share your thoughts with them by taking this survey today. Responses are confidential, and the survey should take about 15 minutes to complete.

CMS thanks you for your time and valuable feedback.

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