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Public Comment

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Today, both the ISAC Performance Review Subcommittee and the Medical Assistance Advisory Committee (MAAC) meetings were held. During these meetings, the Office of Developmental Programs (ODP) announced that as a result of public comments received regarding Performance-Based Contracting, some adjustments are being made to the plans. Tomorrow, ODP will release an announcement with more details, but for now, we know the following:

  • Residential providers will be offered a choice of when they are assigned into a tier. This will be based on which data they chose for ODP to review and make a tier determination upon. The choices will be:
    • Calendar year 2023 data reviewed with notification of tier assignment occurring in November, to be effective January 1, 2025 – June 2026; or
    • Review of Calendar year 2024 data with notification of tier assignment occurring in May, to be effective July 2025 – July 2026.

ODP plans to submit the proposed waiver to CMS on July 19, 2024.

In addition, the presentation from the MAAC meeting can be found here.

Documents from the Performance Review Subcommittee can be found below:

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The Office of Long-Term Living (OLTL) has announced two waiver amendments that are open for public comment. The amendments detail the Community HealthChoices (CHC) waiver renewal and the OBRA waiver amendments. Information on the CHC waiver and OBRA waiver are available individually as well as in the June 15, 2024, PA Bulletin. Comments are due July 15, 2024.

Those interested in submitting comments can do so in the following ways:

  1. For the CHC waiver:
    1. Send a letter to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: Keeley Anglin—CHC Waiver Renewal, PO Box 8025, Harrisburg.
    2. Submit comments to the department via email. Use “CHC Waiver Renewal” in the subject line.
    3. Please use the CHC Waiver Comment Form.
  2. For the OBRA waiver:
    1. Send a letter to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: Keeley Anglin—OBRA Waiver Amendment, PO Box 8025, Harrisburg.
    2. Submit comments to the department via email. Use “OBRA Waiver Amendment” as the subject line.
    3. Please use the OBRA Waiver Comment Form.

Comments received by July 15, 2024, will be considered in subsequent revisions to the proposed renewal and amendment. For more information, please contact Fady Sahhar or Melissa Dehoff.

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Image by Werner Moser from Pixabay

ANCOR has shared that the first step to revise the Standard Occupational Classification process has begun. Today the Office of Management and Budget (OMB), on behalf of the Standard Occupational Classification Policy Committee (SOCPC) — which is the committee that makes recommendations to OMB for potential revisions — announced it is beginning the review of the 2018 Standard Occupational Classification (SOC) Manual for revisions to be made for 2028, and that it is soliciting public comment.

This is an opportunity to write comments in support of revisions to the SOC, in particular for the creation of a code for direct support professionals. In its notice for comments, OMB specifically notes that it “solicits and welcomes comments related to any aspect of occupational classification, especially comments concerning . . . whether to consider the addition of new detailed occupations or occupational groups, including specifically care workers.”

The public comment period is open until August 12, 2024. ANCOR will be submitting comments and providing additional guidance and tools to submit comments in the coming weeks.

For more information, the notice is available on the Federal Register website.

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RCPA has gathered feedback from our members in multiple forums and attended several listening sessions hosted by the Office of Developmental Programs (ODP) in order to hear and compile public comments on the proposed implementation of performance-based contracting (PBC) for Residential Services and waiver amendments to the Consolidated, Community Living, and Person/Family Directed Waivers. After reviewing all of the available information, we have submitted our comments to ODP.

Our members support the ideal of assuring quality services for individuals with ID/A that are integrated and person centered, enabling individuals to experience more independence and choices in their lives. Additionally, we are in favor of limiting the provider pool to only those providers that are able to demonstrate quality service provision.

RCPA wants to support this program for two reasons. First, any initiative by ODP that focuses on improving quality in the system is something we all should stand behind. Second, alternative reimbursement strategies with enhanced rates and additional funding based on quality and outcomes is certainly more innovative and progressive than traditional fee-for-service. It is time for the IDD system to move toward reimbursement policies that reward providers who are progressive in their service provision.

We are, however, concerned about the speed with which this incredibly complex systemic change is proposed to occur, and the amount of performance standards and measures proposed in this plan.

RCPA’s complete letter can be read here. For any questions, contact Carol Ferenz, Director, IDD Division.

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As a reminder, the public comment period ends next Tuesday, June 4, 2024, for the proposed implementation of Performance-Based Contracting for Residential Services, Waiver amendments, and proposed rates for services, which are effective July 1, 2024.

RCPA staff have participated in various listening sessions and met with members to hear your concerns regarding the proposed changes and rates. We will be sending our comments later this week and want to be sure that we are representing your interests. Please contact Carol Ferenz with any thoughts you have regarding these significant changes by close of business Wednesday, May 29, 2024.

Thank you for sharing your concerns. We strongly recommend that you take advantage of this opportunity to provide your own comments to ODP as well.

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Last week, House Bill 2300 was referred to the House Professional Licensure Committee. HB 2300: Legislative Package to Join the National Counseling Compact & Changes to Behavioral Specialists (Former HB 2852), allows Pennsylvania to join the Counseling Compact, enabling Licensed Professional Counselors (LPC) to practice across state lines without needing additional licenses. This change aims to improve access to mental health services by supporting telehealth, allowing LPCs to provide remote counseling. The compact also mandates standardized licensure requirements, including a 60 semester-hour master’s degree, a nationally recognized exam, and supervised postgraduate experience. RCPA is seeking member input as we develop our position on the legislation.

The Compact establishes a data system for sharing licensure and disciplinary information among member states, enhancing oversight and public safety. It mentions granting authority to member states to take actions against LPCs who violate regulations and creates the Counseling Compact Commission to oversee the implementation and administration. These changes ensure consistent standards for mental and behavioral health providers, increasing mobility and the availability of BH services.

As RCPA reviewed the details of this piece of legislation, one item of interest was that the bill entails the creation of a commission in Pennsylvania that will need to be funded. In the past, portions of commission operating costs have been realized by an increase in licensing fees. It is important to note that RCPA has not yet seen any fiscal package associated with the bill.

We ask that members review the bill and provide commentary as well as an organizational position of support, neutrality, or non-support. Please contact RCPA COO and Policy Director Jim Sharp with any feedback or questions.

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The Information Sharing and Advisory (ISAC) Committee for the Office of Developmental Programs (ODP) met on Tuesday, April 23, 2024. Deputy Secretary Ahrens gave an update and reminded members that on Friday, April 19, 2024, ODP published two very important announcements:

  • ODP Announcement 24-038: Open for Public Comment: Proposed Waiver Amendments and Rates for Services Funded Through the Adult Autism Waiver (AAW); and
  • ODP Announcement 24-039: Open for Public Comment: Proposed Implementation of Performance-Based Contracting for Residential Services, Waiver Amendments to the Consolidated, Community Living, and Person/Family Directed Waivers, and Rates.

Public comments are due June 4, 2024, for both of these announcements.

The proposed rates will be dependent on the governor’s budget passing with the proposed increases for ODP services remaining intact. Deputy Secretary Ahrens urged all stakeholders to advocate with legislators to keep this funding in the budget. Governor Shapiro has been visiting programs and sharing publicity about the importance of these services.

The Deputy Secretary also reviewed the current plans for Performance-Based Contracting for Residential Services with ISAC members. ODP has shared provider preparedness tools with the Residential Strategic Thinking Group for their feedback before publishing the provider preparedness tools and holding provider forums to support providers as they get ready for PBC implementation.

Provider preparedness tools include a Residential Provider Performance-Based Contracting Preparedness Assessment, which comes with a template to support providers developing plans to improve performance on the standards ahead of implementation in January 2025.

Once comments are reviewed and analyzed and any revisions made, the waiver application and amendments will be submitted to the Centers for Medicare & Medicaid Services (CMS) for review, and negotiations implementation target date is January 1, 2025.

RCPA is holding a meeting with our members to develop comments for submission to ODP on Thursday, May 9, 2024, from 9:30 am – 12:00 pm. We ask that you register for this meeting here in order to share your thoughts and help us as we develop our response.

For any questions, please contact Carol Ferenz.

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The Department of Human Services (Department) is making available for public review and comment the Office of Developmental Programs’ (ODP) proposed application for a section 1915(b)(4) waiver for a selective contracting program as well as amendments to the Consolidated and Community Living waivers required to implement selective contracting for Residential Habilitation, Life Sharing, and Supported Living services. The selective contracting program will be referred to as Performance-Based Contracting.

The Department is also making available for public review and comment additional proposed amendments to the Consolidated, Community Living, Person/Family Directed Support (P/FDS), and Adult Autism Waivers that are not related to implementation of selective contracting. Changes are proposed to become effective on January 1, 2025.

When performance-based contracting is implemented, all currently enrolled residential providers will have the opportunity to enter into a performance-based contract with ODP. To help support providers with the new requirements and process, ODP will hold provider trainings so that providers have a clear understanding of the process and expectations. As part of this process, providers will submit documentation demonstrating compliance with the performance areas identified by ODP. Additionally, ODP will use data from participant experience surveys, claims, incident management, health risk screening, administrative entities, and a new Performance Analysis Services vendor to evaluate each provider’s performance against the established standards and determine the tier in which the provider will be placed.

Providers will be placed in one of the following tiers based on their performance:

  • Conditional for providers operating under provisional or revoked licenses;
  • Primary for providers that meet current standards and a few additional standards;
  • Select for providers that deliver at least two of the three residential services in the performance-based contracting model and meet enhanced measures; or
  • Clinically Enhanced for providers that offer clinically enhanced medical or behavioral supports and meet enhanced measures.

The Department proposes the following substantive amendments to the Consolidated and Community Living waivers that will support the implementation of performance-based contracting, effective January 1, 2025:

  • Allow for the Department to contract with a Performance Analysis Services vendor that will provide administrative support with data collection, analysis, and reporting functions;
  • Require residential service providers to sign a residential provider agreement, which requires providers to comply with performance standards and reporting requirements outlined in the agreement and ODP policy; and
  • Implement pay-for-performance supplemental payments for residential service providers that meet or exceed performance targets for staff credentialing, employment of individuals served, transition of individuals to Life Sharing or Supported Living services, and reporting on use of technology.

Supplemental payments will be calculated for residential providers meeting or exceeding performance standards as a one-time or combined payment up to 3% of ODP-eligible service revenue from the applicable review period or established payment amount per qualifying event. Providers that have been determined to be a Primary, Select, or Clinically Enhanced provider are eligible to receive the supplemental payments.

  • Pay Licensed Residential Habilitation, Unlicensed Residential Habilitation, Life Sharing, and Supported Living providers that meet the requirements to qualify as a select provider or a Clinically Enhanced residential provider a payment that is in addition to the Medical Assistance fee schedule rate. Select providers will receive a rate add-on of 5% per individual served, and Clinically Enhanced providers will receive a rate add-on of 8%.

Other proposed amendments unrelated to Performance-Based Contracting include:

  • Assuring effective communication for individuals who use American Sign Language through implementation of a new American Sign Language — English Interpreter service. Services will be reimbursed as a vendor service based on the cost that the provider charges to the general public.
  • Promoting health, wellness, and safety by clarifying that individuals who receive services in an acute care hospital will not be disenrolled from the waiver.
  • Supporting the quality of Assistive Technology provided by expanding the qualification requirements for a professional who can complete an evaluation of an individual’s need for Assistive Technology and clarifying that evaluations can be completed for technology costing less than $750 if the service plan team believes it will be beneficial.
  • Increasing community participation and employment by requiring providers of Community Participation Support and Day Habilitation services to annually complete an analysis of each individual’s interests, preferences, skills, and strengths that support the individual’s participation in employment or other community activities.
  • Including revisions to align waiver requirements with regulatory requirements, correct errors, and provide clarification requested by stakeholders.
  • Increasing employment of individuals by allowing indirect activities to be billed through the Benefits Counseling service and improving access to Benefits Counseling for individuals who are not eligible for the Federal Work Incentives Planning and Assistance program.

The Department proposes the following substantive amendments to the Adult Autism Waiver that are not related to implementation of performance-based contracting effective January 1, 2025:

  • Support the quality of Residential Habilitation, Community Home, and Life Sharing services, through alignment of provider qualifications with the qualifications included in the Consolidated and Community Living waivers.
  • Promote health, wellness, and safety by clarifying that Residential Habilitation providers must have a licensed nurse available if the provider serves individuals with needs that require care by a licensed nurse.
  • Promote self-direction, choice, and control by clarifying that Community Transition Services can be used to support individuals transitioning from settings such as Residential Habilitation to private residences in alignment with guidance in the CMS instructions, technical guide, and review criteria for 1915(c) waivers.

View Performance-Based Contracting Information:

View Proposed Changes to the Waivers, Including Changes Not Related to Performance-Based Contracting:

Comments received within 45 days of publication of this notice will be reviewed and considered for revisions to the proposed application for a section 1915(b)(4) waiver as well as proposed amendments to the waivers. Comments should be addressed to Julie Mochon, Department of Human Services, Office of Developmental Programs, 625 Forster Street, Room 510, Harrisburg, PA 17120. Comments may also be submitted to the Department via email using the subject header ”Waiver Comments.”

RCPA will be scheduling a meeting for members to develop comments in response to these proposed amendments. Please contact Carol Ferenz with any questions.

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The Office of Developmental Programs (ODP) has published the proposed Fee Schedule Rates for services funded through the Consolidated, Community Living, Person/Family Directed Support (P/FDS), and Adult Autism Waivers and Base-Funded Program, residential ineligible services, as well as the accompanying rate assumption logs. These rates are proposed to become effective July 1, 2024.

Comments received by 11:59 pm on June 4, 2024, will be reviewed and considered for revisions. Interested persons are invited to submit written comments regarding the proposed rates. Comments may be submitted to the Department via email, and RCPA will schedule a meeting with our members to develop our comments.

Proposed Fee Schedule Rates and Department-Established Fees for Community-Based Services in the Consolidated, Community Living, and P/FDS Waivers and Base-Funding:

Adult Autism Waiver: 

* The proposed AAW fee schedule rates have not been posted

Comments about rates for services in the Consolidated, Community Living, and P/FDS Waivers and base-funding should be addressed to Department of Human Services, Office of Developmental Programs, Division of Provider Assistance and Rate Setting, 4th Floor, Health and Welfare Building, 625 Forster Street, Harrisburg, PA 17120.

Comments about rates for services covered in the Adult Autism Waiver should be addressed to Jamie Bonser, Department of Human Services, Office of Developmental Programs, 625 Forster Street, Room 510, Harrisburg, PA 17120.

We understand that the waiver amendments, including the details regarding Performance-Based Contracting, are scheduled to be published in the PA Bulletin this weekend, and we will share those with members as soon as they are available.

We would like to thank business member Paul Stanalonis for sharing an impact analysis he developed today. Please note that this comparison is based upon the rates that have continued to be in effect throughout COVID, and were not adjusted as originally planned by ODP.

Please contact Carol Ferenz with any questions. A meeting announcement will be sent to members once a date and time is confirmed.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2025 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule. The proposed rule will be published in the March 29, 2024, Federal Register. A high-level overview of the proposed rule is provided below:

Payment Updates:

CMS estimates an overall increase in aggregate payments to IRFs by 2.5% or $255 million (compared to the 4% payment update in FY 2024).

Market basket update for IRF services is 3.2%. This will be reduced by a productivity adjustment of 0.4%, which would result in an overall 2.8% increase. These figures are likely to change due to updated forecasts.

CMS is proposing to update the outlier threshold amount from $10,423 (FY 2024) to $12,158 (FY 2025), which would account for an estimated 0.2 percent decrease to aggregate payments across the IRF PPS in FY 2025.

Quality Reporting Program (QRP) Updates:

CMS is proposing to make additions, modifications, and removals of some QRP measures. A proposal was included to collect four new Standardized Patient Assessment Data Elements (SPADE) in the IRF QRP to bolster the collection of information on social determinants of health (SDOH):

  • Living Situation: Requests regarding the current living situation;
  • 2 Food Items: Questions about food running out;
  • Utilities: Questions about threats to shutting off utilities; and
  • A modification to an existing SPADE on Transportation.

CMS is also proposing to remove the “Admission Class” from the IRF Patient Assessment Instrument (PAI).

Feedback is requested on future revisions to the IRF QRP, as well as feedback on the development of a five-star methodology for IRFs.

Additional information will be forthcoming. Comments on the proposed rule are due to CMS by the end of May.

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