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rcd

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On April 24, 2024, Novitas Solutions hosted their first webinar for inpatient rehabilitation facilities (IRF) in preparation for the start date of the IRF Review Choice Demonstration (RCD) in Pennsylvania on June 17, 2024. Novitas is the RCD contractor for the state of Pennsylvania. The webinar provided an overview of the process, the different review choices, and the instructions for contractor-specific portal (Novitasphere). While the webinar primarily covered the basics of the program as previously laid out in CMS’s materials, there was some new information that was shared:

  1. For the first time, Novitas introduced the clinical leadership team for the demonstration in Pennsylvania:
    • Ene Ojile, the Contract Medical Director overseeing the RCD in Pennsylvania. Dr. Ojile is Board-Certified in Physical Medicine & Rehabilitation (PM&R), and she most recently served as Medical Director for a large freestanding inpatient rehabilitation hospital.
    • Jessica Hicks, RN, MSN, the Medical Review Manager.
    • Mia Jackson, RN, BSN, the Medical Review Team.
  2. There was some discussion and confusion about the methodology Novitas will use to calculate individual hospital’s affirmation rates under the RCD. During the webinar, Novitas staff stated that the total number of submissions and resubmissions would be included in the calculation, potentially penalizing hospitals for completing resubmissions even if the claim is eventually affirmed. After the webinar, Novitas circulated a “clarification” indicating that, “The number of resubmissions is not counted against the affirmation rate.” Additional clarification will be requested to confirm how the rates will be calculated and that the same methodology will be used as in Alabama.

The slides from the April 24 webinar are now available, and Novitas has also posted a recording of the main presentation (without the public Q&A portion) available here.

Novitas will also be hosting the following training and education webinars leading up to the start date. You can register for these webinars at their website.

  • May 2 — Review Choice Selection & Process (PA IRF Providers Only)
  • May 3 — RCD: How to Prepare (All JH and JL IRF Providers)
  • June 4 — Pre-Claim and Post-Payment Review Submissions (PA IRF Providers Only)

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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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The Department of Human Services Bureau of Human Services Licensing (BHSL) has released a draft Regulatory Compliance Guide (RCG) for Chapter 3800, relating to child residential and day treatment facilities. The RCG provides guidance about how the Department of Human Services will interpret and apply the chapter’s regulatory requirements during licensing inspections and investigations.

BHSL is inviting the Rehabilitation and Community Providers Association to work with members to review and comment on this draft guide. Please review the draft document and send your comments, suggestion and recommendations to Connell O’Brien. RCPA will collect provider input and share that information with the leadership of BHSL. Comments are due to RCPA by July 10 for submission to BHSL by July 17. The leadership of BHSL has communicated their clear interest in provider input and plans to take all comments into consideration prior to issuing a final RCG later this summer.

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