Authors Posts by Fady Sahhar

Fady Sahhar

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Fady Sahhar, PhD, is the Acting COO for RCPSO. He is responsible for managing the operations of the company, leading the contract development and negotiations with the Managed Care Organizations on behalf of owner providers. Fady works directly on the business development opportunities for RCPSO and is engaged in the advocacy of the RCPA Physical Disabilities and Aging Division.

Important Electronic Visit Verification (EVV) Reminders:

  • EVV Visit Data Requirements
    • The technical specification and addendum documents released by the Department of Human Services (DHS) are required to be followed as part of the EVV implementation. DHS must be able to aggregate all data by aligning data elements.
    • Required fields outlined in these documents are required to complete EVV implementation for all providers in all programs.
    • Entering false data in any of the required fields is not compliant for EVV implementation.  As an example, the last 5 digits of the direct care worker’s social security number is a required field and must be submitted to uniquely identify the individual providing the care.
  • EVV Error Status Codes (ESCs)
    • Providers currently submitting EVV data either through the DHS Sandata EVV system or their own Alternate EVV system need to verify that their PROMISe EVV ESCs are setting on claims the way they would expect.  If providers are getting errors they believe are inaccurate, providers should contact the Provider Assistance Center (PAC) by email or at 800-248-2152.
    • Please refer to the EVV ESC guidance document on the DHS EVV website for additional information.
  • Telephony Visit Verification (TVV)
    • Cell phones may only be used in conjunction with a location device.
    • Providers cannot require participants to have a land line or cell phone.  It is the provider’s responsibility to ensure caregivers have the necessary equipment for EVV.
    • If a provider solely uses TVV, the provider agency should consider either offering other visit capture modalities or using the DHS Sandata EVV system.
  • Office of Developmental Programs (ODP)/Office of Long-Term Living (OLTL) Medical Assistance (MA) Bulletin
    • Issuance is expected within the next 2 weeks.
  • Office of Medical Assistance Programs (OMAP) MA Bulletins
    • MA Bulletins have been prepared for OMAP providers and are currently undergoing executive review.
    • Issuance is anticipated to occur mid-August for Fee-For-Service (FFS) providers.

OMAP Updates:

  • OMAP FFS Providers
    • On August 3, 2020, a listserv communication was issued to home health care agencies regarding the DHS Sandata training webinar registration opening.
    • All OMAP FFS Providers planning to use the DHS Sandata EVV system must receive training for the DHS Sandata EVV System.
    • Training will be done using a “train the trainer” model either via live webinar of a self-guided online training course.
    • Providers may enroll for the training webinar beginning August 10, 2020 on the Sandata Learn Website.
    • The webinar will be conducted on August 28, 2020.
    • Providers may do self-paced training if they’re unable to attend the webinar.
    • Further information regarding training sessions will be sent to providers via a listserv email.

OLTL Updates:

  • All OLTL providers who render personal care services (PCS) are subject to EVV.  For claims that contain PCS with dates of service October 1, 2020 and forward, there MUST be a matching EVV record in the DHS aggregator in order for the claim to pay.  OLTL strongly encourages providers who are not already capturing EVV visits electronically, to do so NOW and ensure those visits are being sent and stored in the DHS Aggregator.  Providers already capturing PCS visits electronically should ensure they understand the meaning of any EVV edits that are setting and understand what corrections are needed to take place on the claim and/or EVV record for a claim to pay in the future.
  • Community HealthChoices (CHC) Providers
    • Providers serving Participants in CHC must implement an EVV system, follow all implementation directions provided by the CHC Managed Care Organizations (MCOs), and send EVV visit data to the CHC-MCOs. Providers have the option to utilize the HHAeXchange system offered by the CHC-MCOs or select their own Alternate EVV system.
    • As a reminder, providers using the HHAeXchange system offered by the CHC-MCOs do not need to complete Aggregator training or the Alt-EVV certification process.
  • FFS Providers
    • OLTL providers serving participants in the OBRA waiver or the Act 150 program must implement EVV for these programs by either:
      • Completing training and using the DHS EVV Sandata system.
      • Integrating an Alternate EVV system with the DHS EVV Aggregator to send EVV data for OBRA waiver and Act 150 participants.
      • Working with HHAeXchange (if applicable) to send the OBRA waiver and Act 150 EVV data separate from Community HealthChoices (CHC) data.
        • Providers choosing this option must confirm this process is completed with HHAeXchange.

ODP Updates:

  • All ODP providers who render personal care services (PCS) are subject to EVV.  For claims that contain PCS with dates of service October 1, 2020 and forward, there MUST be a matching EVV record in the DHS aggregator in order for the claim to pay.  ODP strongly encourages providers who are not already capturing EVV visits electronically, to do so NOW and ensure those visits are being sent and stored in the DHS aggregator.  Providers already capturing PCS visits electronically should ensure they understand the meaning of any EVV edits that are setting and understand what corrections are needed to take place on the claim and/or EVV record for a claim to pay in the future.
  • Agencies with Choice (AWCs)
    • AWCs are required to comply with all Departmental requirements as a condition of participation in the MA program.  Support Service Professionals (SSP) and/or Managing Employers are required to participate in the Department’s required EVV process.
    • In accordance with ODP Bulletin 00-08-08Agency with Choice Financial Management Services (AWC FMS), “the AWC FMS provider is the employer of record responsible for certain employer functions,” which includes “assuring that Waiver and non-Waiver provider requirements are met.”  The individual or surrogate, as the managing employer of their qualified SSPs, is “responsible to verify time worked by qualified SSPs and approve and sign timesheets.”  This includes participation in the EVV process.  AWCs, therefore, have the authority to require SSP participation in the EVV process as a condition of employment.
    • Please contact your Administrative Entity with any questions you may have.
  • Vendor Fiscal (PALCO)
    • Effective August 16, 2020, PALCO is requiring All participant-directed services are captured electronically by the SSP.
    • EVV training materials and registration forms are available on the PALCO website.

DHS Sandata EVV Updates

  • Sandata Mobile Connect (SMC)
    • On August 17, 2020, DHS Sandata EVV will change the SMC app security lockout functionality to better align with PA DHS’ security requirements. Effective August 17, 2020, after 3 (three) “unsuccessful login” attempts in 15 minutes, a user will be locked out of SMC.
    • After this date, it is RECOMMENDED that upon two (2) unsuccessful attempts to log into SMC, users reset their passwords and not make a 3rd attempt to log in, risking getting locked out.  We ask all agency security administrators to please inform their respective staff members of this change.
  • Billing Module
    • The availability of the billing module has been delayed until 2021.  DHS will release more information as it is available.
    • Providers should continue to use existing billing processes.

A listserv has been established for ongoing updates on the CHC program. It is titled OLTL-COMMUNITY-HEALTHCHOICES, please visit the ListServ Archives page at http://listserv.dpw.state.pa.us to update or register your email address.

Months and dates shown on a calendar whilst turning the pages

General and Targeted Distribution Post-Payment Notice of Reporting Requirements

The purpose of this notice is to inform Provider Relief Fund (PRF) recipients that received one or more payments exceeding $10,000 in the aggregate from the PRF of the timing of future reporting requirements. Detailed instructions regarding these reports will be released by August 17, 2020.

The reporting system will become available to recipients for reporting on October 1, 2020.

  • All recipients must report within 45 days of the end of calendar year 2020 on their expenditures through the period ending December 31, 2020.
  • Recipients who have expended funds in full prior to December 31, 2020 may submit a single final report at any time during the window that begins October 1, 2020, but no later than February 15, 2021.
  • Recipients with funds unexpended after December 31, 2020, must submit a second and final report no later than July 31, 2021.
  • Detailed PRF reporting instructions and a data collection template with the necessary data elements will be available through the HRSA website by August 17, 2020.

If you have any questions, please contact your RCPA Policy Director.

CERTIFICATION CONCEPT

The ARC of Pennsylvania’s Making Employment Work course is an ACRE Basic Certification Training.  To receive certification, participants must attend a 3-day, live webinar training and then complete a self-paced, online curriculum.

Live webinar training takes place on October 5–7, 2020, from 9:00 am to 11:00 am and 1:00 pm to 3:00 pm each day. The rest of the course is self-paced, online and will begin after the conclusion of the lectures on October 7, 2020.

Register for the training and complete the online registration form. See flyer for more information.

Business Team Concept: FUNDING

This communication is to update and replace the ListServ email sent on July 20, 2020 regarding the subject: CARES Act Provider Relief Fund Payments Available for Medicaid/CHIP Providers. The U.S. Department of Health and Human Services has updated the deadline to submit the application to HRSA for this funding to be August 3, 2020 and provided a fact sheet to answer questions. This information has been updated below. Please disregard the previous communication.

The U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced additional distributions from the Provider Relief Fund to eligible Medicaid and Children’s Health Insurance Program (CHIP) providers that participate in state Medicaid and CHIP programs. HHS expects to distribute approximately $15 billion to eligible providers that participate in state Medicaid and CHIP programs and have not received a payment from the Provider Relief Fund General Allocation. The original deadline to submit the application to HRSA for this funding was July 20, 2020. HHS recently released an announcement that the deadline has been updated to August 3, 2020. A PDF fact sheet explaining the application process has also been released to address questions.

Eligibility Requirements:

To be eligible to receive HHS’ Medicaid Provider Distribution payments, initial key eligibility requirements for Medicaid and CHIP programs and/or Medicaid and CHIP managed care organization providers include:

  • The provider must not have received payments from the $50 billion Provider Relief Fund General Distribution to Medicare providers (note: if a Medicaid/CHIP provider was eligible for the General Distribution payment and rejected the payment, it cannot be eligible for the Medicaid Provider Distribution);
  • The provider must have directly billed or own (on the application date) an included subsidiary that has billed a state Medicaid/CHIP program and/or a Medicaid/CHIP managed care plan for health care-related services between January 1, 2018 and December 31, 2019;
  • The provider must have either (i) filed a federal income tax return for fiscal years 2017, 2018 or 2019 or (ii) be an entity exempt from the requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return (e.g. a state-owned hospital or healthcare clinic);
  • The provider must have provided patient care after January 31, 2020;
  • The provider must not have permanently ceased providing patient care directly, or indirectly through included subsidiaries; and
  • If the applicant is an individual, they must have gross receipts or sales from providing patient care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee.

Examples of types of Medicaid/CHIP providers that are eligible for these payments include pediatricians, obstetrician-gynecologists, dentists, opioid treatment and behavioral health providers, assisted living facilities, and other providers of home and community-based services. In order to receive Provider Relief Fund payments, eligible Medicaid/CHIP providers must take action through HRSA’s application portal and comply with the Medicaid Relief Fund Payment Terms and Conditions.

Provider Relief Fund payments will be at least two percent (2%) of reported gross revenue from patient care. Eligible Medicaid/CHIP providers can report their gross annual patient revenue through the Enhanced Provider Relief Fund Payment Portal and the final amount that a provider receives will be determined after such data is submitted, including information on the number of Medicaid patients served. HHS has issued a comprehensive set of instructions for submitting an application through the application portal.

Before applying through the Enhanced Provider Relief Fund Payment Portal, applicants should:

In addition, DHS encourages Medicaid/CHIP providers to carefully review the Medicaid Relief Fund Payment Terms and Conditions with their attorneys and accountants on the appropriate use of and questions about CARES Act Provider Relief Funds.

Contact your division’s policy director if you have any questions.

The Office of Long-Term Living (OLTL) held a webinar providing consumers and other stakeholders an update. This may be the last Third Thursday Webinar, as it was originally designed to communicate with consumers and stakeholders during the rollout of Community HealthChoices (CHC).  As the rollout is now complete, and the continuity of care has ended, the slides provide other public meetings and resources where the same content is covered.

Highlights:

  1. CHC Updates
  • The Continuity of Care (COC) period ended on June 30, 2020 for the Northeast, Northwest, and Lehigh/Capital zones.
  • CHC is now fully implemented statewide.
  • The Department of Human Services is continuing to prioritize the monitoring and oversight of program operations and participant services.
  1. New Resource and Referral Tool
  • The tool will serve as a care coordination system for providers and social service organizations and will include a closed-loop referral system that will report on the outcomes of the referrals.
  • It will also serve as an access point to help Pennsylvanians find and access the services they need to achieve overall well-being and improve health outcomes.
  • Responses can be submitted through the eMarketplace and are due by August 6th.
  1. Appendix K Transition Plan
  • Waiver Services and Person-Centered Service Plans (PCSP)
    • When a county enters the green phase, the CHC-MCOs may begin conducting comprehensive needs reassessments that were missed due to the public health emergency (PHE) and services can be adjusted based on the outcome of the reassessment.
    • When a county enters the green phase, Service Coordinators should monitor participants and PCSPs through face-to-face contact when possible.
  • Initial Level of Care Assessments
    • Initial level of care assessments using the FED that take place in the participant’s home should be conducted face-to-face when possible.
    • Initial level of care assessments using the FED that take place in nursing facilities should be conducted remotely using phone or video conferencing.
  • Needs Assessments and Reassessments
    • Service Coordinators must receive education and training from the CHC-MCOs on how to evaluate individual risk factors and protect themselves from potential exposure according to the guidance issued by the CDC and the Department of Health.
    • Annual Reassessments, including the needs assessment, should be conducted face-to-face when possible.
  • Personal Protective Equipment (PPE)
    • PPE such as gloves, gowns and masks for participant use can be obtained as Specialized Medical Equipment and Supplies if no other source is available.
    • This flexibility will continue for the duration of the Appendix K approval period regardless of the county’s status.
  • Respite
    • Respite in a licensed facility may be extended beyond 29 consecutive days without prior approval of the CHC-MCO, in order to meet the participant’s health and safety needs.
    • When a county transitions to green, this flexibility continues if the need for additional respite is a result of COVID-19.
    • Prior approval of the CHC-MCO is required. This remains in effect for the duration of the Appendix K approval.
  • Personal Assistance Services (Agency and Participant-Directed) and Participant-Directed Community Supports
    • When a county enters the green phase, spouses, legal guardians, and persons with power of attorney may no longer serve as paid direct care workers.
    • Participants will be expected to resume using their existing direct care worker or a replacement worker, if necessary.
  1. Regional Response Health Collaboration Program (RRHCP)

The U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced additional distributions from the Provider Relief Fund to eligible Medicaid and Children’s Health Insurance Program (CHIP) providers that participate in state Medicaid and CHIP programs. HHS expects to distribute approximately $15 billion to eligible providers that participate in state Medicaid and CHIP programs and have not received a payment from the Provider Relief Fund General Allocation.  The deadline to submit the application to HRSA for this funding is July 20, 2020.

Eligibility Requirements:

To be eligible to receive HHS’ Medicaid Provider Distribution payments, initial key eligibility requirements for Medicaid and CHIP programs and/or Medicaid and CHIP managed care organization providers include:

  • The provider must not have received payments from the $50 billion Provider Relief Fund General Distribution to Medicare providers (note: if a Medicaid/CHIP provider was eligible for the General Distribution payment and rejected the payment, it cannot be eligible for the Medicaid Provider Distribution);
  • The provider must have directly billed or own (on the application date) an included subsidiary that has billed a state Medicaid/CHIP program and/or a Medicaid/CHIP managed care plan for health care-related services between January 1, 2018 and December 31, 2019;
  • The provider must have either (i) filed a federal income tax return for fiscal years 2017, 2018 or 2019 or (ii) be an entity exempt from the requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return (e.g. a state-owned hospital or healthcare clinic);
  • The provider must have provided patient care after January 31, 2020;
  • The provider must not have permanently ceased providing patient care directly, or indirectly through included subsidiaries; and
  • If the applicant is an individual, they must have gross receipts or sales from providing patient care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee.

Examples of types of Medicaid/CHIP providers that are eligible for these payments include pediatricians, obstetrician-gynecologists, dentists, opioid treatment and behavioral health providers, assisted living facilities, and other providers of home and community-based services. In order to receive Provider Relief Fund payments, eligible Medicaid/CHIP providers must take action through HRSA’s application portal and comply with the Medicaid Relief Fund Payment Terms and Conditions.

Provider Relief Fund payments will be at least two percent (2%) of reported gross revenue from patient care. Eligible Medicaid/CHIP providers can report their gross annual patient revenue through the Enhanced Provider Relief Fund Payment Portal and the final amount that a provider receives will be determined after such data is submitted, including information on the number of Medicaid patients served. HHS has issued a comprehensive set of instructions for submitting an application through the application portal.

Before applying through the Enhanced Provider Relief Fund Payment Portal, applicants should:

In addition, DHS encourages Medicaid/CHIP providers to carefully review the Medicaid Relief Fund Payment Terms and Conditions with their attorneys and accountants on the appropriate use of and questions about CARES Act Provider Relief Funds.

HHS has created a listing of CARES Act Provider Relief Funds Frequently Asked Questions (FAQ).

The complete press release is on the HHS website.

More information about eligibility and the application process is also available on the HHS website.

** Please note when applying for this, the first step is to enter your Tax ID Number.   The number must be verified before you can move to the next step.  This could take a day or two, therefore providers should NOT wait until the last day, July 20 to apply.

The Department of Human Services has now posted CARES Act funding details along with a Facility Acceptance Form.

Important to note that the Facility Acceptance Form includes some conditions and timelines for the use of these funds:

  1. Will be used in response to the COVID-19 public health emergency.
  2. Only towards eligible expenses that include staff personnel and training costs, housekeeping supplies, and the lease or purchase of medical supplies and equipment including personal protective equipment and testing supplies.
  3. Applied to expenses incurred during the period March 01, 2020 through November 30, 2020.
  4. The final expense report will be submitted on or before December 16, 2020.
  5. If the subsidy exceeds the actual expenditures incurred, the excess subsidy will be returned to the Commonwealth with the final expense report.

If you have any questions, please contact your RCPA Policy Director.