Policy Areas

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The Office of Long-Term Living (OLTL) will be conducting the next Community HealthChoices (CHC) Third Thursday webinar on December 19, 2019 from 1:30 pm – 3:00 pm. During this webinar, Deputy Secretary Kevin Hancock will provide updates on the CHC program. To participate in the webinar, please register here. Once registered, you will receive a confirmation email that contains the information about joining the webinar. If you have any questions, please contact the OLTL Bureau of Policy Development and Communications Management at 717-857-3280.

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The Centers for Medicare and Medicaid Services (CMS) recently announced the availability of the inpatient rehabilitation facility (IRF) provider preview reports. These reports have been updated and contain information based on quality data submitted by IRFs between Quarter 3 of 2018 and Quarter 2 of 2019. The data will reflect what will be published on IRF Compare during the March 2020 update of the website.

Providers have 30 days (December 9, 2019 – January 9, 2020) to review their performance data. While corrections to the underlying data will not be permitted during this time, providers can request CMS to review their data during the preview period if they believe the quality measure scores that are displayed are inaccurate.

Additionally, providers are reminded that the data for the quality measure Percent of Residents or Patients that have new or worsened Pressure Ulcers (short stay), will continue to reflect data collected between Quarter 3 2017 – Quarter 2 2018, and will continue to be publicly displayed until the new Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury, is publicly displayed in fall 2020, as finalized in the fiscal year (FY) 2018 IRF PPS Final Rule.

As of the March 2020 refresh, CMS will no longer publicly display the measure Percent of Residents or Patients who were assessed and appropriately given the seasonal influenza vaccine (short stay), as finalized in the FY 2019 IRF PPS Final Rule. This change is reflected in preview reports. Contact RCPA Rehabilitation Services Director Melissa Dehoff with questions.

Tablet on a desk - Questions and Answers

The Office of Mental Health and Substance Abuse Services (OMHSAS) has released an updated version of the Intensive Behavioral Health Services (IBHS) FAQ. Additionally, there will be another FAQ update in early January. Please review the new version as the inquiries include OMHSAS responses on staff training / qualifications, licensing parameters, service delivery, and other key feedback brought forth by stakeholders. The new IBHS FAQ can be found here.

We have been informed that there will be new OMHSAS IBHS bulletins released in December, regarding the prior authorized services in the fee-for-service delivery system and the medical necessity guidelines. All new IBHS information provided will also be reviewed by the RCPA IBHS Work Group.

As the IBHS implementation moves forward, we ask that RCPA Children’s Division Director Jim Sharp be included on questions sent to the IBHS RA account or directly to OMHSAS regional offices. We will continue to maintain our own member inquiry repository. If you have any questions or feedback, please contact Jim Sharp.

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The Centers for Medicare and Medicaid Services (CMS) recently notified the Office of Long-Term Living (OLTL) of the approval of the OBRA Waiver amendment. The amendment is effective on January 1, 2020.

The changes in the approved amendment include:

  • Revise the Residential Habilitation service definition by modifying the number of hours that are defined as a day unit from a minimum of 12 hours to 8 hours.
  • Revise the service definitions of Job Finding, Job Coaching, Employment Skills Development, Career Assessment, and Benefits Counseling to address when employment services can be provided through the OBRA waiver, should the Office of Vocational Rehabilitation (OVR) have a waiting list (closed order of selection) or when OVR has not made an eligibility determination within 120 days.
  • Update the Abuse Registry Screening information to reflect that the Department of Human Services (DHS) utilizes IDEMIA as the data system to process fingerprint-based FBI criminal record checks, as well as other minor changes.
  • Revise cost neutrality estimates to reflect rate changes to the Personal Assistance Services (PAS) and Residential Habilitation waiver services.

If you have any questions, please contact the OLTL Bureau of Policy Development and Communications Management at 717-857-3280.

Disabled Woman In Wheelchair Boarding Bus

ODP Announcement 19-157 provides information regarding the publication of the Department of Human Services (Department) proposed Fee Schedule Rates for Transportation Trip services that will be added to the Adult Autism Waiver (AAW) effective January 1, 2020. Public comment on these proposed changes will be accepted until 11:59 pm on January 7, 2020.

Effective January 1, 2020, the Department proposes to add Transportation Trip as a service available in the Adult Autism Waiver. The amendment to the Adult Autism Waiver that contains this change is currently with the Centers for Medicare and Medicaid Services (CMS) for approval. In anticipation of approval, a public notice was published in the Pennsylvania Bulletin Volume 49, Number 49 on Saturday, December 7, 2019. The notice informs stakeholders of the proposed Fee Schedule Rates for Transportation Trip services that will be funded through the AAW.

The title of the notice is Proposed Fee Schedule Rates for Transportation Trip Services Funded Through the Adult Autism Waiver.

One Fee Schedule Rate was developed for each Transportation Trip service zone. Transportation Trip services can be offered by providers who enroll directly with the Department to provide Transportation Trip services or through Organized Health Care Delivery System (OHCDS) providers. The assumption log used to develop these rates is available here.

ODP Announcement 19-158 announces the launch of MyODP News Online, an online site that replaces our monthly newsletter with a resource containing real time online news that is most pertinent to our stakeholders. MyODP News Online is now available via MyODP.org. Through this link, stakeholders will receive relevant news and information as it happens. Readers may subscribe to an RSS feed, and eventually may share articles through social media. Past content remains available online.

Stakeholders that previously received the monthly newsletter via listserv will now receive MyODP News Online Weekly Digest. The digest is sent each Friday and contains all the week’s posted news in abstract. Individuals who received SAU1’s self-advocate edited version of the monthly newsletter will continue to receive that publication via regular mail. Readers may send inquiries or suggest story ideas via email.

National Council Logo for Website

On Friday, leaders of the Senate Finance Committee reached an agreement on a 2-year extension and more than doubling the current program by adding 11 additional states to the Certified Community Behavioral Health Clinic Medicaid program. This agreement was announced by Senators Chuck Grassley (R-IA) and Ron Wyden (D-OR), the two lead negotiators on a year-end package of health care bills.

While this is an exciting development, there is still work ahead before this legislative package becomes law. The package must still be voted on by both the House and Senate before going to President Trump for his signature.

The National Council thanks its dedicated advocates for their work in building nationwide support for CCBHCs. Your voices have been heard!

Please see below for a statement on today’s announcement from National Council President and CEO Chuck Ingoglia.

“We applaud the members of Congress who worked so hard on this agreement to fund and expand our nation’s Certified Community Behavioral Health Clinics. Extending and expanding this successful program is vitally important to people who rely on the mental health and addiction services provided by CCBHCs. It’s crucial that the delivery of care not suffer from disruption, and this agreement would ensure programs and services continue uninterrupted.

“Just as importantly, expanding the program means more people in more states will benefit from access to high quality care provided by CCBHCs. In a nation reeling from an opioid and suicide crisis, that is welcome news. While the mental health and addiction crisis continue to devastate the lives of people across the country, CCBHCs represent our nation’s best response. Expansion of the program is both a fiscally responsible decision and a compassionate response from lawmakers who understand the impact CCBHCs provide in communities across the country. Expansion represents a profound opportunity to help people and heal communities.

“We understand there are many hurdles to overcome before this agreement to provide funding and expand the CCBHC program becomes a reality, but we want to applaud the leadership of those responsible for championing the CCBHC program – Chairman Charles Grassley (R-Iowa), Ranking Member Ron Wyden (D-Ore.), Senator Debbie Stabenow (D-Mich.), Senator Roy Blunt (R-Mo.), Representatives Doris Matsui (D-Calif.), Markwayne Mullin (R-Okla.), Greg Walden (R-Ore.) and Frank Pallone (D-N.J.).

“We also want to thank our partners in the field who joined forces with us in this shared mission. The National Alliance on Mental Illness, Mental Health America, National Association of State Mental Health Program Directors, the National Association for Behavioral Healthcare and many others have served as leaders in championing this vital program.”

As we approach the conclusion of the Governor’s Council on Reform public comment period on December 16, 2019, RCPA would like to ensure that each member has the materials for providing their public comments, feedback, and support. RCPA will be submitting commentary within each policy director’s purview, and we strongly urge your agency to submit your thoughts to the Council, including areas and issues that may not be represented in the current recommendations.

If you would like to send your submissions to your respective policy director for inclusion in the RCPA public comment, please have them submitted by close of business on Wednesday December 11, 2019.

Below you will find the links to important documents relating to the Council on Reform, including the Public Comment Submission Form. If you have further questions, please contact your respective RCPA Policy Director.

  1. Governor’s Executive Order
  2. November 1 Press Release
  3. Recommendation Document
  4. Public Comment Form

Thank you for your efforts and partnership to bring these recommendations to the forefront of your work.

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physiotherapist helping patient to walk

An article, “Comparison of Functional Status Improvements Among Patients with Stroke Receiving Postacute Care in Inpatient Rehabilitation vs Skilled Nursing Facilities,” was recently published in the Journal of the American Medical Association (JAMA) Network that highlights the findings from a cohort study of patients who received post-acute care in inpatient rehabilitation facilities (IRFs) or skilled nursing facilities (SNFs) following a stroke. The study examined changes in functional status. Stroke was selected because it is a major cause of disability in the United States and an important public health issue, and often requires a range of treatments and expertise.

The study included patients with stroke who were discharged from acute care hospitals to IRFs or SNFs from January 1, 2013 to November 30, 2014. Medicare claims were used to link to IRF and SNF assessments. The study does include limitations that were encountered, such as the findings don’t take into account other post-acute settings (home health, long-term care hospitals, etc.) and the inability to examine cognitive function before and after the stroke, stroke severity, or location of the stroke.

The findings of the study suggest that the care in an IRF was associated with greater improvement in mobility and self-care compared with care in an SNF. Their findings indicate the need to carefully manage discharge to post-acute care based on the patient’s needs and potential for recovery. Post-acute reform based on the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) must avoid a payment system that shifts patients with stroke who could benefit from intensive inpatient rehabilitation to lower cost settings. The IMPACT Act of 2014 is a bill that is intended to change and improve Medicare’s post-acute care services and how they are reported. Contact RCPA Rehabilitation Services Director Melissa Dehoff with questions.