Policy Areas

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The Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the inpatient rehabilitation facility prospective payment system (IRF PPS) for fiscal year (FY) 2020.

Some of the key proposals in the rule include:

  • Net Payments: Net payments for IRF’s would increase by 2.3 percent, including a 3.0 percent market basket update, offset by a statutorily mandated cut of 0.5 percentage points for productivity, and a 0.2 percent decrease in outlier payments. This update reflects the proposed revision and rebasing of the market basket using data from 2016 as the base year instead of 2012.
  • Case-Mix Revisions: The Functional Independence Measure (FIM) and Functional Modifier items were removed from the IRF Patient Assessment Instrument (PAI) as finalized in the FY 2019 IRF PPS final rule. CMS also indicated that the FY 2020 case-mix groups (CMGs) would be based on a patient’s motor function, age, memory function, and communication function. However, in this proposed rule CMS made the decision not to include the communication and memory scores because their inclusion in the CMG definitions resulted in lower payments for patients with cognitive deficits (based on their analysis of two years of data).
  • Outlier Threshold and Cost-to-Charge Ratio: CMS proposes to update the outlier threshold amount from $9,402 for FY 2019 to $9,935 for FY 2020 to ensure outlier payments account for 3 percent of total payments, as they did for FY 2019. CMS notes that its initial analysis showed that outlier payments would be 3.2 percent and made the above proposed adjustment to maintain it at 3 percent.
  • Rehabilitation Physician Definition: CMS proposes to clarify that compliance with the regulatory definition of “rehabilitation physician” (a licensed physician with specialized training and experience in inpatient rehabilitation) will be determined by the IRF. Currently, the regulations do not specify the level or type of training or experience that are required to satisfy this criteria.
  • Proposed Changes to IRF Quality Reporting Program (QRP): CMS proposes to adopt two measures to the IRF QRP with data collection for discharges beginning October 1, 2020.
  • Transfer of Health Information to the Provider
  • Transfer of Health Information to the Patient

Transfer of Health Information is a required domain of the IMPACT Act and CMS has been developing these measures since 2016. The measures are process-based measures that assess if a “current reconciled medication list” is given to either the subsequent provider or to the patient/family/caregiver when the patient is discharged or transferred from his or her current PAC setting. CMS proposes to start collecting the measure via the IRF-PAI for discharges beginning October 1, 2020.

  • Proposed Revision to Discharge to Community Measure: CMS proposes to revise the Discharge to Community post-acute care measure to exclude baseline nursing facility (NF) residents from the measures beginning with the FY 2020 IRF QRP due to stakeholder recommendations.

CMS proposes to define baseline NF residents as those who had a long-term NF stay in the 180 days preceding their hospitalization and IRF stay.

  • Proposed Standard Patient Assessment Data Elements (SPADEs): This proposal is slated for reporting beginning in October 2020. In line with the IMPACT Act, CMS is required to develop and collect standardized patient assessment data in PAC settings. In this rule, CMS proposes to adopt ”many of” the standardized patient assessment data elements (SPADEs) it had previously proposed in the FY 2018 IRF PPS proposed rule, as well adopt new SPADEs on social determinants of health. Some proposed items, such as the Brief Interview of Mental Status (BIMS), are currently on the IRF-PAI, in which case CMS is proposing to formally adopt them as SPADEs. However, most of the proposed items would entail adding new, additional reporting elements to the IRF-PAI.
  • Proposal to Collect All-Payer IRF PAI Data: CMS proposes to expand the reporting of the IRF-PAI data to include data on all patients, regardless of their payer, beginning with patients discharged on or after October 1, 2020.

The proposed rule will be published in the April 24, 2019 edition of the Federal Register. Comments on the provisions contained in the proposed rule will be accepted until June 17, 2019. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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ODP Announcement 19-046 provides information regarding upcoming training available to people with disabilities, family members, and other stakeholders (SCs Provider staff, AEs, organizational leadership). Person Centered Thinking is a core concept at the foundation of the services and supports provided to people with intellectual disabilities and autism in Pennsylvania. The above-mentioned individuals/groups are invited to come and learn about Person Centered Thinking and how it can be used to enhance the quality of life of the people we support.

This interactive, two-day training serves as a foundation for everyone involved in supporting people with significant disabilities. During this training, attendees will have the opportunity to develop their skills by completing a series of guided exercises. Participants will practice utilizing person-centered thinking resources and techniques. Information gathered using these skills can help teams develop meaningful Individual Support Plans (ISPs) that help people with disabilities achieve an Everyday Life.

All training sessions will be held from 9:00 am to 4:00 pm. Registration will begin at 8:30 am. Breakfast and lunch will not be provided.

The first trainings will be held Friday, May 17 and Friday, May 31, 2019 at the Intellectual disAbility Services in Philadelphia, as well as Monday, June 10 and Tuesday, June 11 at PaTTAN in Harrisburg. Additional sessions are being planned for the 2019/20 fiscal year. As soon as registration is open for these additional sessions, another announcement will be sent out. If you have any questions about this training opportunity, please submit them via email.

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The next Community HealthChoices (CHC) Third Thursday webinar has been scheduled for April 18, 2019 at 1:30 pm.

The agenda for this webinar will include Office of Long-Term Living (OLTL) Deputy Secretary Kevin Hancock providing updates on the CHC launch, with a special focus on monitoring report data from both the Southwest and Southeast regions.

If you wish to participate in the webinar, you must register using this link. After registering, you will receive a confirmation email containing information about joining the webinar.

If you require captioning services, please use this link and use the following login information:
Username: OLL  Password: OLL

Reminder: All CHC related information can be found online here. Comments can be submitted electronically via email.

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

RCPA is pleased to announce the hiring of James (Jim) Sharp as the new director for its Children’s Division. Jim brings 30 years of systems expertise to RCPA; most recently working for Merakey in several key positions, including Executive Director of Operations for Pennsylvania, Delaware, & Maryland; Executive Director of Behavioral Services and Development; and as the Regional Executive Director for NHS Northwestern Academy. Prior to his work at Merakey, Jim served as the Chief Juvenile Probation Officer at the Philadelphia Family Court Juvenile Probation, the nation’s fourth largest juvenile probation department. In his tenure as Chief P.O., he aided in the implementation of national and statewide models for violence prevention, aftercare reintegration, and juvenile drug and graduated sanctions courts.

Jim began his career as a juvenile probation officer in Montgomery County before joining George Junior Republic as Court Liaison and Admissions Director.

In addition to his bachelor’s degree from Mount Saint Mary’s University, he holds a Master of Administration, and graduated Magna Cum Laude from Shippensburg University.

Jim will begin in this position on May 13. Please join us in welcoming Jim to RCPA!

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RCPA is recognizing Mental Health Awareness Days.

Monday, May 6, 2:30 pm to 3:30 pm, Pennsylvania State Capitol Rotunda, Harrisburg, PA, guest speakers including:

  • Teresa Miller, Secretary of the Pennsylvania Department of Human Services;
  • Ruth Fox, CEO of Allegheny Family Network;
  • Kaitlyn Arrow, a 17-year-old experienced speaker; and
  • Donnell Brown, adult in recovery

At this time, the Dennis Marion Award for Service will be given.

Wednesday, May 8, 9:00 am to 1:00 pm, Strawberry Square, Harrisburg, PA, over 40 vendors will be present to discuss services that are available to young people, their families, professionals, and service professionals.

See here for more information.

Registration is now open for the upcoming Community HealthChoices (CHC) Educational Provider Sessions for Phase three regions of the state. The locations for each region are available on the RSVP pages through the links below.

Additionally, one day-long transportation summit will be held in each region. RSVP for this summit here.

The agenda for each summit is as follows:

  • Registration: 8:30 am – 9:30 am
  • CHC Overview Presentation: 9:30 am – 12:00 pm
  • Lunch/MCO Meet and Greet: 12:00 pm – 1:30 pm
  • Breakout sessions: 1:30 pm – 3:30 pm

Prior to the summit meetings, emails will be sent to attendees regarding schedule, parking, and event location on each campus. Additionally, there is a CHC Questions and Answers (Q&A) document on the CHC website as a resource for additional questions.

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In 2004, the Office of Mental Health and Substance Abuse Services (OMHSAS) Advisory Committee formed a Recovery Workgroup, tasked to explore how to transition the adult mental health system in Pennsylvania into a more recovery-oriented approach. The Recovery Workgroup was convened, by invitation, to discuss the process of developing a blueprint for building a recovery-oriented service system in Pennsylvania. This collaboration of broad-based stakeholders resulted in A Call for Change, a document that would outline a destination for Systems Transformation and provide guidance on strategies for how to get there.

Because A Call for Change focused on transforming the adult-serving behavioral health system, in 2010, the OMHSAS Children’s Bureau proceeded with developing a document to guide transformation of the child-serving system to one that promotes resiliency for children, youth, and their families.  A Call for Change: Transformation of the Children’s Behavioral Health System in Pennsylvania was drafted as a strategic plan, identifying an ideal array of services, goals, and prioritized action steps to achieve systems change.

Several years have passed since these documents were developed.  In the Fall of 2018, the OMHSAS Mental Health Planning Council challenged OMHSAS to re-visit A Call for Change, to assess how far Pennsylvania’s  behavioral health system that serves children, youth, and their families, as well as adults and older adults, has progressed with transformation, and to identify priorities for future efforts.  OMHSAS agreed to support the assessment of progress and the issuance of A Call for Change, 2019.

The assessment phase will include regional on-site listening sessions, intended to generate broad-based stakeholder input and dialogue.  The schedule for the regional listening sessions is available here with newly scheduled options and rescheduled dates for the Southeast Region.  In addition, OMHSAS is posting an online survey to obtain input from stakeholders who are unable to attend a session. The survey can be accessed at through May 1, 2019 at this link.

Any questions or comments related to the Call for Change Project can be directed here.

ODP Announcement 19-044 serves to communicate the process for Administrative Entities (AEs) to validate that new Provider Applicants have satisfied all Provider Qualification requirements effective April 1, 2019. (Announcement 084-18 Revised Qualification Process for New Providers will become obsolete as of the date of this publication.)

In order to become a qualified provider of Consolidated, P/FDS and Community Living Waivers, applicants must complete ODP Provider Qualification Form DP 1059 and submit required provider qualification documentation designated for new provider applicants. CEOs of provider applicants must successfully complete ODP Provider Orientation training, which includes pre-registration module webcasts and a full day face-to-face classroom session. Upon completion of each training component, the CEO must pass a post-test to earn and be issued a Certificate of Achievement.

New Provider Process flowchart and process step tools for licensed and unlicensed services are available for provider applicants on MyODP. New provider applicants must review all source documents referenced within ODP’s New Provider Self-Assessment Tool. While completing the tool, the provider applicant shall ensure that all policies, procedures, processes, and/or protocols are developed and aligned with ODP requirements. The Assigned Administrative Entity (AE) will validate the documentation that applicants submit with the New Provider Self-Assessment Tool. The Assigned AE is the AE within the county where the provider applicant intends to serve the most individuals.

CEOs of new provider applicants must sign the ODP Waiver Provider Agreement (available on the HCSIS homepage) and submit via email. ODP will return the agreement with a stamp of approval in the upper right corner of the front page. If further information is required, the provider will be notified. Likewise, if a provider is not approved, they will receive written notice.

New provider applicants wishing to be qualified for Residential Habilitation, Lifesharing, and Supported Living are required to earn and submit a Certificate of Completion for the ODP Dual Diagnoses Training available on MyODP to their Assigned AE with other required documentation. This training must be completed by the CEO of the provider applicant.

All required documentation and timeframes are outlined in ODP Announcement 19-044. The provider must register their services in HCSIS (see HCSIS Tip Sheet) and may begin to provide qualified services only after an AE has authorized it to do so in an Individual Support Plan.

ODP Announcement 19-045 is to inform all interested parties that the Office of Developmental Programs (ODP) has reorganized and updated employment-related materials on the MyODP platform. Resources, communications, and training materials related to employment are categorized by individuals and families per waiver or program, as well as by provider roles in the service system.

The employment page can be found under the “Resources” tab on the MyODP home page. ODP will update material on the web page as it continues its efforts, in accordance with the Employment First Act (62 P.S. §§ 3401-3409), to help individuals obtain competitive integrated employment.

Additionally, ODP released a second update to the Employment Service Definition Quick Guide for Intellectual Disability/Autism Waivers and Base-funded Participants originally released as part of Announcement 19-025.  Please use this updated guide in place of other versions. Questions about this announcement can be forwarded via email.