Medical Rehab

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On November 13, 2017, the Centers for Medicare and Medicaid Services (CMS) began to post a list of potential audits for Recovery Audit Contractors (RACs) to review. The topics will be listed, on a monthly basis, on the Provider Resources page of the CMS website. The topics currently proposed include: review of pre-admission screening, post-admission examination, and other requirements for inpatient rehabilitation facility (IRF) stays. The review type is identified as a “complex review.” Comments or questions should be submitted via email.

Executive Order to Review State Licensure Board Requirements & Processes

In the November 11, 2017 Pennsylvania Bulletin, Governor Wolf issued an Executive Order (No. 2017-03) that directs the Commissioner of Professional and Occupational Affairs within the Department of State to conduct a review of the State Professional and Occupational Licensure board requirements and processes. This includes a comprehensive review of the processes, fees, training, and continuing education requirements and prepared report for each type of professional and occupational license. The report is to include: training requirements; licensing, registration, and renewal fees; continuing education requirements; and any other requirements described within the executive order. The report is to also include information regarding the number of other states which require a license for each professional or occupational license, the national and regional averages for training requirements, fees, and continuing education requirements.

The Commissioner has been given the authority to establish an advisory group to assist with the research, data collection, and formatting of the reports, and any other function the Commissioner deems necessary. The advisory group shall be composed of members chosen by the Commissioner from the professional Boards and Commissions, Bureau of Professional and Occupational Affairs (BPOA) staff, and any other persons the Commissioner deems necessary. The advisory group must be established within 30 days from the effective date of this executive order. Additional details regarding the report are provided in the bulletin.

The report is due to the Governor, the Secretary of Policy and Planning, and the Secretary of the Commonwealth no later than 180 days from the establishment of the advisory group or 210 days from the effective date of this executive order, whichever is sooner.

Some of the boards impacted by this executive order include: State Board of Physical Therapy, State Board of Speech–Language Pathology and Audiology, the State Board of Medicine, the State Board of Nursing, the State Board of Occupational Therapy, etc.

The executive order is effective immediately.

On November 3, 2017, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2018 Medicare Physician Fee Schedule final rule. The proposed rule updates payment policies, payment rates, and quality provisions for services with an overall payment update of .41 percent.

Some of the key provisions finalized in the rule include:

  • Addition of several codes to the list of telehealth services, eliminating the required reporting of the telehealth modifier GT for professional claims in an effort to reduce administrative burden for practitioners, and separating payment for CPT code 99091, which describes certain remote patient monitoring, for 2018;
  • Adoption of CPT codes for CY 2018 for reporting several care management services currently reported using Medicare G-codes and clarifying a few policies regarding chronic care management;
  • Increase in payment rates for office-based behavioral health services that better recognizes overhead expenses for office-based face-to-face services with a patient;
  • Revision of Part B drug payments for infusion drugs furnished through an item of durable medical equipment (DME) to conform with requirements of the 21st Century Cures Act;
  • Revision of payment for chronic care management in Rural Health Clinics (RHCs) and Federally-Qualified Health Centers (FQHCs), and establishing requirements and payment for RHCs and FQHCs furnishing general behavioral health integration (BHI) services and psychiatric collaborative care model (CoCM) services;
  • Implementation of the Medicare Diabetes Prevention Program (MDPP) expanded model starting in 2018;
  • Change to the current Physician Quality Reporting System (PQRS) program policy that requires reporting of 9 measures across 3 National Quality Strategy domains to only require reporting of 6 measures for the PQRS with no domain requirement; and
  • Revision to the rules for accountable care organizations (ACOs) participating in the Medicare Shared Savings Program to reduce burden and streamline program operations.

In addition, CMS indicated they will continue to consider the following based on comments from stakeholders:

  • Stakeholder input in response to the proposed rule’s comment solicitation on how CMS could expand access to telehealth services, within the current statutory authority;
  • Reviewing and updating “outdated” Evaluation and Management (E/M) visit codes; and
  • Reviewing stakeholders’ comments for potential future rulemaking or publication of sub-regulatory guidance pertaining to the Clinical Laboratory Fee Schedule (CLFS) data collection and reporting periods.

The final rule will be published in the November 15, 2017 Federal Register.

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The inpatient rehabilitation facility (IRF) quality reporting program (QRP) submission deadline is coming up on Wednesday, November 15, 2017. The submission deadline includes both the IRF patient assessment instrument (PAI) assessment data and the IRF data that is submitted to the Centers for Medicare and Medicaid Services (CMS) via the Center for Disease Control and Prevention’s (CDC) National Healthcare Safety Network (NHSN) for discharges. Providers are encouraged to run validation/output reports prior to each quarterly reporting deadline to ensure all required data is submitted. The list of required measures are posted on the IRF Quality Reporting Data Submission Deadlines web page.

The Energy & Commerce House Health Subcommittee scheduled a hearing for Wednesday, November 8, 2017, at 10:00 am in room 2123 of the Rayburn House Office Building. The hearing will focus on the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 and Alternative Payment Models: Developing Options for Value-based Care.

Members of the subcommittee will discuss alternative payment models (APMs) and hear from those that are already engaged in the transition to value-based care, as well as those developing new models and stakeholders who are already delivering improved outcomes and savings for Medicare beneficiaries and taxpayers.

The Majority Memorandum, witness list, and witness testimony for the hearing will be available here as they are posted.

On October 26, 2017, the Energy & Commerce Committee and the Ways and Means Committee announced in a press release that they have come to a policy agreement on a permanent repeal of the Medicare therapy caps. The policy/discussion draft will repeal the therapy caps, continue to require an appropriate modifier is included on claims submitted over the new threshold (indicating the services are medically necessary), and continue targeted medical review of claims established by the Medicare Access and CHIP Reauthorization Act (MACRA).

Background:
In 2006, Congress created an exceptions process allowing patients to exceed the cap based on medical necessity. The cap was addressed most recently in 2015 with MACRA (H.R. 2), becoming law. A provision in H.R. 2 established targeted medical review of therapy caps and extended the therapy cap exceptions process until January 1, 2018.

Please mark your calendars! The upcoming RCPA Brain Injury Committee meeting, originally scheduled for November 15, 2017, has been rescheduled to December 6, 2017. The meeting will take place at its regularly scheduled time (10:00 am – 2:00 pm) and location (RCPA 777 East Park Drive, Harrisburg, PA  17111). A formal meeting invitation will be forthcoming in early November. Questions regarding this change can be sent to Melissa Dehoff.

The Department of Human Services (DHS) recently issued the following information and resources in preparation for the roll-out of Community HealthChoices (CHC) beginning January 2018 in the Southwest zone of the state.

Coming to the Southwest Zone in January 2018

The Department of Human Services (DHS) is committed to open and frequent communication to educate and inform individuals who will move to Community HealthChoices (CHC). It is critical that they are aware of the upcoming changes and are able to make an informed decision on their plan selection. We are using multiple channels to get the message out, and want to ensure that you are aware of upcoming information that potential participants will receive.

  • INFORMATIONAL FLYER

Participants in the Southwest Zone received this flyer (also available in Spanish) in August 2017 to inform them that CHC was coming to their county in January 2018.

  • CHC Community Meetings for Participants

Participants in the Southwest will receive an invitation to community meetings in late September.

There will be more than 40 events in the Southwest Zone, with at least one in each of the 14 impacted counties. The meetings will give more information about CHC, the LIFE program, and answer questions participants may have.

To register for a community meeting, participants can go to www.healthchoices.pa.gov or call 1-833-735-4416. A copy of the invitation is available here.

  • Notices

DHS will mail notices to potential participants beginning today. The notice will inform participants that they will transition to CHC in January and will need to select a health plan, also called a managed care organization (MCO).

The notice also tells potentially eligible participants that they may be eligible for the LIFE program.

Copies of the notices are be available here.

  • Pre-Enrollment Packets

Beginning on October 2, 2017, pre-enrollment packets will be mailed to participants. This packet will contain information about each of the health plans and the benefits offered by each plan, and tell participants how to enroll in a health plan. There will be a toll-free number and website for participants to use to make their selection. A day after the packets are mailed, automated calls will be made to let participants know that the packets are coming.

If participants do not select a health plan, they will get a follow-up call.

Individuals who do not select a plan by November 13, 2017, will be assigned to a plan. Individuals can change their plan at any time.

  • Social Media

DHS’ Facebook, Twitter, and YouTube accounts make CHC information readily available. If you are not following us yet, please click the provided links to make sure you are receiving all up-to-date information on CHC and all department priorities.

chc-phases-map

(Map, Community HealthChoices Phases)

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The Department of Human Services (DHS) published a notice that will appear in tomorrow’s Pennsylvania Bulletin that they intend to make a supplemental payment in fiscal year (FY) 2017/2018 to certain special rehabilitation facilities (SRFs) that have high Medical Assistance (MA) and total facility occupancy levels. An SRF is one that specializes in providing services and care to adults who have a neurological/neuromuscular diagnosis and condition, as well as severe functional limitations. Because of the complex needs of these individuals, SRF’s typically incur staffing and specialized medical equipment costs that are very high. Additionally, SRF’s with high MA and total facility occupancy levels are dependent on MA payments to continue to operate. To help offset the higher costs incurred by these SRFs while they reconfigure to home and community-based services, DHS intends to make a supplemental payment to these facilities to assure that the unique services they provide continue to be available to MA beneficiaries.

To qualify for an MA dependency payment the following requirements must be met:

  • Be classified as an SRF as of the cost report end date.
  • Have MA occupancy greater than or equal to 94% as reported on Schedule A, Column A, Line 5 of the cost report.
  • Have an overall nursing facility occupancy greater than or equal to 95% as reported on Schedule A, Column A, Line 4 of the cost report.
  • Have at least 200 MA certified nursing facility beds as of the cost report end date.

DHS will accept comments on this notice for thirty days following publication. Comments should be sent to: Department of Human Services, Office of Long-Term Living, Bureau of Policy and Regulatory Management, Attention: Marilyn Yocum, PO Box 8025, Harrisburg, PA 17105-8025.