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Medical Rehab

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On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.

If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:

Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.

RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:

Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the ‎reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.

Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following ‎information:‎

  • A copy of the CMS non-compliance letter;
  • A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of ‎calendar year 2024; and
  • If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the ‎monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract ‎Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among ‎Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.

The Bureau of Human Services Licensing (BHSL) has received a small number of reports of issues with faxing the updated Documentation of Medical Evaluation (DME) forms. These reports indicate that some fax machines cannot pick up the contrast in the grey shaded areas. You will find both DME forms with the grey areas lightened significantly. These forms are also being added to the BHSL website.

Please note, BHSL has fax-tested both versions of these forms and did not encounter any issues. Issues with faxing may be related to the age/condition or settings of individual fax machines. Online faxing services that do not require the use of a fax machine are widely available, as are alternative methods of form transmission, such as in-person drop off, email, online drop boxes, or the United States Postal Service.

Questions about this communication may be sent electronically.

RCPA’s 2025 Conference Strive to Thrive will be held in Hershey September 9 – 12, 2025. Early bird rates for registration end August 8! Be sure to register today and take advantage of the early bird rates!

RCPA is proud to host those who lead PA in health and human services at our Annual Conference. This year, DHS Secretary Valerie Arkoosh will be presenting as our kickoff plenary speaker on September 9. Throughout the week, we will hear updates from various departments and leaders of DHS, including:

  • ODP Deputy Secretary Kristin Ahrens;
  • OLTL Deputy Secretary Juliet Marsala;
  • DDAP Deputy Secretary Kelly Primus; and
  • OMHSAS Deputy Secretary Jennifer Smith.

View our Registration Brochure for complete details of the conference schedule and speakers. You can also register directly here. Be sure to check the RCPA Conference website regularly for details and updates to the schedule, registration, and sponsors/exhibitors.

In addition to registration, there are still many opportunities available for sponsorship and exhibit booths, so don’t delay! We are grateful to all our sponsors and exhibitors who help make the conference happen. If your organization is interested in sponsoring or exhibiting at our conference, all information is available in our Sponsor, Exhibit, and Advertise Brochure. You can contact Carol Ferenz, Conference Coordinator, for more details.

Thank you to our Sponsors and Exhibitors! We thank you for your support!

The Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS/ASC) proposed rule in the July 17, 2025, Federal Register.

The rule outlines new proposed payment rates and related policies for a wide variety of Medicare providers, including not only physicians but other individual Medicare clinicians, such as physical and occupational therapists, speech-language pathologists, nurse practitioners, and physician assistants.

The proposed CY 2026 OPPS/ASC would implement a 2.4% increase to OPPS payment rates that reflects a market basket update of 3.2%, reduced by a productivity adjustment of 0.8 percentage points.

RCPA will provide a more detailed analysis of the OPPS/ASC proposed rule with a focus on the implications for rehabilitation providers. Additional information can be provided on this OPPS fact sheet.

Comments on the proposed rule are due by September 15, 2025. Members are encouraged to share comments and concerns to Melissa Dehoff by September 8, 2025, to include in RCPA’s comment letter.

Photo by Matt Popovich on Unsplash

FOR IMMEDIATE RELEASE

July 22, 2025

Media Contact: Tpr. Gagliardi / X: @PSPTroopBPIO

Providers with any information are encouraged to contact PSP Washington at 724-223-5200.

Washington, PA – To aid in an ongoing investigation, the Pennsylvania State Police (PSP) Bureau of Criminal Investigation is requesting health care agencies and providers in the state to review their employment records due to an investigation of suspected fraudulent activities involving Shannon Nicole Womack.

Womack is alleged to have used at least 10 aliases to pose as a licensed practical nurse (LPN), registered nurse (RN), and registered nurse supervisor at rehabilitation and nursing home facilities in various regions across Pennsylvania. She is charged with securing the nursing positions through staffing agencies by submitting fraudulently signed documents and also by creating a false LLC to deploy herself to jobs. Reports indicate Womack worked at each of these jobs for only a short time.

The PSP is working with the Department of Health, Department of State, and multiple district attorneys and states in the ongoing investigation.

Investigators confirmed Womack used the following aliases in various parts of the state:

  • Shannon Nicole Parham
  • Shannon Nicole Abiola
  • Shannon Nicole Armstrong
  • Shannon Abiola-Parham
  • Shannon Nicole Grimes
  • Shannon Nicole Womack
  • Shannon Nicole Lawson
  • Shannon Nicole Lethco
  • Shannon Nicole Robinson
  • Shannon Lee Lawson

If any of the names listed above match any employment records at a provider’s facility, they are urged to contact PSP Washington at 724-223-5200.

Womack is charged with Corrupt Organizations, Endangering the Welfare of Care, Unlawful Use of a Computer, Identity Theft, Forgery, Theft by Unlawful Taking, and multiple other charges.

Criminal charges are merely allegations, and all defendants are presumed innocent unless and until proven guilty.

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The Intensive Model of Therapy for Children With Neurological or Movement Disorders

Thursday, September 4, 2025
12:00 pm – 1:00 pm EDT; 11:00 am – 12:00 pm CDT;
10:00 am – 11:00 am MDT; 9:00 am – 10:00 am PDT
Register Here

Presenter Bio: Amy O’Donnell
Amy O’Donnell is a pediatric physical therapist at The Children’s Institute in Pittsburgh, Pennsylvania. She earned her bachelor’s degree from Washington & Jefferson College and her Doctorate in Physical Therapy from the University of Pittsburgh. Amy joined The Children’s Institute in 2012 and has since specialized in pediatric physical therapy care.

Her first exposure to the intensive therapy model came during her student training, and she became actively involved in the program following its expansion to her clinic location in 2014. In 2019, she was named the program coordinator. Amy has co-authored both qualitative and quantitative research articles on the Intensity Program at The Children’s Institute, with both publications appearing in Pediatric Physical Therapy journal.

Objectives: Following this course, the learner will:

  • Define and discuss benefits of episodic care and family centered care;
  • Define and discuss benefits of intensive therapy model; and
  • Discuss different types of intensive therapy models and strategies to implement into your clinic.

Audience: This webinar is intended for all interested members of the rehabilitation team.

Level: Beginner/Intermediate

Certificate of Attendance: Certificates of attendance are available for all attendees. No CEs are provided for this course.

Complimentary webinars are a benefit of membership in IPRC/RCPA. Registration fee for non-members is $179. Not a member yet? Consider joining today.

On July 14, the National MLTSS Health Plan Association submitted comments on the “Preserving Medicaid Funding for Vulnerable Population – Closing a Health Care-Related Tax Loophole” proposed rule. Per the Association:

This rule proposes to refine how CMS evaluates whether a health care-related tax is considered “generally redistributive.”

In our comments, we noted that we appreciate CMS’ efforts to strengthen the oversight and quality of Medicaid programs but raised concerns about the timelines and administrative burden on states, as well as the potential impact on individuals receiving long term-services and supports (LTSS).

The recommendations included:

  • Extending the transition period to three years for all states.
  • Providing clear implementation guidance and technical assistance to states.
  • Postponing finalization of the rule until further research and data analysis on provider-related taxes and impacts are conducted.

Read the full letter here.

In Pennsylvania, this rule would impact participants’ funding of approximately $1B in federal matching funds for HealthChoices, Community HealthChoices, and Behavioral HealthChoices. No immediate action is required. If you have any questions, contact Fady Sahhar.

The Brain Injury Association of America (BIAA) has announced the webinar Acquired Brain Injury (ABI): A Transdisciplinary Approach to Inpatient Rehabilitation, which is scheduled for July 24, 2025, at 3:00 pm.

During this live webinar, a team from the Sheltering Arms Institute will share the inner workings of their transdisciplinary system of care. As it becomes more important than ever for clinicians to work as a transdisciplinary team to provide the best care for patients, the close coordination of care between therapy, nursing, medical staff, psychology, and case management is necessary in order to make the greatest impact.

The live webinar has a fee of $50.00. Those interested can register here.