Medical Rehab

The Administration for Community Living (ACL) recently posted a number of grant opportunities associated with traumatic brain injuries (TBI).

On February 7, 2018, College and Career Success for Students with Serious Mental Illness or Traumatic Brain Injury was posted. The purpose of this grant opportunity is to generate new knowledge about the effectiveness of interventions to improve college education and employment outcomes of people with serious mental illness or traumatic brain injury. The funding for this grant is $475,000 and the closing date for applications is April 9, 2018.

On February 14, 2018, two additional grant opportunities were posted:

Traumatic Brain Injury State Partnership Program Partner State Funding Opportunity, whose purpose is to create and strengthen a system of services and supports that maximizes the independence, well-being, and health of persons with TBI across the lifespan, their families, and their caregivers. Through the TBI State Partnership Program, the goal is two-fold:

  1. To allow states to strengthen and grow their capacity to support and maintain a system of services and supports that will help maximize the independence, well-being, and health of persons with TBI; and
  2. To learn from and call upon the expertise of states that have built and maintained a strong and sophisticated state TBI infrastructure. This grant opportunity has an award ceiling of $150,000.

The Traumatic Brain Injury State Partnership Program Mentor State Funding Opportunity has a purpose to create and strengthen a system of services and supports that maximizes the independence, well-being, and health of persons with TBI across the lifespan, their families, and their caregivers. Through the TBI State Partnership Program, the goal is two-fold:

  1. To help states strengthen and grow their capacity to support and maintain a system of services and supports that will help maximize the independence, well-being, and health of persons with TBI; and
  2. To learn from and call upon the expertise of states that have built and maintained a strong and sophisticated state TBI infrastructure. For the 2018 funding cycle, ACL is funding two tiers of grantees that will work together to maximize the program’s impact nationally.

Partner State Grants will provide funding to states for building and enhancing basic infrastructure, while Mentor State Grants will provide funding to more established states to maintain and expand their infrastructure and also to mentor Partner States and work together with other Mentor States and ACL to improve the national impact of the TBI program. Applicants must agree to provide the required 2:1 state match, support a state TBI advisory board, provide at least one full-time dedicated staff person, create an annual TBI state plan, create and/or expand their state TBI registry, work with one or more Partner States to increase their capacity to provide access to comprehensive and coordinated services for individuals with TBI and their families, and work with other Mentor States and ACL to improve national coordination and collaboration around TBI services and supports.

ACL encourages organizations that are interested and qualify to apply for both funding opportunity announcements; however, ACL will not make more than one award to a single applicant. Applicants that score in the fundable range on both reviews may choose which award they wish to receive. Applicants that are only interested in receiving a Partner State Grant do not need to apply for this opportunity. This grant opportunity has an estimated award ceiling of $300,000. The closing date for both of these grant opportunities is April 16, 2018.

RCPA will be working with the Pennsylvania Department of Health (DOH) to review the grant applications and discuss next steps surrounding these opportunities.

The 2018 RCPA conference will take place October 2–4 (please note new dates) at the Hershey Lodge. A premier statewide event, the Conference Committee is seeking workshop proposals for possible inclusion. This event offers diverse educational opportunities and submissions are needed in every area; a complete listing of focus tracks is available on the online proposal form. Presentations are encouraged that assist providers to develop and maintain quality, stable, and effective treatments, services, and agencies in an industry where change is constant. The committee looks for presentations which:

  • Highlight new policy, research, and treatment initiatives such as the CCBHC model and Centers of Excellence, to name a few;
  • Provide specific skills and information related to individual and organizational leadership development and enhancement;
  • Address system changes that affect business practices such as Community HealthChoices and integrated and co-located care; and
  • Offer concrete skills and tools to operate more efficient and effective agencies, allowing organizations to strive, survive, and thrive.

Workshop ideas beginning to percolate for 2018 include pharmacogenomics; technology as a human resource option; executive leadership; integrated care strategies for implementation and reimbursement; XYZ rate setting; social capital; ethics; sexuality and sexual abuse issues in the intellectual and developmental disabilities (IDD) service area; trauma informed care across service types; emergency planning for community violence; acquisitions/mergers and consolidations; value-based purchasing; abuse and protection in the aging population; emerging leaders. The committee welcomes any proposal that addresses these and other topics essential to the rehabilitation, brain injury, mental health, addiction, aging, children’s, and developmental disability communities. Members are encouraged to consider submitting proposals and to forward this opportunity to those who are exceptionally good speakers and have state-of-the-art information to share.

The Call for Proposals and accompanying guidelines outline requirements for submissions. The deadline for submissions is Friday, March 16 at 5:00 pm. Confirmation of receipt will be sent. Proposals submitted after the deadline will not be considered.

Proposals selected stand out by inclusion of solid learning objectives, information that a participant can use to enhance professional skills or methods, and being geared to a diverse and advanced audience. If the proposal is accepted, individuals must be prepared to present on any day of the conference. Workshops are 90 or 180 minutes in length. At the time of acceptance, presenters will be required to confirm the ability to submit workshop handouts electronically four weeks prior to the conference. Anyone unable to meet this expectation should not submit proposals for consideration.

Individuals are welcome to submit multiple proposals. Notification of inclusion will be made by May 15. Questions may be directed to Sarah Eyster, Conference Coordinator.

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During the January 2018 Medicare Payment Advisory Commission (MedPAC) public meeting, the agenda included the topic of the Merit-based Incentive Payment System (MIPS). MedPAC members voted in favor of recommending Congress eliminate this system, stating the program was burdensome and complex. The presentation also cited that the program “Replicates flaws of prior value-based purchasing programs.” It was recommended that MIPS be replaced with a new model known as the voluntary value program (VVP). The VVP would include an across-the-board withhold for all fee schedule payments, and performance would be assessed using uniform measures across three categories, which include clinical quality, patient experience, and value. Those in favor of the new program indicated it would better prepare physicians to participate in the Medicare Access and CHIP Reauthorization Act’s (MACRA) Advanced Alternative Payment models.

The agenda included many additional topics of interest, some of which referenced increasing the equity of Medicare’s payments within each setting, mandated report on telehealth services and the Medicare program, and a status report on Medicare Accountable Care Organizations.

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On January 9, 2018, the Centers for Medicare and Medicaid Services (CMS) announced their launch of a new voluntary bundled payment model called the Bundled Payments for Care Improvement (BPCI) Advanced. BPCI Advanced will test a new iteration of bundled payments for 32 clinical episodes initially (29 Inpatient Clinical Episodes and 3 Outpatient Clinical Episodes) and will qualify as an advanced alternative payment model (APM) under the quality payment program (QPP). Participants can earn additional payment if all expenditures for a beneficiary’s episode of care are under a spending target that factors in quality.

The Model Performance Period for BPCI Advanced begins on October 1, 2018, and runs through December 31, 2023. For additional information about the model, including the Request for Applications document, application template, etc., visit the BPCI Advanced web page. Applications must be submitted via the application portal. The application portal will close on March 12, 2018.

An open door forum, BPCI Advanced – Model Overview and Application Process, has been scheduled for Tuesday, January 30, 2018, from 12:00 pm – 1:00 pm EST. Registration is now open.

The Department of Defense (DoD) published the final rule, TRICARE; Reimbursement of Long Term Care Hospitals and Inpatient Rehabilitation Facilities, in the December 29, 2017 Federal Register. This final rule finalizes the changes in the inpatient rehabilitation facility (IRF) payments from the proposed rule that was published back in 2016 and establishes TRICARE inpatient care reimbursement methodologies and rates similar to Medicare. Currently, IRFs are exempted from the TRICARE diagnosis related group (DRG) based payment system and paid by TRICARE at the lower of a negotiated rate or billed charges.


To reduce the burden from sudden significant reductions on the IRFs, the final rule includes a gradual transition from TRICARE’s current policy of allowing 100 percent of allowable charges (either the billed charge or voluntary negotiated rate), by phasing-in the Medicare IRF prospective payment system (PPS) rates as follows:

  • Allowing 135 percent of Medicare IRF PPS amounts in the first 12-month period after implementation (estimated reduction of $24M);
  • 115 percent in the second 12-month period after implementation (an estimated reduction of $41M); and
  • 100 percent in the third 12-month period after implementation (an estimated $57M).

The DoD will apply the FY 2019 IRF PPS for purposes of the 12-month period beginning on October 1, 2018, and follow any changes adopted by the Medicare IRF PPS for subsequent years. The provisions in the final rule become effective on March 5, 2018.

On December 11, 2017, the Centers for Medicare and Medicaid Services (CMS) issued Medicare Learning Network (MLN) Matters Article, SE17036, which provides information about new instructions recently issued to Medicare medical review contractors. The guidance also provides the standards to use when reviewing claims for compliance with the intensity of therapy requirements for inpatient rehabilitation facility (IRF) claims.

If you have any questions, please contact your MAC at their toll-free number, available online.

The Department of Human Services has been working in collaboration with Managed Care Organizations (MCOs), county oversight organizations, and RCPA regarding the concerns and challenges with implementing federal Ordering, Referring and Prescribing (ORP) requirements by the January 1, 2018 deadline. The Department of Human Services has informed RCPA of the following:

  • The ORP requirements for Fee-for-Service continue to apply; i.e., allORP practitioners must be enrolled in the Pennsylvania Medical Assistance (MA) Program or the rendering provider will not be paid.
  • In the HealthChoices managed care delivery system, if a rendering network provider submits a claim to an MCO with the National Provider Identifier (NPI) information that results in edits identifying that the non-networkORP is not enrolled in MA, the claim can be paid. However, if the non-MA enrolled ORP has a high volume of claims, the MCO will work with the network provider and non-MA enrolled ORP to have them enroll in MA or work to transition the member to an enrolled MA provider.

Contact your contracting BH-MCO for additional information.

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The Centers for Medicare and Medicaid Services (CMS) published a final rule and interim final rule with comment period that cancels the Episode Payment Models (EPM) and Cardiac Rehabilitation (CR) Incentive Payment Model and rescinds the regulations governing these models in the December 1, 2017 Federal Register. It also implements certain revisions to the Comprehensive Care for Joint Replacement (CJR) model. Some of these revisions include:

  • Allowing certain hospitals selected for participation in the CJR model a one-time option to choose whether to continue their participation in the model;
  • Technical refinements and clarifications for certain payment, reconciliation, and quality provisions; and
  • Change to increase the pool of eligible clinicians that qualify as affiliated practitioners under the Advanced Alternative Payment Model (APM) track.

An interim final rule with comment period is also being issued in conjunction with the final rule in order to address the need for a policy to provide some flexibility in the determination of episode costs for providers located in areas impacted by extreme and uncontrollable circumstances.

Comments will be accepted on the interim final rule with comment period until January 30, 2018. The final and interim final regulations become effective on January 1, 2018.