Medical Rehab

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The Energy and Commerce (E&C) Health Subcommittee has scheduled a hearing for Thursday, July 26, 2018 at 10:00 am. The hearing is entitled MACRA and MIPS: An Update on the Merit-based Incentive Payment System. This will be the fourth oversight hearing on the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. Members of the Subcommittee will hear from witnesses on the importance of fee-for-service as an option for certain physicians in the traditional Medicare and how the Merit-based Incentive Payment System (MIPS) has acted as a way to streamline quality programs, provided new financial opportunities for providers to participate and transition to new models of care. The witness list and testimony for the hearing will be posted to the E&C website as they are received. The hearing webcast will also be available. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with any questions.

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It has been reported that the Centers for Medicare and Medicaid Services (CMS) has issued letters of non-compliance to Inpatient Rehabilitation Facilities (IRFs) specific to the IRF quality reporting program (QRP) requirements for the data collection period affecting federal fiscal year (FFY) 2019 reimbursement. IRFs that did not meet the IRF QRP reporting requirements will receive a two percent payment reduction on their IRF prospective payment system (PPS) annual increase factor in FY 2019.

IRFs found to be non-compliant should have received notification from their Medicare Administrative Contractor (MAC) and are also expected to receive a letter in their provider Certification and Survey Provider Enhanced Reporting (CASPER) folder with specific details regarding the missing quality reporting data. Additional information on the data collections requirements and submission timeframes for FY 2019 compliance determination can be found in the CMS Data Collection & Final Submissions table posted on the CMS website, as well as the CMS IRF QRP website.

IRFs that feel they have received a non-compliance notification letter in error may request CMS reconsideration of the decision. Providers have 30 days to file a reconsideration request. Detailed filing instructions can be found on the IRF Quality Reporting Reconsideration and Exception & Extension web page.

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The Centers for Medicare and Medicaid Services (CMS) recently announced the launch of their first Data Element Library (DEL). The DEL is the centralized resource for CMS assessment instrument data elements (e.g. questions and responses) and their associated health information technology standards. This free centralized resource will allow the public, for the first time, to view the specific types of data that CMS requires post-acute care facilities (such as inpatient rehabilitation facilities) to collect as part of the health assessment of their patients. Standardized and interoperable data support health information exchange across health care settings to facilitate care coordination, improved health outcomes, and reduced provider burden through the reuse of appropriate health care data.

The assessment items included in the DEL originate from the following:

  • Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI);
  • Long-Term Care Hospital Continuity Assessment Record & Evaluation (CARE) Data Set;
  • Resident Assessment Instrument (RAI) Minimum Data Set (MDS);
  • Outcome and Assessment Information Set (OASIS);
  • Hospice Item Set (HIS); and
  • Functional Assessment Standardized Items (FASI) (In Progress).

Contact Melissa Dehoff with any questions.

In preparation for the launch of Community HealthChoices (CHC) in the Southeast region, this CHC Fact Sheet explains the delivery of service coordination through the program. Under CHC, service coordination is a function of the managed care organizations (MCOs). A service coordinator is the MCO’s designated, accountable point-of-contact for each participant receiving long-term care services, their person-centered service plan, and service coordination. Therefore, the Office of Long-Term Living (OLTL) sees the service coordinators as part of the MCO under CHC.

In addition to the fact sheets, there are now short, easily digestible overview trainings on CHC that can be found here in order to increase stakeholder knowledge in anticipation of the Southeast rollout of the program.

To assist stakeholders in finding answers to questions more quickly, all FAQs have been consolidated into a single CHC Questions and Answers Document. The new document is in searchable PDF format and contains a table of contents that allows the user to easily move to different sections within the document.

The CHC Questions and Answers Document can be found on both the Participant and Provider sections of the CHC website by clicking on “View CHC Publications” or by following this link.

CONTACT: If you have any questions, please visit the CHC website or submit comments via email.

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The Centers for Medicare and Medicaid Services (CMS) has scheduled a call on Thursday, June 21, 2018 at 2:00 pm that will focus on and provide additional information about the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. During the call, CMS will answer frequently asked questions (FAQs) on quality measures, standardized data elements, the CMS data element library, and future directions of the IMPACT Act. Members that wish to participate in the call must register. Send any questions or request assistance with registration via email.

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The Centers for Medicare and Medicaid Services (CMS) has posted a number of various inpatient rehabilitation facility patient assessment instrument (IRF PAI) resources to their website, including the RTI International Report on patient assessment data elements.

Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Proposed Rule for FY 2019: Reminder: Comments are due by June 26, 2018. See May 4, 2018 RCPA Info for additional information on the proposed provisions.

PROPOSED IRF-PAI Version 3.0: The proposed assessment tool indicates an effective date of October 1, 2019. However, the fiscal year (FY) 2019 IRF prospective payment system (PPS) proposed rule indicates it will be effective in FY 2020.

Change Table: Proposed IRF-PAI Version 3.0 – Effective October 1, 2019 (FY 2020) – Changes from Version 2.0 to 3.0: This table highlights the differences between the IRF PAI Version 3.0 and IRF PAI Version 2.0.

RTI International Report: Analyses to Inform the Potential Use of Standardized Patient Assessment Data Elements in the Inpatient Rehabilitation Facility Prospective Payment System: This report includes a summary by RTI on the use of  assessment data in the current IRF PPS and describes the process used to substitute data from the quality indicators sections of the IRF PA into the IRF PPS. The report also presents the case-mix groups (CMGs) and payment weights based on those elements that CMS proposes for FY 2020.

Contact Melissa Dehoff with questions.

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The Centers for Medicare and Medicaid Services (CMS) released the display copy of the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

Key highlights from the proposed rule:

  • Proposed Removal of FIM: Being the most significant proposal, CMS proposes to remove the Functional Independence Measure (FIM) instrument, as well as the associated Functional Modifiers, from the IRF Patient Assessment Instrument (PAI).
  • Changes to the IRF Coverage Requirements: There are several proposed changes to the coverage requirements:
    • Post-Admission Physician Evaluation: CMS is proposing allowing the post-admission physician evaluation to count towards one of the required three weekly face-to-face physician visits.
    • Physician Attendance at Interdisciplinary Team Meeting: CMS is proposing to amend the regulations to allow the rehabilitation physician leading the required interdisciplinary team meeting to attend the meeting remotely (via video conference or teleconference).
    • Admission Order Documentation Requirement: CMS is proposing to remove the requirement that there be a physician order for inpatient care when the patient is admitted since this requirement is included under the Medicare Conditions of Participation (CoPs) regulations.
    • Requests for Information on Physician Requirements: CMS is seeking information on specific areas where they can alleviate burden through changes to requirements pertaining to physician supervision in an IRF. CMS is also seeking information on the use of non-physician practitioners (NPPs) in IRFs.
  • Proposed Changes to IRF QRP – CMS is proposing to remove two measures from the IRF Quality Reporting Program (QRP):
    • National Healthcare Safety Network (NHSN) Facility-wide Inpatient Hospital-onset Methicillin-resistant Staphylococcus Aureus (MRSA) Bacteremia Outcome Measure (NQF #1716); and
    • Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short Stay) (NQF #0680).
  • Display of Functional Outcomes Measures Data on IRF Compare: CMS proposes to begin publicly displaying data on the following assessment-based measures in calendar year (CY) 2020 on IRF Compare:
    • Change in Self-Care (NQF: #2633);
    • Change in Mobility Score (NQF: #2634);
    • Discharge Self-Care Score (NQF: #2635); and
    • Discharge Mobility Score (NQF: #2636)

CMS has published a fact sheet that provides additional information on the proposed rule. The proposed rule will be published in the May 8, 2018 Federal Register, with comments being due by June 26, 2018.

The Department of Health and Human Services (HHS) has committed to improving the Medicare claims appeals process. This commitment includes the internal implementation of an expanded Settlement Conference Facilitation (SCF) program by the Office of Medicare Hearings and Appeals (OMHA). SCF is an alternative dispute resolution process at OMHA that gives certain providers and suppliers an opportunity to resolve their eligible Part A and Part B appeals.


In order to educate all Medicare Part A and Medicare Part B providers and suppliers who have OMHA or Medicare Appeals Council appeals pending, an SCF Expansion Open Door Call will be held on Tuesday, May 22, 2018 at 1:30 pm. The call will focus on the logistics of the SCF process and SCF eligibility criteria. Providers that plan to join the call are encouraged to submit their questions in advance via email and include “SCF May 22 Call” in the subject line. To participate, registration is required. Additionally, providers are encouraged to read the updated SCF expansion materials, including an SCF Expansion Frequently Asked Questions document, on the website.

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The Centers for Medicare and Medicaid Services (CMS) issued revised Change Request (CR) 10531 (MLN Matters Number: 10531). The article, “Claims Processing Actions to Implement Certain Provisions of the Bipartisan Budget Act of 2018,” was revised and provides direction to Medicare Administrative Contractors (MACs) to reprocess claims related to several provisions of the Bipartisan Budget Act of 2018. The initial MLN article was released on March 26, 2018.

On February 9, 2018, Congress passed the Bipartisan Budget Act of 2018, which contains a number of provisions that extend certain Medicare Fee For Service (FFS) policies, including Ambulance add-on payment provisions and a three percent home health Rural Add-on Payment. In addition, the Act permanently repeals the outpatient therapy caps beginning on January 1, 2018, while retaining the requirement to submit the KX modifier for services in excess of the prior cap amounts. Due to the retroactive effective dates of these provisions, various Medicare FFS claims shall be reprocessed. This CR provides guidance to MACs regarding Medicare FFS claims reprocessing requirements and time frames.

Join RCPA as it hosts its 2018 conference October 2 – 4 at the Hershey Lodge. The Conference Committee is excited to release this year’s Sponsors, Exhibitors, and Advertisers brochure, with new opportunities to get in on the action – from exhibit hall to an awards luncheon and everything in between.

Don’t miss your chance to be seen and to support the work of this dynamic organization! The event is a highlight for the Pennsylvania mental health, drug and alcohol, intellectual and developmental disabilities, children’s, brain injury, medical rehabilitation, and physical disabilities and aging provider community.

Benefits for Exhibitors
Exhibit activities take place October 3 – 4. Based on your feedback last year, we have increased the length of time exhibit hall is open and the number of activities offered. RCPA encourages all interested parties to complete the contract now! Events within Exhibit Hall include two lunch meals, a reception, breakfast, coffee breaks, and prize giveaways. Exhibit hours occur during the two busiest days of the conference, increasing the likelihood that exhibitors – an integral component to conference success – have the opportunity to interact with attendees. A “Best of Show” competition provides even more opportunities to engage guests and winners receive a discount on 2019 exhibit rates.

Interaction with conference guests outside of the exhibit area is just as important! Participating in other conference events such as receptions, meals, and educational offerings provides exhibitors greater potential and flexibility to establish opportunities for business. RCPA includes two exhibitor registrations with the exhibit fee; and since exhibitors can attend the entire conference, RCPA encourages organizations to use those registrations fully.

Exciting New Sponsorship Opportunities
The association is privileged to have the backing of the finest organizations in the field for its conference. Through the use of sponsorship circles, RCPA is able to honor all supporting organizations. Within each sponsorship circle, specific events and items such as meals, receptions, conference tote bags, attendee materials, etc. are available, providing additional “name recognition” for sponsors. Please review sponsorship materials and contact Sarah Eyster to reserve your opportunity.

Sign Up Now
The deadline for inclusion in all digital materials is July 31. Sponsors, exhibitors, and advertisers who wish to be listed on the website, the mobile app, and in the online conference program must adhere to that deadline.

The association looks forward to welcoming you at the conference! Space and opportunities are reserved on a first come, first-served basis and no reservation is considered complete without payment. For additional questions, please contact Sarah Eyster, Conference Coordinator.