Medical Rehab

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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.

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Registration is now open for providers interested in attending a free two-day, in person training session on the inpatient rehabilitation facility quality reporting program (IRF QRP). The session, scheduled for Wednesday, May 9 –  Thursday, May 10, 2018 in Baltimore, MD will be hosted by the Centers for Medicare and Medicaid Services (CMS).

The primary focus of this “Train-the-Trainer” event will be to provide those responsible for training staff at IRFs with information about IRF QRP changes and updates to the Inpatient Rehabilitation Facility–Patient Assessment Instrument (IRF-PAI) v. 2.00, effective October 1, 2018. Topics will include information on new items, including those associated with the drug regimen review quality measure. Presenters will also discuss resources available on the CMS website, support available through the IRF help desks, public reporting, and use of reports to aid providers in better understanding the IRF QRP.

Additional information, including the registration page and agenda, is posted on the CMS website. Interested providers are encouraged to register as soon as possible as the in-person training is limited to the first 200 people on a first-come, first-served basis.

The training will not be available via webcast, but will be available via a link from the IRF QRP training web page after the training has completed.

The Pennsylvania Department of Health (DOH) has created a brain injury identification wallet card. The card was created as a result of a telephone call from an individual with a brain injury who moved from another state. The individual was inquiring as to whether PA had a card that could be used in emergent situations that would easily identify him as having a brain injury and his symptoms. The wallet card is available on the DOH website. The intent of the card is to provide a document for individuals with a brain injury that could be used to communicate their symptoms and emergency information to emergency personnel or the public.

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Today, the Centers for Medicare and Medicaid Services (CMS) released the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) transfer of health measures for public review and comment. CMS contracted with the RTI International and Abt Associates to develop cross-setting post-acute care transfer of health information and care preferences quality measures in alignment with the IMPACT Act.

As part of its measure development process, CMS is requesting comments on two draft measure specifications, including:

  1. Medication Profile Transferred to Provider
  2. Medication Profile Transferred to Patient

Additional information is provided on the public comment page on the CMS website. The public comment period closes on May 3, 2018.

On March 9, 2018, Representative Tina Pickett introduced House Resolution 741 designating the month of March 2018 as “Brain Injury Awareness Month” in Pennsylvania. The resolution was adopted (188–0) on March 14, 2018. A similar co-sponsorship memo was introduced in the Senate by Senator Schwank and will be voted on in the near future. March is nationally recognized as Brain Injury Awareness Month as well.

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.