Policy Areas

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In April, the staff from the Penn State University EPISCenter met with the RCPA Children’s Committee to review the impact, challenges, and “lessons learned” in Pennsylvania’s use of evidence-based and promising practices. Now the EPISCenter has developed two new reports highlighting three years of Multisystemic Therapy (MST) and Functional Family Therapy (FFT) data for fiscal years 2012-2014. These reports are designed to be shared with stakeholders and present statewide trends for utilization, outcomes, and implementation quality, while noting areas where there is variation between individual sites. These reports provide hard evidence of the high quality and productivity of FFT and MST services in Pennsylvania.

Chapter 6100 Draft for Comments
The Office of Developmental Programs Chapter 6100 Regulations Work Group has released draft regulations for initial comments due by May 22. RCPA is requesting that members share their comments by May 20 with Policy Specialist Linda Drummond, who will compile and share with ODP’s Work Group.

HCBS Fact Sheet
The Department of Human Services has developed a fact sheet to answer some of the questions received based on the state’s compliance with the Centers for Medicare and Medicaid Services Home and Community-Based Services Final Rule.

  • More information on the DHS transition plan is available here.
  • More information about the Final Rule is available here.

New Jersey Seeking Providers
The New Jersey Department of Human Services Division of Developmental Disabilities will be shifting to a Medicaid-based, fee-for-service system beginning this July. This transition includes the launch of the division’s new Supports Program, a Medicaid waiver program that will fund a wide array of disability-related services for adults with intellectual and developmental disabilities aged 21 and older.

Many of the New Jersey-based providers are in the process of becoming Medicaid-approved, so that they can continue to offer services in the new system. In addition, New Jersey is very interested in reaching out-of-state providers who might have an interest in – and capacity for – providing disability-related services in New Jersey. They are developing a Prospective Provider Welcome Packet, which can be available to Pennsylvania providers interested in these opportunities. For information, contact Diane Flynn, NJ Division of Developmental Disabilities, or 609-689-6714.

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A little known, but vital provision of the Affordable Care Act (ACA), provides free health insurance for former foster youth. These young adults are eligible for Medicaid until age 26, regardless of their income, provided they were in foster care at age 18 or older and also enrolled in Medicaid. An estimated 6,000+ young adults in Pennsylvania may be eligible for this coverage, but only about 900 have signed up for it. Many former foster youth have substantial health care needs and are very unlikely to have insurance. Pennsylvania’s Juvenile Law Center (JLC) has developed materials to help community providers reach out to and inform current and former foster youth that you may be serving in your programs.

Visit the JLC website to download flyers and other informational resources on the ACA provision. View and share the JLC’s 30-second public service announcement on free health insurance for former foster youth.

May is Foster Care Month. What better time to help foster youth get the vital health care that all young people need? If you have any questions or want more information, contact Jenny Pokempner at JLC.

US Education Department
The US Secretary of Education has proposed some changes in federal regulations published in the Federal Register. The Secretary proposes to amend the regulations governing the State Vocational Rehabilitation Services program and the State Supported Employment Services. The new regulations would implement changes to the Rehabilitation Act of 1973, needed to comply with the Workforce Innovation and Opportunity Act (WIOA), enacted on July 22, 2014. The proposed regulations would also impose limits on the use of subminimum wages. Comments are due by June 15.

WIOA Proposed Rulemaking
The US Departments of Labor and Education have released five Notices of Proposed Rulemaking (NPRM) regarding the Workforce Innovation and Opportunity Act (WIOA). Apparently, there are accessibility issues with the NPRM for WIOA Regulations. Suzanne B. Mitchell, chief of the RSA Technical Assistance Unit, forwarded a link related to accessibility, which should resolve the issue.

WIOA Advisory Committee
The Advisory Committee on Increasing Competitive Integrated Employment for Individuals with Disabilities will hold its third meeting on May 11-12, via webinar. The meeting will be open to the public and will take place each day from 1:00-5:00 pm EDT. During the meeting, the committee will hear expert testimony, and its four subcommittees will report on their efforts to date and discuss next steps in their work. There will be a public comment period on May 11, 3:00-4:00 pm EDT. Instructions on submitting comments can be found in the Federal Register Notice. Members of the public wishing to participate in the webinar must register by May 4.

IM4Q Training
Mark your calendars for the ODP Annual Statewide Training on Independent Monitoring for Quality on July 29-30 at the Harrisburg Hilton.

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On April 23, the Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2016 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule. RCPA will review the provisions contained within the proposed rule with members, for their input, to include in comments to CMS. Highlights of the proposed rule are provided below.

Proposed Changes to the IRF Quality Reporting Program
The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) added Section 1899B to the Social Security Act to require that IRFs report data on measures that satisfy domains specified under the IMPACT Act, which will also be implemented in other post-acute care (PAC) settings (Skilled Nursing Facilities, Long-Term Care Hospitals, and Home Health Agencies). This rule proposes to adopt measures that satisfy three of the quality domains required by the IMPACT Act in FY 2016: skin integrity and changes in skin integrity, functional status, cognitive function, and incidence of major falls. IRFs that fail to submit the required quality data to CMS will be subject to a two percentage point reduction to their applicable FY annual increase factor.

The domains specified by the IMPACT Act and the quality measures proposed are as follows:

  • Domain 1. Skin integrity and changes in skin integrity:
  • Quality Measure: “Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened” (NQF #0678)
  • Domain 2. Functional status, cognitive function, and changes in function and cognitive function:
  • Quality Measure : Application of the “Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function” (NQF #2631; under review)
  • Domain 3. Incidence of major falls:
  • Quality Measure: Application of the “Percent of Residents Experiencing One or More Falls with Major Injury” (NQF #0674)

Additionally, CMS proposes to adopt four additional functional status quality measures, as well as proposing the previously finalized quality measure “All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from Inpatient Rehabilitation Facilities” (NQF #2502), in order to establish its newly NQF-endorsed status.

The four functional status quality measures under consideration include:

  • IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients (NQF #2633; under review);
  • IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients (NQF #2634; under review);
  • IRF Functional Outcome Measure: Discharge Self-Care Score for Medical Rehabilitation Patients (NQF #2635; under review); and
  • IRF Functional Outcome Measure: Discharge Mobility Score for Medical Rehabilitation Patients (NQF #2636; under review).

CMS proposes to publicly report IRF quality reporting program data beginning in fall 2016. A period of time will be provided for review and correction of quality data by IRFs prior to its publication of the performance data.

Continuation of Reporting Previously Collected IRF QRP Measures
For the FY 2018, adjustments to the IRF PPS annual increase factor, CMS is retaining previously discussed measures, including:

  • NHSN CAUTI Outcome Measure (NQF #0138);
  • Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short-Stay) (NQF #0680);
  • Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short-Stay) (NQF #0678);
  • All-Cause Unplanned Readmission Measure for 30 Days Post-Discharge from IRFs (NQF #2502);
  • Influenza Vaccination Coverage among Healthcare Personnel (NQF #0431);
  • NHSN Facility-Wide Inpatient Hospital-Onset MRSA Bacteremia Outcome Measure (NQF #1716); and
  • NHSN Facility-Wide Inpatient Hospital-Onset CDI Outcome Measure (NQF #1717).

A future update to the numerator of the quality measure Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678) is being considered. This update would hold providers accountable for the reporting of unstageable pressure ulcers, including suspected deep tissue injuries (sDTIs). If this proposed change were to be implemented, the numerator of the quality measure would be updated to include unstageable pressure ulcers, including sDTIs, that are new or developed in the facility, as well as Stage 1 or 2 pressure ulcers that become unstageable due to slough or eschar (indicating progression to a Stage 3 or 4 pressure ulcer) after admission.

Proposed Changes to the IRF Prospective Payment System

  • Standard Payment Rate: The standard payment rate conversion factor is proposed to be increased in FY 2016 to $15,529 from the FY 2015 amount of $15,185. This amount is the result of a 2.7 percent market basket increase minus a productivity adjustment of 0.6 percent, minus a 0.2 percent legislative adjustment. CMS is also proposing a new rehabilitation only market basket.
  • Update to CMG Weights, Lengths of Stay and Comorbidities: CMS updated the Case Mix Group (CMG) weights using FY 2013 cost report data and the FY 2014 claims data and the lengths of stay (ALOS) per CMG.
  • Labor Related Share and Area Wage Adjustments: The proposed labor related share for FY 2016 is 69.6, a slight increase over FY 2015’s labor-related share of 69.294. CMS used the same methodology it has previously employed in calculating previous IRH/U labor-related shares.
  • Outlier Threshold: CMS updates the outlier threshold amount to $9,698 in order to maintain the outlier payments at three percent of total IRF payments in FY 2016. The national cost-to-charge ratio ceiling is set for FY 2016 at 1.36; the ceiling for rural IRFs is 0.569 and 0.437 for urban IRFs.
  • Changes to Facility Adjusters: CMS made significant changes to the methodology used to develop the facility-level adjustment factors in the FY 2014 IRF PPS final rule. For FY 2016, CMS continues to freeze the LIP, rural, and teaching adjustments at the FY 2014 levels, which are: LIP factor of 0.3177; rural adjustment at 14.9 percent; and teaching adjustment factor at 1.0163.

Revised Version of the IRF PAI
A revised version (FY 2017, version 1.4) of the inpatient rehabilitation facility patient assessment instrument (IRF PAI) has been published, to account for changes in measure reporting occurring as a consequence of the IMPACT Act. CMS has also published a chart that compares the IRF PAI versions 1.4 (effective FY 2017) and 1.3 (effective FY 2016).

The proposed rule will be published in the April 27, 2015 Federal Register. Comments on the provisions contained within this proposed rule will be accepted through June 22.

ODP Provider Agreement
The Office of Developmental Programs (ODP) has released the “Addendum to the Provider Waiver Agreement,” which must be signed and the hard copy with the original signature returned to ODP no later than May 4. Or a signed scanned copy must be emailed by May 4 with the hard copy mailed to ODP with a postmark of no later than May 4.

DHS Provider Enrollment
The Department of Human Services (DHS) is working on the issue of the provider enrollment backlog and the time-consuming paper-intensive manual process. Due to the changes required by the Affordable Care Act, if a provider enrolled on or before March 25, 2011, they must be revalidated by March 24, 2016. If the provider enrolled after March 25, 2011, the revalidation must occur on or before five years from the date of initial enrollment.

DHS has launched the following initiatives to address some of the issues:

  • Electronic Enrollment: DHS expects to have a new, electronic enrollment web portal available in the fall of 2015. This new portal will greatly reduce the need for the paper application.
  • Standardization of Policies and Procedures: DHS is developing a department-wide approach to provider enrollment to reduce variations across program offices that cause confusion. The process will be completed by October 31, and will include standardization of policies and procedures for both DHS staff and providers.
  • Staffing: By May, DHS will add nine staff to help process provider enrollment applications and reduce backlogs.

ODP Updates
ODP has issued the following information:

  • Informational Memo #034-15: Helpful Resources from the PA Department of Transportation; Information regarding the Yellow Dot Program
  • Informational Memo #035-15: New ODP Specialty Codes 508 and 509; Effective July 1, new codes will be added for providers to use; #508 Behavioral Support and #509 Supports Broker Services
  • HCSIS Service Notes Sweep delayed which impacts the supports coordinators TSM file creation; expected to be resolved by April 23
  • RCPA has informed ODP that there are not enough trainings scheduled in some areas to accommodate those that wish to attend “The Outcome Section of the ISP: Better Outcomes: Better Lives” (Announcement #030-15)

WIOA Proposed Rulemaking
The US Departments of Labor and Education have released five notices of proposed rulemaking regarding the Workforce Innovation and Opportunity Act (WIOA). These announcements are open for public inspection. The Notices of Proposed Rulemaking are published in the Federal Register and the 60-day public comment period will end on June 15. Written comments may be submitted online.

LEAD Center is offering two new WIOA Policy Briefs:

SNAP Asset Test
DHS announced that as of April 27, it is eliminating the SNAP asset test. The anticipated state savings from eliminating the asset test is $3.5 million annually. SNAP is a federal program that provides monthly food stamps.

Webinars and Trainings

Adult Protective Services
The Department of Human Services has released information regarding the reporting of suspected cases of abuse, neglect, exploitation, or abandonment as required by the Adult Protective Services (APS) law. Information about APS, including the forms to be used by mandated reporters, may be found on the department’s website under the “Report Abuse” icon on the left side. This site also includes the recorded webinar explaining APS and how to handle mandatory reports. Questions may be submitted via email or phone, 717-736-7116. The statewide Protective Services Hotline at 800-490-8505 is used for reporting cases.

Provider Monitoring
The Office of Developmental Programs (ODP) has asked RCPA to request feedback from its members regarding the provider monitoring process over the past several years. Direct service providers and supports coordination organizations are asked to please share any comments/suggestions/recommendations with Policy Specialist Linda Drummond by May 1.

ODP Updates
ODP has released the following information:

  • Announcement #030-15: New Required Training: The Outcome Section of the ISP: Better Outcomes, Better Lives; this required training for SCOs and AEs is also recommended for provider staff.
  • Informational Packet #031-15: Amendments to 55 PA Code 6000, ODP Statement of Policy, Subchapter Q as a result of Adult Protective Services.
  • Announcement #032-15: Risk Mitigation Training for SCOs, AEs, and Providers.
  • Announcement #033-15: Availability of ODP’s Consolidated, P/FDS and Adult Autism Waiver Amendments and Accompanying Transition Plans submitted to CMS.

Chapter 6100 Work Group
The notes from the ODP Chapter 6100 Regulations Work Group provide an overview of sections on vendor goods and services, cost-based rates and allowances, residential habilitation, allowable costs, donations, board, start-up costs, targeted support management, base-funded, and supports coordination.

Provider Survey Extended
The deadline has been extended to April 30 for the Department of Human Services Home and Community-Based Services Provider Survey to be completed by all ODP and OLTL licensed and unlicensed, residential and non-residential service providers. Direct any questions regarding the survey to RA-pwhcbsfinalrulepl@pa.gov.

ODP Updates
The Office of Developmental Programs has issued the following information:

  • Informational Packet #028-15 Reissue: Revised document, “Changes to the Approved Program Capacity Process Resulting from the Provider Settlement Agreement
  • Medication Administration Train-the-Trainer Courses and Recertification Courses are scheduled to be available by mid-May. ODP has extended the current certifications until June 30, 2015.
  • DHS: The Impact: Autism Awareness Month; DHS Secretary Dallas has issued a monthly update on the department’s initiatives to keep stakeholders updated.
  • Money Follows the Person National Report for 2013 is available. Currently, Pennsylvania has 1,900 Money Follows the Person transitions to the community and transitions will continue until December 31, 2018.