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Authors Posts by Melissa Dehoff

Melissa Dehoff

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Melissa Dehoff is responsible for all medical rehabilitation and brain injury service issues. Ms. Dehoff attends multiple state-level meetings to advocate on behalf of members on brain injury and rehabilitation issues and is a member of the Department of Health Traumatic Brain Injury Advisory Board.

The following documents from the August 3, 2022, Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting are now available:

The next MLTSS Subcommittee is scheduled for September 7, 2022, from 10:00 am — 1:00 pm. The meeting will be held in person in the Pennsylvania Department of Education’s Honors Suite, 1st floor, at 333 Market Street Tower in Harrisburg as well as via webinar. To register to participate via webinar, please visit this webinar registration link. After registering, you will receive a confirmation email containing information about joining the webinar.

Photo by Christina @ wocintechchat.com on Unsplash

This is a reminder that there is a Financial Management Services (FMS) stakeholder meeting today, August 5, from 1:00 pm – 2:30 pm.

The purpose of this public meeting is to discuss upcoming changes for the administration of FMS under the Community HealthChoices (CHC), OBRA Waiver, and Act 150 programs. Representatives from the Office of Long-Term Living (OLTL) and CHC Managed Care Organizations (MCOs) will be in attendance to discuss upcoming changes.

Please register using this link. After registering, you will receive a confirmation email containing information about joining the webinar.

If you choose to use your phone to call in, please use the numbers below:
Dial in: 415-930-5321
Access Code: 264854023#
Audio PIN: shown after joining the webinar

The Centers for Medicare and Medicaid Services (CMS) recently released a Request for Information (RFI) requesting public comments on the Medicare Advantage program. CMS is asking for input on ways to achieve the agency’s vision so that all parts of Medicare are working towards a future where people with Medicare receive more equitable, high quality, and person-centered care that is affordable and sustainable, essentially asking for ways to strengthen this program.

CMS’s intent is to better align the Medical Assistance (MA) program with the agency’s vision for Medicare and the CMS Strategic Pillars. CMS is strongly emphasizing the importance of stakeholder comments for this process. This openness to feedback presents MA plans, providers, and other stakeholders an opportunity to inform the agency’s early thinking as it considers potential regulatory actions impacting supplemental benefits, value-based contracting arrangements, risk adjustment, prior authorization, and marketing among other issues.

CMS will accept comments on the RFI until August 31, 2022.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2023 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was published in today’s Federal Register. Some of the key provisions contained in the final rule are provided below:

Final FY 2023 Payment Updates
CMS estimates overall payments to IRFs will increase by 3.2 percent compared to FY 2022 levels (higher than the 2 percent estimated in the proposed rule). This update is the result of a 4.2 percent update to the IRF market basket reduced by a 0.3 percent productivity adjustment, which is required by law. As a result of this market basket increase and a few small budget neutrality adjustments, the standard payment conversion factor will increase from $17,240 to $17,878. ‎CMS is also adjusting the outlier threshold, which it says will reduce overall payments by 0.6 percent. CMS says the 3.2 percent overall increase will result in $275 million in increased payments to IRFs compared to 2022.

Proposed Expansion of IRF Transfer Policy to Include Home Health Services
CMS issued a Request for Information (RFI) in the proposed rule regarding the potential expansion of the current IRF transfer payment policy to include home health services. For background, IRFs receive a reduced case mix group (CMG) payment rate under the IRF transfer policy when the patient’s discharge occurs earlier than the average length of stay (for that respective CMG and tier) and the patient is discharged to a certain setting (an IRF, acute-care hospital, LTCH, nursing home that takes Medicare and Medicaid payment). The policy currently does not apply to home health.

The RFI in this year’s rule followed a December 2021 Office of Inspector General (OIG) report finding that Medicare could have saved over $993 million had the IRF transfer policy been expanded to include home health services (based on 2017 and 2018 data). The OIG therefore recommends that CMS explore ways to capture early discharges to home health care in the current policy, which CMS referenced in the proposed rule. Following a review of concern cited in stakeholder comments, CMS is not moving forward with any changes to the transfer policy at this time.

IRF Quality Reporting Program Changes & Requests for Information All-Payer IRF-PAI Reporting Proposal
CMS proposed to require collection of the IRF-PAI for all IRF patients, including those without Medicare, beginning with the FY 2025 IRF QRP (with data collection to begin on October 1, 2023). Currently the IRF-PAI is only required to be collected for Medicare Part A (fee-for-service) and Part C (Medicare Advantage) beneficiaries. In response to comments, CMS opted to finalize the proposal but with a revised implementation date. IRFs will now be required to collect IRF-PAIs on all patients, regardless of payer, for the FY 2026 IRF QRP (data collection to begin on October 1, 2024).

RFI on Future QRP Measure Expansions
CMS had issued a Request for Information (RFI) related to measures/concepts for use in the QRP in future years in the proposed rule. The agency specifically requested information on a cross-setting function measure that would include self-care and mobility items, and development of a patient-level COVID-19 vaccination measure. CMS referenced several of AMRPA’s comments, including concerns that IRF stays are typically not long enough to adequately capture COVID-19 vaccination for patients. CMS did not provide a response to comments but affirmed the agency would use the stakeholder feedback to inform future rulemaking.

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On July 13, 2022, the Centers for Medicare and Medicaid Services’ (CMS) Medicare Administrative Contractors (MACs) distributed notifications to inpatient rehabilitation facilities (IRFs) that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for calendar year (CY) 2021, which will affect their FY 2023 Annual Payment Update (APU). Non-compliance notifications were placed into facilities’ “Certification and Survey Provider Enhance Reports” (CASPER) folders in the Quality Improvement and Evaluation System (QIES) for hospice and skilled nursing facilities (SNFs), and into facilities’ “My Reports” folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs and long-term care hospitals (LTCHs). If a facility received a letter of non-compliance, it may submit a request for reconsideration to CMS via email. The submission deadline is 11:59 pm on August 11, 2022. View the full details and instructions for submission here.

The next Financial Management Services (FMS) Stakeholder meeting has been scheduled for August 5, 2022, from 1:00 pm – 2:30 pm.

This public meeting is being held to discuss upcoming changes for the administration of FMS under the Community HealthChoices (CHC), OBRA Waiver, and Act 150 Programs. Representatives from the Office of Long-Term Living (OLTL) and Community HealthChoices Managed Care Organizations (CHC MCOs) will be in attendance to discuss upcoming changes.

Please register using this registration link. After registering, you will receive a confirmation email containing information about joining the webinar.

If you choose to use your phone to call in, please use the numbers below:
Dial in: (415) 930-5321
Access Code: 264854023#
Audio PIN: shown after joining the webinar

On July 7, 2022, the Centers for Medicare and Medicaid Services (CMS) released the proposed Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2023. In this proposed rule, CMS is proposing an approximately 4 percent reduction to the base payment factor for all services for 2023. The specific level of adjustment providers may see will depend on changes CMS finalizes to other factors. CMS is also proposing to expand the list of codes that can be provided via telehealth through 2023 to include some therapy codes. Modifications to the Quality Payment Program (QPP), which includes the Merit-Based Incentive Payment System (MIPS), to allow for additional pathways for participation for certain specialties is also being proposed. The proposed rule will appear in the July 29 Federal Register.

Information and registration for the August Managed Long-Term Services and Supports (MLTSS) Subcommittee meeting was recently released by the Office of Long-Term Living (OLTL). The meeting will be held on August 3, 2022, from 10:00 am – 1:00 pm. Attendees can participate via webinar or in person at the PA Department of Education Building’s Honors Suite at 333 Market Street in Harrisburg.

To participate in the meeting via webinar, please register via the link below. Those participating by webinar are encouraged to register early. When registering, please verify that you entered your email address correctly. You will receive a confirmation email containing information about joining the webinar if you registered correctly.

Webinar Registration Link
If you have trouble accessing the webinar registration through the Internet Explorer or Safari web browsers, please try accessing it through a different web browser such as Chrome or Edge.

Dial In Number:
The dial-in number is: 
(415) 655-0052
Access Code: 205870515#