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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.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2025 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule. The proposed rule will be published in the March 29, 2024, Federal Register. A high-level overview of the proposed rule is provided below:

Payment Updates:

CMS estimates an overall increase in aggregate payments to IRFs by 2.5% or $255 million (compared to the 4% payment update in FY 2024).

Market basket update for IRF services is 3.2%. This will be reduced by a productivity adjustment of 0.4%, which would result in an overall 2.8% increase. These figures are likely to change due to updated forecasts.

CMS is proposing to update the outlier threshold amount from $10,423 (FY 2024) to $12,158 (FY 2025), which would account for an estimated 0.2 percent decrease to aggregate payments across the IRF PPS in FY 2025.

Quality Reporting Program (QRP) Updates:

CMS is proposing to make additions, modifications, and removals of some QRP measures. A proposal was included to collect four new Standardized Patient Assessment Data Elements (SPADE) in the IRF QRP to bolster the collection of information on social determinants of health (SDOH):

  • Living Situation: Requests regarding the current living situation;
  • 2 Food Items: Questions about food running out;
  • Utilities: Questions about threats to shutting off utilities; and
  • A modification to an existing SPADE on Transportation.

CMS is also proposing to remove the “Admission Class” from the IRF Patient Assessment Instrument (PAI).

Feedback is requested on future revisions to the IRF QRP, as well as feedback on the development of a five-star methodology for IRFs.

Additional information will be forthcoming. Comments on the proposed rule are due to CMS by the end of May.

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The next phase of the Centers for Medicare and Medicaid Services (CMS) inpatient rehabilitation facility (IRF) review choice demonstration (RCD) is scheduled to be implemented in Pennsylvania on June 17, 2024, and will last for five years. This demonstration applies to only IRF providers physically located in Pennsylvania.

Between May 3, 2024, and June 2, 2024, IRFs must select either 100% pre-claim review or 100% post-payment claim review.

CMS has stated that creating a review choice process will ensure Medicare coverage and documentation requirements are likely met. This program reduces the number of Medicare appeals, improves provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.

Novitas Solutions is the Medicare Administrative Contractor (MAC) for Pennsylvania and will process the IRF claims. In preparation for the implementation of IRF RCD, Novitas Solutions will be conducting their first webinar on April 24, 2024, from 1:00 pm – 2:30 pm. Registration to participate in this webinar is now open. Members are strongly encouraged to participate in this webinar to prepare for this demonstration. If the registration link does not work, please copy and paste the below link into your browser to register:
https://fcso.webex.com/webappng/sites/fcso/meeting/register/0fd87e2111f7446fa477d0a25f78674c?ticket=4832534b000000073a942d9e6f94601b6b106adc8f502bcee359653432e8c326edb0f50ebc253329&timestamp=1711559626291&RGID=re6663754d2fe70defe3195e29c69465a

In addition to information on the CMS website, Novitas Solutions has a dedicated website that provides a great deal of information and resources on IRF RCD.

The meeting documents from the March 7, 2024, Long-Term Services and Supports (LTSS) Subcommittee meeting are now available. These documents include the transcript and PowerPoint presentations. You can view the documents below:

The next LTSS Subcommittee meeting is scheduled for April 3, 2024, from 10:00 am – 1:00 pm in the PA Department of Education’s Honors Suite at 333 Market St. in Harrisburg, PA. The option to participate via webinar is also an option. The agenda for the April meeting is here.

To participate in the meeting via webinar, please register here. After registering, you will receive a confirmation email containing information about joining the webinar. If you plan to participate via phone, the dial-in number is: (213) 929-4212; PIN: 914 913 021#.

The Office of Long-Term Living (OLTL) has announced that they will be presenting a six-session webinar series that will focus on housing issues. The live, interactive webinars will be conducted from 12:00 pm – 1:30 pm in April and May and will focus on the following topics:

2024 OLTL Spring Housing Series Curriculum

  • April 2: Understanding Housing Nuances in Pennsylvania
  • April 9: Recommended Relationships to Have in the Housing Sector
  • April 16: Fair Housing and Landlord/Tenant Issues with the Housing Equality Center of PA
  • April 23: OFF
  • April 30: Types of Housing Funding Sources
  • May 7: Keeping Participants Housed with Landlord Engagement Techniques AND Housing Information Resources to be Aware of
  • May 14: Assistive Technology and Housing with the PA Assistive Technology Foundation (PATF)

Target Audience

The webinar series targets Service Coordinators, Managed Care Organizations (MCO), and Service Coordination Entity support staff who assist program participants in securing and maintaining affordable, accessible housing through Home and Community-Based Services (HCBS). The target audience for these webinars includes individuals and organizations who provide long-term services and supports (LTSS) for older Pennsylvanians and people with physical disabilities.

Important Information

The information covered in this webinar series will be similar to the information covered in the 2023 OLTL spring and fall housing webinars (except for an added session on assistive technology). Since the information is similar, if you attended the 2023 housing webinars, you do not need to attend this series unless you wish to refresh your knowledge on the topic, participate in a session that you missed, or participate in the new assistive technology session.

This webinar series builds on information already provided in the Online Housing Training Modules and the Self-Determination Housing of Pennsylvania (SDHP)/Inglis’ Prepared Renter Program (PREP) curriculum.

The content in each webinar builds on prior content. Participants will get the most out of the series by taking all of the webinars.

To participate in the webinars, registration is available here.

The Brain Injury Association of America (BIAA) will be conducting a virtual Brain Injury Fundamentals course on March 20, 2024 from 1:00 pm – 2:00 pm. The course will provide foundational knowledge about working with individuals who have a brain injury, and is ideal for non-licensed health care professionals, first responders, and support staff.

This course is self-paced, so those who are unable to participate in the in-person course due to scheduling conflicts or other commitments have the opportunity to complete the course with greater flexibility. Please note that while the self-paced option offers 24/7 access for independent learning and development, there is a two-hour live instructor component as well. To participate in the session, please register here.

As noted in a previous alert from the Department of Human Services (DHS), the Department of Health and Human Services (HHS) has also been providing updates regarding the recent cybersecurity incident that impacted Change Healthcare (a unit of UnitedHealth Group). HHS has noted that their first priority is to help coordinate efforts to avoid disruptions to care throughout the health care system.

On March 5, 2024, HHS announced immediate steps that the Centers for Medicare and Medicaid Services (CMS) is taking to assist providers to continue to serve patients. CMS will continue to communicate with the health care community and assist, as appropriate. Providers should continue to work with all their payers for the latest updates on how to receive timely payments.

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On March 1, 2024, the Centers for Medicare and Medicaid Services (CMS) posted an update on the Review Choice Demonstration for Inpatient Rehabilitation Facility (IRF) Services web page that announced they will be expanding the Review Choice Demonstration for IRF services in Pennsylvania on June 17, 2024. The demonstration will apply to IRF admissions occurring on or after June 17, 2024. IRF admissions prior to the June 17 date are not part of the demonstration, and IRF providers must select either 100% pre-claim review or 100% post-payment review between May 3, 2024, and June 2, 2024.

Medicare Administrative Contractor (MAC) for Jurisdiction L (which includes the state of Pennsylvania) is Novitas Medicare Solutions, who processes claims for IRFs located in Pennsylvania. Novitas will be directly involved in the RCD and created a dedicated RCD page on their website. The page includes additional information on background and general information, timelines, the two choices for claims review (pre-payment and post-payment), IRF RCD contact information, educational events, and other resources.

The IRF RCD began in Alabama in August 2023. CMS has cited that creating a review choice process will ensure Medicare coverage and documentation requirements are likely met. CMS feels this program will reduce the number of Medicare appeals, improve provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.

RCPA will continue to update members as additional information is received. Members are encouraged to review the information on the CMS RCD web page and Novitas RCD web page. Questions regarding this information can be directed to Melissa Dehoff.