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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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Beginning today, an update has been made to the Home and Community-Based Services (HCBS) application process completed by the Pennsylvania Independent Enrollment Broker (IEB) that will include the IEB scheduling the Intake Visit Assessment (IVA) as the first step of the enrollment process.

As a result of this update, the following changes will take place:

  • Upon initial contact with the applicant, the PA IEB will schedule an in-home visit, which includes an IVA within seven days, unless otherwise requested by the applicant.
  • The HCBS application will start on the day of the in-home visit, or upon receipt of a Commonwealth of Pennsylvania Application for Social Services (COMPASS) application, whichever occurs first.
  • At the in-home visit, the PA IEB will:
  • Review the enrollment process and give the applicant and others present at the IVA an overview of what they can expect;
  • Assist the applicant with completing the HCBS application and collecting all supporting documents available at the time of the IVA;
  • Answer questions and assist with HCBS information and choice counseling to make their Managed Care Organization (MCO) selection.

The goal of this change is to alleviate some challenges applicants encounter while trying to navigate the eligibility and enrollment process. Questions regarding this update should be directed to the Office of Long-Term Living (OLTL) Participant Enrollment Unit at 800-757-5042 or by email.

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The Centers for Medicare and Medicaid Services (CMS) recently announced the availability of a revised inpatient rehabilitation facility prospective payment system (IRF PPS) Medicare Learning Network (MLN) booklet. Topics in the booklet include: IRF PPS Elements (including rates, classification criterion, compliance percentage, and reasonable and necessary criteria); payment updates; IRF quality reporting program (QRP) measures for annual payment update; and many resources.

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Included in the August 24, 2019 Pennsylvania Bulletin was a notice from the Department of Human Services (DHS) about a change in the fee schedule rates for Personal Assistance Services (PAS) procedure codes (W1793, W1793TT, W1792, and W1792TU), and for Residential Habilitation procedure codes W0100 and W0102 in the Medical Assistance OBRA Waiver. The changes in the fee schedule rates for these services will be effective on January 1, 2020.

The existing fee schedule rates for PAS (Agency) and PAS (CSLA), procedure codes W1793 and W1793 TT, are increased by 2%. The intent of the increase is to provide for a wage increase for direct care workers providing agency-directed personal assistance services. DHS is also increasing the PAS (Consumer) and PAS (Consumer Overtime) rates, procedure codes W1792, and W1792 TU, to maintain equity in all the PAS rates in the OBRA waiver.

In addition, the existing fee schedule rates for Residential Habilitation procedure codes W0100 and W0102 are increased to include a 3 percent vacancy factor. A vacancy factor had not previously been included in the rate methodology; however, the Department recognizes that providers may not always deliver services to participants at full capacity. Therefore, a 3 percent vacancy factor will be applied to adjust the rates to account for the days the residential provider did not provide services to the participant. The provider cannot bill for days the participant did not receive services, but rather is paid a higher rate for days the participant received services. A vacancy factor of 3 percent was applied to reflect payment to providers for an average number of vacant days.

The fee schedule rates are available in the notice. Written comments regarding these fee schedule rates will be accepted through close of business on Monday, September 23, 2019 and should be sent to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: Marilyn Yocum, PO Box 8025, Harrisburg, PA 17105-8025. Comments may also be submitted to the Department via email. Comments received within 30 days will be considered in subsequent revisions to the fee schedule.

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The Department of Human Services (DHS) has released the Office of Long-Term Living’s (OLTL’s) proposed OBRA waiver amendments for public review and comment in the August 24, 2019 Pennsylvania Bulletin.

DHS proposes the following substantive changes to the OBRA waiver effective January 1, 2020:

  • Revise the Residential Habilitation service definition by modifying the number of hours that are defined as a day unit from a minimum of 12 hours to 8 hours.
  • To the service definitions of Job Finding, Job Coaching, Employment Skills Development, Career Assessment, and Benefits Counseling, add language that Office of Vocational Rehabilitation (OVR) services are considered not to be available if OVR has not made an eligibility determination within 120 days; and add language to address when employment services through the OBRA waiver can be provided should OVR close the order of selection, thereby creating a waiting list for OVR services.

In addition, DHS proposes to make the following technical edits:

  • Update Appendix C-2.b., Abuse Registry Screening, to reflect that the Department utilizes IDEMIA as the data system to process fingerprint-based Federal Bureau of Investigation (FBI) criminal record checks as well as other minor editorial changes to the section.

The proposed amendments and a summary of all of the revisions are available for review here.

Written comments regarding these proposed waiver amendments will be accepted through close of business on Monday, September 23, 2019 and should be sent to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: OBRA Waiver Amendments, PO Box 8025, Harrisburg, PA 17105-8025. Comments may also be submitted to the Department via email. Please use OBRA Waiver Amendments as the subject line.

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The Department of Human Services (DHS) has released the Office of Long-Term Living’s (OLTL’s) proposed Community HealthChoices (CHC) waiver renewal for public review and comment in the August 17, 2019 Pennsylvania Bulletin.  DHS proposes to renew the CHC waiver with an effective date of January 1, 2020 in order to be aligned with the calendar year.

Some of the proposed changes to the CHC waiver include:

  • Revise the Residential Habilitation service definition by modifying the number of hours that are defined as a day unit from a minimum of 12 hours to a minimum of 8 hours.
  • To the service definitions of Job Finding, Job Coaching, Employment Skills Development, Career Assessment and Benefits Counseling, add language that Office of Vocational Rehabilitation (OVR) services are considered to not be available if OVR has not made an eligibility determination within 120 days; and add language to address when employment services through the CHC waiver can be provided should OVR close the order of selection, thereby creating a waiting list for OVR services.
  • Modify the qualifications for Service Coordinators and Service Coordinator supervisors.
  • Clarify that, if a CHC Managed Care Organization (MCO) identifies that a participant has not been receiving services for 5 or more days, and if the suspension of services was not pre-planned, then the CHC-MCO must communicate with the participant to determine the reason for the service suspension within 24 hours. If the participant’s health status or needs have changed, then the CHC-MCO must conduct a comprehensive needs reassessment of the participant’s needs within 14 days of identifying the issue.
  • Add that an emergency back-up plan must be included in the Person-Centered Service Plan.
  • Remove and modify language to reflect that the CHC waiver will be fully operational Statewide as of January 1, 2020.
  • Update language to reflect that the Department utilizes IDEMIA as the data system to process fingerprint-based Federal Bureau of Investigation criminal record checks.
  • Update the OLTL bureau names and responsibilities.

The proposed CHC waiver renewal and a summary of all revisions are available for review here. Written comments regarding these proposed revisions will be accepted through close of business on September 16, 2019 and should be sent to the Department of Human Services, Office of Long-Term Living, Bureau of Policy Development and Communications Management, Attention: CHC Waiver Renewal, P.O. Box 8025, Harrisburg, PA 17105-8025. Comments may also be submitted to the Department at RA-waiverstandard@pa.gov.

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On August 9, 2019, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2020 outpatient prospective payment system (OPPS) proposed rule. In addition to the proposed changes to the amounts used to determine the Medicare payment rates, this proposed rule updates and refines the requirements for the hospital outpatient quality reporting program. Included in this proposed rule is a provision that would require inpatient rehabilitation facilities (IRFs) and other hospitals to post certain payment information, which seeks to increase price transparency by requiring all hospitals in the United States to make hospital standard charges available to the public. It would also publish patients’ out-of-pocket costs for scheduled health care services. The rule also proposes to implement site-neutral payment rates for outpatient hospital physician visits that would align the payment amount for non-hospital physician visits. Comments on this proposed rule will be accepted through September 27, 2019. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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Community HealthChoices (CHC) is Pennsylvania’s mandatory managed care program for individuals who are dually eligible for Medicare and Medicaid, and individuals 21 years of age or older with physical disabilities who receive long-term services and supports through Medicaid. CHC is currently live in the Southwest and Southeast part of the state. The remainder of the state will transition to CHC on January 1, 2020.

CHC participants have protections if they do not agree with a CHC managed care organization’s (CHC-MCO’s) decision to deny, decrease, or approve a service or item different from what was requested. Participants can also voice dissatisfaction with their CHC-MCO or a provider. These concerns or issues can be voiced through the complaints and grievance process. Information about the complaint and grievance process is available in this fact sheet. Additional information is provided in a comprehensive FAQ Document. For additional questions, please visit the CHC website or submit via email.

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The Department of Human Services (DHS) recently announced that they will be holding public electronic visit verification (EVV) webinars to provide additional information and updates related to the DHS EVV implementation. These meetings are scheduled every five weeks leading up to January 1, 2020. The next meeting is scheduled for Tuesday, August 13, 2019 from 1:00 pm to 3:30 pm and registration is required. A confirmation email and information about the webinar will be sent following registration.

Future public meeting dates include*

  • Tuesday, September 17, 2019 from 1:00 pm – 3:30 pm
  • Tuesday, October 22, 2019 from 1:00 pm – 3:30 pm
  • Tuesday, November 26, 2019 from 1:00 pm – 3:30 pm

*Please note: dates are subject to change. Contact the DHS office for more information or call 800-692-7462.

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The Centers for Medicare and Medicaid Services (CMS) released proposed updates and policy changes under the Medicare outpatient prospective payment system (OPPS) and Ambulatory Surgical Center (ASC) payment systems, including price and quality transparency that lay the foundation for a patient-driven health care system. The proposed rule is scheduled to be published in the August 9, 2019 Federal Register.

CMS will be conducting a listening session on Wednesday, August 14, 2019 from 2:30 pm – 4:00 pm to briefly cover provisions from the proposed rule and address clarifying questions to assist providers with formulating written comments for formal submission. Registration for the listening session is required.

Topics will include:

  • Price transparency: Requirements for all United States hospitals to make their standard charges public; and
  • Increasing choices and encouraging site neutrality, including payments for clinic visits.

Providers are encouraged to review, in addition to the proposed rule, the press release and the fact sheet prior to the call.

CMS has noted that feedback received from providers during this listening session is not a substitute for formal comments on the rule, which are due by September 27, 2019. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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