Brain Injury

Today Governor Wolf announced that the departments of Human Services (DHS) and Community and Economic Development (DCED) are now accepting applications for the Home and Community-Based Services (HCBS) loan program.

The loans are intended to support long-term care providers as they position themselves to successfully transition to managed care in Community HealthChoices, Governor Tom Wolf’s plan to improve the quality of care for seniors and individuals with disabilities through managed long-term services and supports.

“HCBS will allow seniors and individuals living with disabilities to transition from living in long-term care facilities to residing in the community, ensuring that people have choices about where they live and receive services,” Governor Wolf said. “My administration is committed to serving more people in the community – where they want to live.”

It’s expected that loans – for startups, reconfiguration, or expansion – will range from $50,000 to $200,000.

“These loans will support projects that help the Commonwealth to improve the quality of care for seniors and people with disabilities by building infrastructure so individuals will have more choices available to them,” DHS Secretary Ted Dallas said. “Through these funds, individuals will be served in the right setting with the proper amount of services and supports to help all Pennsylvanians live full, independent lives on their own terms.”

DHS can receive loan applications at any time of the year and will process them on a first-come, first-served basis. DCED will then work with DHS to process the loans.

“The collaborative effort necessary to launch this program is a demonstration of our commitment to Governor Wolf’s government that works initiative for a common goal of creating a better Pennsylvania,” said DCED Secretary Dennis Davin, “DCED is proud to be a part of such an important program.”

Visit here for more information on the HCBS loan program, or here (PDF) for the loan application.

The Department of Human Services has released a timeline for transitions to Community HealthChoices (CHC), which is a managed care program that will better coordinate the way participants receive their physical health services and long-term services and supports (LTSS). The goal is to serve more people in their homes and their communities. CHC will serve Medicaid participants 21 years of age or older who also receive Medicare, need LTSS in their home or community, or are in nursing facilities. Today, there are five waivers in which participants receive LTSS. In the future there will be two waivers.

CHC: will serve participants currently in the Aging, Attendant Care, Independence, and COMMCARE waivers. OBRA participants who are nursing facility clinically eligible will also move to CHC.

OBRA Waiver: will continue to serve participants 18 years of age and older who have a severe developmental disability requiring the level of care provided in an intermediate care facility/other related conditions (often referred to as ICF/ORC).

What will happen?

  • Since CHC only serves participants 21 years of age and older, participants in the Attendant Care and Independence waivers who are between 18 to 20 years of age will be enrolled in the OBRA Waiver to receive LTSS services.
  • The OBRA Waiver will provide the same services available in Attendant Care and Independence waivers.
  • It is DHS’ priority to ensure that participants’ services are not impacted in any way.

When will this happen?
Southwest Zone: August 2017 to October 2017
Southeast Zone: February 2018 to May 2018
Remaining Zones: August 2018 to October 2018

What will happen?

  • The COMMCARE Waiver will end December 31, 2017. Any new applicants who would have been eligible for the COMMCARE Waiver after September 1, 2017, will be eligible for and enrolled in the Independence Waiver.
  • This means that participants who are receiving services in the COMMCARE Waiver who do not live in the Southwest Zone will be enrolled in the Independence Waiver before December 31, 2017.
  • It is DHS’ priority to ensure that participants’ services are not impacted in any way.

When will this happen?
COMMCARE Waiver participants residing outside of the Southwest Zone will be enrolled in the Independence Waiver by their service coordinators between July 2017 and November 2017.

COMMCARE participants in the Southwest Zone will transition to CHC on January 1, 2018.

What will happen?

  • OBRA Waiver participants whose level of care determination was completed before November 18, 2016, will get an assessment to determine their eligibility for CHC. Those determined ineligible for CHC will remain in OBRA.
  • DHS is working with the Area Agencies on Aging, service coordinators, and providers to ensure assessments are completed in a timely manner. Participants will be contacted by their Area Agency on Aging to schedule a time for the assessor to meet with them to go through the assessment process. 

When will this happen?
Southwest Zone: May 2017 to August 2017
Southeast Zone: October 2017 to February 2018
Remaining Zones: April 2018 to August 2018

*There are no additional transitions for Aging Waiver participants. Aging Waiver participants will simply transition to CHC when CHC begins in their zones.

On April 27, 2017, the Centers for Medicare and Medicaid Services (CMS) released the display version of the fiscal year (FY) 2018 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

Some of the key provisions are provided below; a more detailed analysis of the proposed rule with be forthcoming following the publication of the proposed rule in the May 3, 2017 Federal Register. In addition, CMS published a Fact Sheet that highlights the major provisions of the proposed rule.

ICD-10-CM Presumptive Compliance Coding Changes
CMS is proposing to make refinements to the ICD-10-CM lists used in determining IRFs’ presumptive compliance with the 60 percent rule. The complete lists of proposed code revisions are available for download on the IRF PPS website. CMS notes that the version of these lists that is finalized in conjunction with the FY 2018 IRF PPS final rule will constitute the baseline for any future updates to the presumptive methodology lists. The codes include:

  • TBI and Hip Fracture Codes

The proposed rule addresses certain ICD-10-CM diagnosis codes for patients with traumatic brain injury (TBI) and hip fracture conditions. CMS proposes to include such codes in counting towards presumptive compliance when they are used as an etiologic diagnoses in the following IGCs effective October 1, 2017:

Brain Dysfunction – 2.21 Traumatic, Open Injury;
Brain Dysfunction – 2.22 Traumatic, Closed Injury;
Orthopedic disorders – 8.11 Status Post Unilateral Hip Fracture; and
Orthopedic disorders – 8.11 Status Post Bilateral Hip Fracture.

The complete list of TBI and hip fracture ICD-10-CM codes is available for download on the CMS IRF PPS website.

  • Major Multiple Trauma Codes

CMS also proposes changes to address major multiple trauma codes that did not translate exactly between ICD-9-CM and ICD-10-CM. Specifically, CMS proposes to count IRF Patient Assessment Instruments (PAIs) that contain 2 or more of the ICD-10-CM codes from the three major multiple trauma lists that can be downloaded here. In order for patients with multiple fractures to qualify as meeting the 60 percent rule requirement for IRFs under the presumptive methodology, codes from the following lists could be used if combined as CMS describes in the proposal whereby (a) at least one lower extremity fracture is combined with an upper extremity fracture and/or rib/sternum fracture or b) fractures are present in both lower extremities:

List A: Major Multiple Trauma—Lower Extremity Fracture
List B: Major Multiple Trauma—Upper Extremity Fracture
List C: Major Multiple Trauma—Ribs and Sternum Fracture

  • Removed Codes and Other Proposals

CMS proposes to remove certain non-specific and arthritis diagnosis codes that were inadvertently reintroduced through the ICD-10-CM conversion process, and removing one ICD-10-CM code (G72.89 – Other specified myopathies) that was identified as being inappropriately applied to patients with generalized weakness, instead of to patients with clinically identified myopathies. Specifically CMS is proposing to remove 15 codes related to rheumatoid polyneuropathy with rheumatoid arthritis.

Request for Information
CMS also included a Request for Information (RFI) for continuing feedback on the Medicare Program. Feedback is requested on potential regulatory, sub-regulatory, policy, practice and procedural changes to make the delivery system less bureaucratic and complex, reduce burden for clinicians and providers, and increases quality of care while decreasing cost. CMS asked to be provided with clear and concise proposals that include data and specific examples. CMS will not respond to RFI comment submissions in the final rule, but rather will actively consider all input in developing future regulatory proposals or future sub-regulatory guidance. Ideas addressing opioid use disorder and other substance use disorders is a big area of interest.

IRF Classification Criteria
CMS is also specifically seeking stakeholder input on the 60 percent rule, including but not limited to, the list of 13 conditions used to evaluate 60 percent rule compliance.

Proposed Future Measures
Transfer of Information Measures
CMS is developing two Improving Medicare Post-Acute Care Transformation (IMPACT) Act-required measures regarding post-acute care providers’ Transfer of Information. It intends to specify these measures by October 1, 2018 and propose them for adoption in the FY 2021 IRF QRP, with data collection beginning “on or about” October 1, 2019. The measures are 1) Transfer of Information at Post-Acute Care Admission, Start or Resumption of Care from other Providers/Settings, and (2) Transfer of Information at Post-Acute Care Discharge, and End of Care to other Providers/Settings. Experience of Care and Patient-Reported Pain
CMS is developing an experience of care survey for IRFs, and survey-based measures will be developed from this survey. The survey explores experience of care across five main areas: (1) beginning stay at the rehabilitation hospital/unit; (2) interactions with staff; (3) experience during the rehabilitation hospital/unit stay; (4) preparing for leaving the rehabilitation hospital/unit; and (5) overall rehabilitation hospital/unit rating. CMS is also considering a patient-reported pain measure, Application of Percent of Residents Who Self-Report Moderate to Severe Pain (Short Stay) (NQF #0676), for future rulemaking.

Public Reporting
CMS proposes to publicly report data on six additional measures:

  • Application of Percent of Long-Term Care Hospital (LTCH) Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631) (assessment-based);
  • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674) (assessment-based);
  • Medicare Spending Per Beneficiary-PAC IRF QRP (claims-based);
  • Discharge to Community-PAC IRF QRP (claims-based);
  • Potentially Preventable 30-Day Post-Discharge Readmission Measure for IRF QRP (claims-based); and
  • Potentially Preventable within Stay Readmission Measure for IRFs (claims-based).

Comments on the proposed rule will be accepted until June 27, 2017. Discussion on the provisions of this proposed rule will be included as an agenda topic at the June Medical Rehabilitation Committee meeting.

RCPA will host its annual conference at the Hershey Lodge on October 10–13, 2017. At this large-scale, statewide event, the RCPA board of directors wants to continue the important tradition of recognizing individuals and organizations/facilities for their dedication and commitment to service. The following award categories have been created for this event and recognition:

  • RCPA Innovation Award. Presented to an individual or organization in recognition of significant innovation. Examples include cross-systems integration, physical/behavioral health integration, and implementation of new technologies.
  • Exemplary Service to RCPA Award. Presented to an individual or organization/facility that has shown a strong commitment and dedication in service to the association, its members, and related issues.
  • Legislative Leadership Award. Presented to an individual who has shown significant leadership and commitment to government affairs and legislative issues, on behalf of RCPA and its members.
  • Community Leadership Award. Presented to an individual in recognition of extending service and knowledge to the community at large, and efforts in helping the community understand the needs of individuals served by RCPA members. This can be for specific or short-term significant acts, or to recognize a career-long body of work.
  • Lifetime Achievement Award. Presented to an individual in honor of his/her significant, consistent, and enduring contribution throughout his/her career in support and furthering of the field.

At this time, RCPA is accepting nominations through an open solicitation of members (e.g., designated contact person, CEOs/executive directors, staff) and RCPA committees. Members may nominate one or more individuals/organizations in one or more categories. Nominations will be reviewed by a sub-group of the board of directors to make recommendations for final selection and approval by the full board.

Include the name/organization (if applicable) of the nominee, the award category, and a statement about why you believe the individual/organization should be honored. Nominations should be made by Friday, June 2, 2017. Please send nominations to Cindy Lloyd.

Award recipients are not limited to RCPA members and every award may not be presented annually. Please join the association in continuing this tradition and in offering nominations for those who deserve recognition for their significant contributions.

Today the Wolf Administration issued a document entitled Understanding Community HealthChoices vs HealthChoices to explain the similarities and differences between the two programs.

Community HealthChoices (CHC) is a new initiative that will increase opportunities for older Pennsylvanians and individuals with physical disabilities to remain in their homes. HealthChoices is Pennsylvania’s mandatory managed care program for 2.2 million Medical Assistance participants.

CHC was developed to: (1) enhance access to and improve coordination of medical care and; (2) create a person-driven, long-term support system in which people have choice, control, and access to a full array of quality services that provide independence, health, and quality of life. Long-Term Services and Supports help eligible individuals to perform daily activities in their homes such as bathing, dressing, preparing meals, and administering medications.

The document describes eligibility, timelines for implementation, and the CHC managed care organizations that will operate in each zone beginning in January, 2018.

The Traumatic Brain Injury (TBI) Advisory Board, which is established under section 1252 of the Federal Traumatic Brain Injury Act of 1996, will convene for their public meeting on Friday, May 5, 2017, from 10:00 am to 3:00 pm in the large conference room of the Community Center, 2nd Floor, Giant Food Store located at 2300 Linglestown Road, Harrisburg, PA 17110.

The Board assists the Department of Health in understanding and meeting the needs of persons living with traumatic brain injury and their families. This quarterly meeting will provide updates on a variety of topics including the number of people served by the Department of Health’s Head Injury Program (HIP). In addition, meeting participants will discuss budgetary and programmatic issues, community programs relating to traumatic brain injury, and available advocacy opportunities.

For additional information, or for persons with a disability who wish to attend the meeting and require an auxiliary aid, service, or other accommodation to do so, contact Michael Yakum, Division of Community Systems Development and Outreach, 717-772-2763, or for speech and/or hearing impaired persons, contact V/TT 717-783-6514 or the Pennsylvania AT&T Relay Service at 800-654-5984.

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Members are encouraged to save the date for an upcoming teleconference that will focus on lessons learned when New Jersey transitioned to Managed Long-Term Services and Supports (MLTSS). The teleconference is scheduled for Monday, May 1, 2017, at 2:00 pm. Presenting will be Mr. Adam Steinberg, President/CEO, Universal Institute Rehabilitation & Living Centers, and Ms. Susan Robinson, MA/CCC-SLP, MBA, Assistant Program Director, Drucker Brain Injury Center, MossRehab Hospital. They will partner to share experiences/issues that were encountered with their Traumatic Brain Injury (TBI) population and the solutions that were developed to address these issues, some of which include coordination of benefits (Medicare denials), cognitive rehabilitation therapy, etc. Please stay tuned; additional information will be forthcoming.

RCPA has joined the many community organizations across Pennsylvania that are now participants in the #FamilyFirstPA Coalition. #FamilyFirstPA is a campaign committed to enabling families to advocate for themselves in the ongoing effort to protect human services in the state budget process. The project works with provider, advocacy, faith-based, and community organizations to identify FAMILIES and provide social media platforms for them to share their stories of the challenges they face and the critical support their family has received from community services that rely on state and county funding. While these families may not know about funding streams, waivers, etc., they know what a difference critical human services are making in the lives of their families. In the current phase of the project, #FamilyFirstPA is seeking and interviewing families in four regions:

  • Lehigh Valley: Berks, Lehigh, Northampton Counties
  • Southeast: Bucks, Chester, Montgomery, Delaware Counties
  • South Central: Dauphin, Lancaster, York Counties
  • Southwest: Allegheny, Washington, Westmoreland Counties

More information about the project can be found online and providers and families are encouraged to “like,” participate in, and “follow” #FamilyFirstPA on Facebook and Twitter.