Medical Rehab

On November 23, the leadership of the Office of Mental Health and Substance Abuse Services (OMHSAS), including Deputy Secretary Dennis Marion and Medical Director Dr. Dale Adair, provided a webcast presentation on the development of Applied Behavior Analysis (ABA) services for children with an Autism Spectrum Disorder (ASD). The webcast to more than 130 RCPA members reviewed the current concepts and recommendations developed by a clinical work group, assisting OMHSAS in the development of ABA medical necessity guidelines, clarifying the authorization pathway for Behavioral Health Rehabilitation Services for children and adolescents diagnosed with Autism Spectrum Disorder.

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The Centers for Medicare and Medicaid Services released a Request for Information (RFI) in the November 20, 2015 Federal Register. The RFI is geared to Inpatient Rehabilitation Facilities (IRFs) and will assist in the design and development of a survey regarding patient and family member experiences with the care received in the IRF. Comments will be received until 5:00 pm on Tuesday, January 19, 2016.

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As a reminder to members, inpatient rehabilitation facility (IRF) quality reporting program (QRP) data collected between April 1, 2015 and June 30, 2015 must be submitted by Sunday, November 15, 2015. Additional information, including a list of the quality measure data that is due, is available on the IRF Quality Reporting Spotlight and Announcements web page.

Home Care Rule
Linda Drummond, RCPA director, Intellectual and Developmental Disabilities Division, is working with the PA State Independent Living Council and Temple’s Institute on Disabilities, to determine the impact of the new US Department of Labor’s Home Care Rule on providers. Please share any questions, issues, or recommendations regarding this rule with Linda Drummond, for inclusion with the document being developed for the Department of Human Services, on areas of concern impacting service providers on implementation of this rule. This may be impacting LifeSharing/Shared Living, Participant Directed, and Companionship services.

Today, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule, Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies. This revises the discharge planning requirements for hospitals (including inpatient rehabilitation facilities and long term care hospitals), critical access hospitals, and home health agencies; these requirements must be met in order to participate in the Medicare and Medicaid programs. The proposed rule also implements the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, which strives to improve consumer transparency and beneficiary experience during the discharge planning process, by developing a discharge plan based on the goals, preferences, and needs of each patient.


Under the proposed rule, hospitals would be required to develop a discharge plan within 24 hours of admission or registration and complete a discharge plan before the patient is discharged home or transferred to another facility. These requirements will apply to all inpatients, and certain types of outpatients, including patients receiving observation services, patients undergoing surgery (or other same-day procedures where anesthesia or moderate sedation is used), and emergency department patients who have been identified as needing a discharge plan. In addition, hospitals will be required to:

  • Provide discharge instructions to patients who are discharged home;
  • Have a medication reconciliation process with the goal of improving patient safety by enhancing medication management;
  • For patients who are transferred to another facility, send specific medical information to the receiving facility; and
  • Establish a post-discharge follow-up process.

The proposed rule is scheduled to be published in the November 3, 2015 Federal Register with a 60-day comment period.

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The Centers for Medicare and Medicaid Services recently identified a system’s error when calculating payments for inpatient rehabilitation facility (IRF) providers. To correct this error, a special wage index under the fiscal year 2016 IRF prospective payment system (PPS) will need to be implemented. This system fix will be implemented sometime around October 26, 2015. Providers’ Medicare administrative contractor will mass adjust affected IRF PPS claims with dates of service on or after October 1, 2015. No provider action is required.

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In the October 1, 2015 Federal Register, the Centers for Medicare and Medicaid Services (CMS) released a Request for Information (RFI) to seek public comment related to new provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). This is for the design of the new Medicare physician payment system that will replace the Sustainable Growth Rate (SGR) formula, which includes the merit-based incentive payment system, alternative payment models, and a physician-focused payment model. Originally, comments were due by November 2, 2015; however, an extension of the comment period for an additional 15 days was published in the October 20, 2015 Federal Register, indicating the new due date as Tuesday, November 17, 2015.

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The Centers for Medicare and Medicaid Services (CMS) has announced that a special open door forum for inpatient rehabilitation facilities (IRFs) will be held on Tuesday, October 20, 2015, from 2:00 to 3:00 pm. During the call, CMS will discuss the upcoming Dry Run for IRFs Provider Performance reports on All-Cause Unplanned Readmissions for 30-day post discharge from IRFs. This will also include timeline and content of facility dry run reports that will be disseminated to IRFs from November 3 through December 3, 2015.

To participate in this special open door forum call:
Dial: 1-866-402-6263
Conference ID #: 55982595

The Departments of Human Services and Aging have extended an invitation for Managed Care Organizations (MCOs) and Home and Community-based Service (HCBS) providers to convene to discuss Community HealthChoices (CHC). The purpose of the meeting is to begin the conversation between the MCOs and providers, as the transition from fee-for-service to managed care begins.

The meeting has been scheduled for Wednesday, November 4, 2015, from 1:00 to 3:00 pm at the Radisson Hotel located at 1150 Camp Hill Bypass, Camp Hill, PA 17011.

On Thursday, October 1, 2015, at 10:00 am, the House Energy and Commerce Health Subcommittee will hold a hearing, “Examining Potential Ways to Improve the Medicare Program,” that will include the review of three bills that strive to strengthen Medicare. The bills that will be examined include:

  • HR 1934, the Cancer Care Payment Reform Act, which would build on the promise of new provider delivery model development envisioned in the sustainable growth rate replacement policy, enacted into law earlier this year. This bill would establish a national oncology medical home demonstration project to improve Medicare payments for cancer care.
  • Draft legislation that would make changes to documentation and face-to-face requirements for home health providers under the Medicare program.