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Comment

The Centers for Medicare and Medicaid Services (CMS) released a Request for Information (RFI) that seeks public input on the concept of establishing a National Directory of Healthcare Providers and Services (NDH) that could serve as a centralized data hub for health care provider, facility, and entity directory information nationwide. The goal of this directory is to improve access to care, reduce clinician burden, and support interoperability throughout the health care sector.

CMS is seeking comment on how a CMS-led directory could reduce directory maintenance burden on providers and payers by creating a single, centralized system, promoting real-time accuracy for patients.

Feedback obtained in response to the RFI will aid CMS’ understanding of the current landscape of health care directories, as well as information useful to CMS when considering an NDH. CMS is specifically requesting public feedback on the NDH concept and potential benefits, provider types, entities and data elements that could be included to create value for the health care  industry, the technical framework for an NDH, priorities for a possible phased implementation, and prerequisites and actions CMS should consider taking to address potential challenges and risks.

The RFI will be published in the Federal Register on October 7, 2022. Comments on the RFI will be accepted through December 6, 2022.

The Centers for Medicare and Medicaid Services (CMS) has released a Request for Information (RFI) that seeks public input on accessing healthcare and related challenges, understanding provider experiences, advancing health equity, and assessing the impact of waivers and flexibilities provided in response to the COVID-19 Public Health Emergency (PHE).

The Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs RFI furthers CMS’ commitment to engaging and learning from partners, communities, and individuals across the health system to inform how we can better support the populations we serve. In alignment with Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, the CMS Strategic Plan Pillar: Health Equity, and the CMS Framework for Health Equity (2022–2032), this RFI aims to gather feedback and perspectives related to challenges and opportunities for CMS to embed health equity into their efforts encouraging innovation, reducing burden, and creating efficiencies across the healthcare system.

CMS is seeking to better understand individual and community-level burdens, health-related social needs, and opportunities for improvement that can reduce disparities and promote efficiency and innovation across programs. CMS is requesting information related to strategies that successfully address drivers of health inequities, including opportunities to address social determinants of health and challenges underserved communities face in accessing comprehensive, quality care. For example, challenges accessing care may include understanding coverage options, receiving culturally and linguistically appropriate care, accessing oral health services, and accessing comprehensive and timely healthcare services and medication.

Through this RFI, CMS also seeks to better understand the factors impacting provider wellness and learn more about the distribution of the healthcare workforce. CMS is particularly interested in understanding the greatest challenges for healthcare workers in meeting the needs of individuals, and the impact of CMS policies, documentation, and reporting requirements, operations, and communications on provider experiences.

Comments received in response to the Make Your Voice Heard RFI will be used to identify opportunities for improvement and to increase efficiencies across CMS programs. In addition, CMS hopes to learn how specific programs have benefited providers, practices, and the people served.

CMS encourages comments from all interested stakeholders, in particular, patients and their families, providers, clinicians, consumer advocates, and healthcare professional associations. CMS also encourages comments from individuals serving and located in underserved communities and from all CMS stakeholders serving populations facing disparities in health and healthcare. The RFI is open for a 60-day public comment period.

Comments must be received by November 4, 2022, to be considered.

The Department of Human Services (DHS) announced they will be accepting comments on Pennsylvania’s Final Statewide Transition Plan (STP) for Home and Community-Based Services (HCBS). This plan applies to Medicaid Waivers under the Office of Long-Term Living (OLTL), Office of Developmental Programs (ODP), and Office of Child Development & Early Learning (OCDEL). The notice is below and includes additional information about upcoming webinars.

HCBS Settings Rule – Background

CMS published the HCBS Rule, which amends the Medicaid regulations for HCBS waivers under section 1915(c) of the Social Security Act. The HCBS Rule supports enhanced quality of programs and services and adds protections for individuals receiving services. The HCBS Rule reflects CMS’ intent to ensure all individuals receiving services and supports through Medicaid waivers have full access to the benefits of community living, including receiving services in the most integrated setting. The HCBS Rule includes a provision requiring states to develop a transition plan to ensure that services will meet federal requirements by March 2023.

Statewide Transition Plan

The Department received initial approval of its STP on August 30, 2016, which can be accessed at the Department’s HCBS Stakeholder Waiver and Planning Team web page.

To receive final approval of Pennsylvania’s STP, the Department is required to complete the following remaining steps and submit an updated STP with this information included:

  • Complete a thorough, comprehensive site-specific assessment of all HCBS settings, implement necessary strategies for validating the assessment results, and include the outcomes of this assessment within the STP;
  • Draft remediation strategies and a corresponding timeline that will resolve issues that the site-specific settings assessment process and subsequent validation strategies uncovered by the end of the HCBS rule transition period (March 17, 2023);
  • Outline a detailed plan for identifying settings that are presumed to have institutional characteristics, including qualities that isolate HCBS beneficiaries, as well as the proposed process for evaluating these settings and preparing for submission to CMS for review under heightened scrutiny;
  • Develop a process for communicating with beneficiaries that are currently receiving services in settings that the state has determined cannot or will not come into compliance with the HCBS settings rule by March 17, 2023; and
  • Establish ongoing monitoring and quality assurance processes that will ensure all settings providing HCBS continue to remain fully compliant with the rule in the future.

This information is included in Pennsylvania’s Final STP for public comment. A presentation providing a general overview of the HCBS Rule and Pennsylvania’s Final STP will be recorded by the Department and posted by the end of August to prepare stakeholders for public comment. Information about where to access the presentation will be published when it is available.

As outlined in the public comment section below, the Office of Child Development and Early Learning (OCDEL), Office of Developmental Programs (ODP), and Office of Long-Term Living (OLTL) will each hold webinars to go over information in Pennsylvania’s STP that is specific to their waivers and programs. Public comment will be accepted during each of these webinars.

Public Comment

Pennsylvania’s Final STP is available for a 30-day public comment period at the Department’s HCBS STP web page. Comments will be accepted no later than 11:59 pm on September 22, 2022. Stakeholders may provide public comment through one of the following methods:

  1. Electronic comments submitted via email
    1. Stakeholders are asked to use the subject header “PA Final STP” and submit comments to this mailbox.
  2. Written comments submitted via mail
    1. Mailing address: Department of Human Services, Office of the Secretary, P. O. Box 2675, Harrisburg, PA 17105-2675.
  3. Verbal and written comments during public comment webinars
    1. The following dates and times below are for stakeholders to participate in the public comment webinars:
      1. Webinar Specific to STP Information for OCDEL
        September 12, 2022
        9:00 am – 10:00 am
        Please register for the webinar via email.
      2. Webinars Specific to STP Information for ODP
        September 8, 2022
        10:00 am – 12:00 pm
        Please register for the webinar.
        September 12, 2022
        1:00 pm – 3:00 pm
        Please register for the webinar.
      3. Webinar Specific to STP Information for OLTL
        September 15, 2022
        2:00 pm – 3:00 pm
        Please register for the webinar.

When submitting electronic or written comments, it is recommended that you include the following information:

  • The page number or Appendix where the information you are commenting on is located; and
  • Which office (OCDEL, ODP, or OLTL) the comment applies to, if applicable.

Image by Werner Moser from Pixabay

Following up on the previous RCPA Alert regarding the Pennsylvania Insurance Department’s Notice for Public Comment, please note that comments may be submitted via email OR sent directly to the following address:

PA Insurance Department
Attn: Katie Merritt, Policy Director
1326 Strawberry Square,
Harrisburg, PA 17120

Comments will be accepted until Friday, August 5, 2022.

The department is looking to hear from consumers, advocates, and other organizations about challenges they have experienced accessing various provider types. The notice is divided into two categories: physical health services and behavioral health services, including substance use disorder treatment.

On behalf of its behavioral health provider members, RCPA is compiling comments to submit to PID, although members who prefer to submit their comments and experiences on their own are encouraged to do so. Providers wanting to submit comments as part of an RCPA response can send them to Drug and Alcohol Division Director Jason Snyder. PID will accept comments until Friday, August 5, so please submit your comments to RCPA by Friday, July 29.

The Pennsylvania Insurance Department (PID) is studying the availability of providers in various specialties, including behavioral health, and geographic areas. This is an opportunity for behavioral health providers, including drug and alcohol and mental health providers, to share their challenges in finding and employing specialists required by state regulations and payer contracts and the subsequent access issues that result.

The goal of the study is to understand areas of need based on the current availability of providers to accept new patients, the amount of time it takes to get an appointment with these providers, and the network adequacy considerations based on the findings. PID is seeking public comment from organizations, consumer advocates, providers, and consumers about their experience with getting an appointment or finding available specialists.

On behalf of its behavioral health provider members, RCPA is compiling comments to submit to PID, although members who prefer to submit their comments and experience on their own are encouraged to do so. Providers wanting to submit comments as part of an RCPA response can send them to Drug and Alcohol Division Director Jason Snyder. PID will accept comments until Friday, August 5, so please submit your comments to RCPA by Friday, July 29.

More information can be found in PID’s published Notice for Public Comment.

ODP Announcement 22-018 is to make stakeholders aware that the proposed renewals of the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waivers are available for public review and comment. There is a 30-day public comment period on the information proposed in the waivers that starts on February 12, 2022, and ends on March 14, 2022.