On Apr. 3, CMS issued updated Medicare payment policies and rates.
CMS proposed rule to update Medicare inpatient psychiatric facilities prospective payment system (IPF PPS) and quality reporting (IPFQR) for 2025; issued fact sheet.
Sought input on potential revisions to the IPF PPS facilities and patient assessments.
Revisions support high-quality behavioral health treatment in inpatient psychiatric facilities, consistent with Biden Administration's focus on mental health crisis, #139283
IPF Payment Rates
Updated the IPF PPS payment rates by 2.7%, based on the proposed 2021-based IPF market basket increase of 3.1% less a proposed 0.4% point productivity adjustment.
Proposed that if more recent data becomes available CMS will use data to determine 2025 market basket update % increase and the productivity adjustment in final rule.
Updated outlier threshold so estimated outlier payments remain at 2% of total pays.
Increased IPF PPS electroconvulsive therapy (ECT) per treatment amount to $660.30.
IPF PPS Patient-Level Adjustment Factors
Revised methodology for determining payment rates under the IPF PPS for psychiatric hospitals and psychiatric units based on a review of data collected in prior years.
Patient-level adjustments include severity diagnosis related groups assignment of the patient’s principal diagnosis, comorbidities, age, and variable per diem adjustments.
Updated the regression model used to determine IPF PPS payment adjustments to reflect costs, claims data for 2019, 2020, 2021; implement in budget-neutral manner.
Proposed to change the patient-level adjustments for which CMS adjusts payment.
Wage Index Update
For fiscal year 2025, proposed to adopt the core-based statistical area (CBSA) labor market areas for the IPF PPS wage index as defined in the OMB Bulletin 23-01.
Providers transitioning from rural to urban based on revisions receive two-thirds of the rural adjustment in FY 2025, and one-third of the rural adjustment in FY 2026.
Further, specified that these providers would receive no rural adjustment in FY 2027.
Provided 5% cap on any decrease to wage index from its wage index in the prior year.
Cost Reporting
Clarified eligibility criteria for the option to elect to file an all-inclusive cost report.
CMS will issue revised cost reporting guidance and make operational changes to improve quality of ancillary charge data on IPF claims by enforcing eligibility criteria.
For cost reporting periods beginning on or after Oct. 1, 2024, only government-owned and tribally owned IPFs will be permitted to file an all-inclusive rate cost report.
IPFQR Program Reporting
Adopted one new measure, the 30-Day Risk-Standardized All-Cause Emergency Department Visit Following an Inpatient Psychiatric Facility Discharge measure.
Assessed proportion of patients 18 and older with an emergency department visit.
Required IPFs to submit patient-level quality data quarterly instead of annually.
Patient Assessment Instrument
Issued request for information (RFI) about IPF PPS patient assessment instrument.
CAA required IPFs to collect standardized patient assessment data on set categories.
Identify meaningful data elements for collection appropriate for acute inpatient psychiatric care setting and criteria for development, implementation of instrument.
PF PPS Facility-Level Adjustment Factors
Issued RFI on potential revisions to the IPF PPS facility-level adjustments in the future.
Based on the results of more recent IPF cost and claim analysis; defined sources.
Consultation
Comments on proposed updates must be submitted by May 28, 2024.
Jul. 2024 CMS Final Rule
On Jul. 31, 2024, CMS issued final rule to finalize patient-level adjustment factors and increase per-treatment amount for ECT to $661.52, adopted new CBSA wage index.
CMS is not finalizing its proposal to require IPFs to submit data on a quarterly basis for patient-level measures, data reporting for patient-level measures will remain annual.
CMS is updating the IPF PPS payment rates by 2.8%, based on 2021-based IPF market basket increase, which also considers the reduction in the productivity adjustment.
IPF PPS payment rates for psychiatric hospitals and psychiatric units will be based on based on a review of the data collected in prior years per the Social security act.
Summarizes comments received re revisions to IPF PPS facility-level adjustment factors and development of standardized IPF Patient Assessment Instrument (IPF-PAI).
IPFs participating in IPFQR Program will be required to report starting rate year 2028.
CMS determined that some IPFs may be unable to meet patient-level reporting on a quarterly basis and decided to maintain the current annual reporting requirements.
Final rule is scheduled to be published in fed register on Aug. 7, effective Oct. 1, 2024.
Aug. 2024 CMS Federal Register Final Rule
On Aug. 7, 2024, CMS published final action in federal register, effective Oct. 1, 2024.
