Fact Sheets

Final FY 2016 Medicare Payment and Policy Changes for Inpatient Psychiatric Facilities

Final FY 2016 Medicare Payment and Policy Changes for Inpatient Psychiatric Facilities

On July 31, 2015, the Centers for Medicare & Medicaid Services (CMS) issued a final rule outlining fiscal year (FY) 2016 Medicare payment policies and rates for the Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS).

The final rule also updates the Inpatient Psychiatric Facilities Quality Reporting (IPFQR) Program, which requires facilities to report on quality measures or incur a reduction in their annual payment update. This final rule expands the measure sets in future fiscal years, removes superfluous measures and changes certain data reporting requirements.

The provisions implemented for FY 2016 are summarized below.

SUMMARY OF PAYMENT UPDATES AND CHANGES TO THE IPF PPS 
 
Federal Per Diem Base Rate Update : CMS is updating the estimated payments to IPFs in FY 2016 relative to estimated payments in FY 2015 by 1.5 percent (or $75 million). This amount reflects a 2.4 percent IPF market basket update less the productivity adjustment of 0.5 percentage point and less the 0.2 percentage point reduction required by law, for a net update of 1.7 percent. Estimated payments to IPFs are reduced by 0.2 percentage point due to updating the outlier fixed-dollar loss threshold amount.

Stand-alone IPF Market Basket and Labor Related Share for FY 2016 : CMS is adopting an IPF-specific market basket to replace the Rehabilitation, Psychiatric and Long-Term Care (RPL) market basket. The final IPF market basket is based on 2012 Medicare cost report data (the RPL market basket is based on 2008 data) for both freestanding and hospital-based IPFs. The final 2012-based IPF market basket has been modified slightly based on public comments. The FY 2016 Labor Related Share (LRS) of the IPF market basket is 75.2 percent, which is an increase from the FY 2015 LRS of 69.294 percent.

Wage Index : CMS is updating the Core Based Statistical Areas (CBSAs) with the Office of Management and Budget (OMB) Bulletin No. 13-01 and 2010 US Census Data. To implement this update, CMS is adopting the newest OMB delineations for the FY 2016 IPF PPS wage index using a 1-year transition with a 50/50 blended wage index for all providers. The FY 2016 IPF PPS wage index for each provider consists of a blend of fifty percent of the FY 2016 wage index using the current OMB delineations and fifty percent of the FY 2016 wage index using the revised OMB delineations.

As a result of the adoption of the new OMB delineations for the FY 2016 IPF PPS wage index, 37 IPF providers will have their status changed from rural to urban, and therefore lose their 17 percent rural adjustment. CMS is implementing a gradual phase-out of the rural adjustment, so that these 37 providers will receive two-thirds of the rural adjustment in FY 2016, one-third of the rural adjustment in FY 2017, and no rural adjustment for FY 2018 and subsequent years.

QUALITY MEASURE UPDATES AND OTHER IPFQR PROGRAM CHANGES

Background on the IPFQR Program: The IPFQR Program is a pay-for-reporting program established by the Affordable Care Act (ACA). IPFs are subject to a reduction of two percentage points in their annual payment update for failure to meet administrative and data reporting requirements on specified quality measures. The current IPFQR Program measure set includes 14 measures. In the FY 2016 final rule, CMS is increasing the IPFQR Program measure set to 16 measures by adding five measures and removing three measures. CMS is also finalizing several policies that will lessen the burden on reporting entities.

Measures Adopted for the FY 2018 Payment Determination and Subsequent Years

• One Tobacco Treatment Measure : TOB-3 - Tobacco Use Treatment Provided or Offered at Discharge, and a subset measure TOB-3a Tobacco Use Treatment at Discharge (NQF #1656), measure patients 18 and older who have used tobacco products and who were referred to counseling and received or refused a prescription for cessation medication upon discharge, and the subset measure, which includes only those patients who received counseling and cessation medication at discharge. IPFs will be required to begin collecting data for this measure January 1, 2016.
• One Substance Use Treatment Measure : SUB-2 - Alcohol Use Brief Intervention Provided or Offered, and a subset measure SUB-2a Alcohol Use Brief Intervention (NQF #1663), measure patients 18 and older to whom a brief substance-abuse intervention was provided, or offered and refused, and the subset measure, which includes only those patients who received a brief intervention. IPFs will be required to begin collecting data for this measure January 1, 2016.

Two Transition Record Measures :

• Transition Record with Specified Elements Received by Discharged Patients (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care) (NQF #0647) measures the percentage of patients discharged from an inpatient facility, or their caregivers, who received a transition record with specified elements at the time of discharge. For the FY 2018 payment determination, IPFs will be required to collect only two quarters of data, beginning on July 1, 2016. Beginning with the FY 2019 payment determination, IPFs will be required to report all four quarters of data.
• Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care) (NQF #0648) measures the percentage of patients discharged from an inpatient facility for whom a transition record was transmitted to the health care setting designated for follow-up care within 24 hours of discharge. For the FY 2018 payment determination, IPFs will be required to collect only two quarters of data, beginning on July 1, 2016. Beginning with the FY 2019 payment determination, IPFs will be required to report all four quarters of data.
• One Screening for Metabolic Disorders Measure : Screening for Metabolic Disorders measures the percentage of patients discharged with an antipsychotic prescription for which a structured metabolic screening for: (1) BMI; (2) blood pressure; (3) glucose or HbA1c; and (4) lipid panel was completed in the past year. For the FY 2018 payment determination, IPFs will be required to collect only two quarters of data, beginning on July 1, 2016. Beginning with the FY 2019 payment determination, IPFs will be required to report all four quarters of data.

Measures Removed 

Beginning with FY 2017 Payment Determination : CMS removed HBIPS 4 (Patients Discharged on Multiple Antipsychotic Medications) due to the loss of NQF endorsement, and because CMS believes that HBIPS-5 Patients Discharged on Multiple Antipsychotic Medications with Appropriate Justification sufficiently includes the data that HBIPS-4 was intended to collect.

Beginning with FY 2018 Payment Determination: CMS removed HBIPS 6 (Post-Discharge Continuing Care Plan Created) and HBIPS 7 (Post-Discharge Continuing Care Plan Transmitted to Next Level of Care Provider Upon Discharge) because these measures would be superfluous to and not as robust as the two transition measures CMS adopted for FY 2018 and subsequent years.

Other Changes

CMS also made the following changes to the data reporting requirements for IPFQR Program measures:

• Beginning with FY 2017 Payment Determination ; CMS will require IPFs to report measure data as a single, yearly count rather than by quarter and age because obtaining data for each quarter and by age is burdensome to providers and the resultant number of cases is often too small to allow for public reporting. In addition, CMS will require IPFs to report aggregate population counts for discharges as a single, yearly count rather than by quarter.
• Beginning with FY 2018 Payment Determination: CMS will give providers the option of obtaining one global sample for most measures, rather than having different sampling requirements for different measures. CMS believes that uniform sampling will decrease provider burden and allow for streamlined procedures.

The final IPF PPS rule can be downloaded from the Federal Register at: www.federalregister.gov/public-inspection. It will publish at the Federal Register on August 5, 2015.

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