On July 29, 2021, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that updates Medicare payment policies and rates for the Inpatient Psychiatric Facility (IPF) Prospective Payment System (PPS) for Fiscal Year (FY) 2022 and finalizes changes to the IPF Quality Reporting Program (QRP). CMS is publishing this final rule consistent with the requirements to update Medicare payment policies for IPFs on an annual basis. This fact sheet discusses the major provisions of the final rule.
FY 2022 Updates to the IPF Payment Rates
For FY 2022, CMS is updating the IPF PPS payment rates by 2.0% based on the final IPF market basket estimate of 2.7%, less a 0.7 percentage point productivity adjustment. In addition, the final rule updates the outlier threshold to maintain outlier payments at 2.0% of total payments. This adjustment will result in a 0.1% overall increase to aggregate payments. Total payments to IPFs are estimated to increase by 2.1% or $80 million in FY 2022 relative to IPF payments in FY 2021.
Updates to the IPF Teaching Policy
In FY 2022 and for subsequent years, CMS is adopting conforming changes to the IPF PPS teaching policy with respect to displaced residents from IPF hospital closures and closures of IPF teaching programs, thus aligning IPF teaching policy with changes that the Inpatient Prospective Payment System (IPPS) finalized in the FY 2021 IPPS/LTCH PPS final rule.
Inpatient Psychiatric Facility Quality Reporting Program (IPF QRP) Updates
Background on the IPF QRP
The IPF QRP requires IPFs to submit quality data to CMS in accordance with the IPF QRP’s requirements or receive a payment reduction of 2.0 percentage points to their annual update. CMS makes the IPF QRP data submitted by IPFs publicly available. This public reporting helps consumers make more informed decisions about their health care options.
COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP) Measure
For the FY 2023 payment determination and subsequent years, CMS is finalizing its proposal to adopt the COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP) measure to the IPF QRP. The measure addresses the quality priority of “Promote Effective Prevention & Treatment of Chronic Disease” through the Meaningful Measures domain of Preventive Care. The process measure was developed by the Centers for Disease Control and Prevention (CDC) to track COVID-19 vaccination coverage among HCP in the IPF setting. This measure will be reported using the COVID-19 Modules on the CDC’s National Healthcare Safety Network web portal.
Follow-up After Psychiatric Hospitalization (FAPH) Measure
For the FY 2024 payment determination and subsequent years, CMS is finalizing its proposal to adopt the Follow-up After Psychiatric Hospitalization (FAPH) measure to the IPF QRP. This claims-based measure uses an expanded cohort based on the Follow-up After Hospitalization for Mental Illness (FUH) measure, which is currently in the IPF QRP, to include patients with substance use disorders. It also includes more provider types than the FUH measure for who can provide follow-up care, such as primary care providers. CMS is finalizing its proposal to remove the FUH measure from the IPF QRP because the FAPH measure is more broadly applicable to a larger patient population.
Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or any Other Site of Care) Measure
CMS proposed to remove three chart-abstracted measures from the IPF QRP for the FY 2024 payment determination and subsequent years because the costs associated with these measures outweigh the benefits of continuing to retain them in the IPF QRP. CMS is finalizing removal of one of these measures (Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or any Other Site of Care)). The removal of this chart-abstracted measure reduces information collection burden by nearly 290,000 hours or approximately $0.5 million per year across all IPFs.
Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention (SUB-2/2a) Measure/ Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment (TOB-2/2a) Measure
CMS is not finalizing removal of the Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention (SUB-2/2a) measure or the Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment (TOB-2/2a) measure in response to comments indicating that these measures still provide benefits that outweigh the costs of retaining them in the IPF QRP measure set.
Transition to Patient-Level Reporting for Chart-Abstracted Measures
Additionally, CMS is finalizing its proposal to transition to patient-level reporting for chart-abstracted measures beginning with voluntary reporting of data for the FY 2023 payment determination and transitioning to required patient-level reporting for the FY 2024 payment determination and subsequent years. CMS believes that reporting of patient-level data will improve the accuracy of data accuracy submissions without increasing provider burden.
Closing the Health Equity Gap - RFI
Consistent with Executive Order 13985 on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, CMS solicited comments on addressing health equity in the IPF QRP. CMS is committed to addressing the significant and persistent inequities in health outcomes in the United States through improving data collection to better measure and analyze disparities across programs and policies. CMS is working to make health care quality more transparent to consumers and providers, enabling them to make better choices as well as promoting provider accountability around health equity. We sought feedback on ways to attain health equity for all patients through policy solutions. Specifically, CMS requested comment on future potential stratification of quality measure results by dual eligibility and other social risk factors in facility-specific reports, ways to improve demographic data collection, and the potential creation of a facility equity score to synthesize results across multiple measures and social risk factors. We received many comments on these topics and will consider the input provided for future development and expansion of our health equity quality measurement efforts.
Patient Experience of Care, Functional Outcomes, and Digital Measures-RFI
CMS continues to seek to develop a comprehensive set of quality measures to be available for widespread use for informed decision-making and quality improvement in the IPF setting. Therefore, CMS sought information on potential future measures in the following areas that CMS believes are important to stakeholders, but which are not covered in the current IPF QRP measure set: patient experience of care, functional outcomes, and digital measures. CMS received many comments on potential measure considerations and will consider the input provided for future measure development.
Data Validation Pilot Program-RFI
CMS also sought public input on elements of a potential data validation pilot program for the IPF QRP. CMS received comments with various considerations for a data validation pilot, and will consider this input in the development of future policies.
The final rule (CMS-1750-F) can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection/current
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