On April 27, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a rule proposing updates for fiscal year (FY) 2019 to Medicare payment policies and rates for the Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) and the IPF Quality Reporting (IPFQR) Program. This proposed rule also includes a Request for Information (RFI) on promoting interoperability and electronic healthcare information exchange through possible revisions to the CMS Patient Health and Safety Requirements for Hospitals.
This fact sheet discusses major provisions of the proposed rule. The deadline for submitting comments on the proposed rule is June 26, 2018. The proposed rule (CMS-1690-P) can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection/.
Background on the IPF PPS
Effective January 1, 2005, CMS implemented the IPF PPS, a per diem PPS for routine inpatient hospital services and psychiatric services provided by IPFs for the diagnosis and treatment of mentally ill persons. The IPF PPS per diem base rate is adjusted to account for patient and facility characteristics that contribute to higher costs per day. The IPF PPS methodology also includes a payment adjustment for interrupted stays, additional payments for outlier cases, and a per treatment payment for electroconvulsive therapy (ECT) treatments. IPFs include psychiatric hospitals and certified psychiatric units in acute care hospitals and critical access hospitals.
Advancing My HealthEData: Request for Information from stakeholders
In addition to payment and policy proposals, CMS is releasing a Request for Information (RFI) to obtain feedback on positive solutions to better achieve interoperability or the sharing of healthcare data between providers. Specifically, CMS is requesting stakeholder feedback through a RFI on the possibility of revising Conditions of Participation related to interoperability as a way to increase electronic sharing of data by providers. This will inform next steps to advance this critical initiative.
In responding to the RFI, commenters should provide clear and concise proposals that include data and specific examples. CMS will not respond to RFI comment submissions in the final rule, but rather will actively consider all input in developing future regulatory proposals or future sub-regulatory guidance.
Meaningful Measures
Inpatient Psychiatric Facility Quality Reporting
The IPFQR Program is a pay-for-reporting program established by the Affordable Care Act. For FY 2019, CMS recommends the removal of 8 Inpatient Psychiatric Facility Quality Reporting Program measures beginning with the FY 2020 payment determination, and continuing for subsequent years.
|
Measure Name |
Removal Rationale |
|
Federal Data Registry Measure |
|
|
Influenza Vaccination Coverage Among Healthcare Personnel (NQF #0431) |
Costs associated with the measure outweigh the benefit of its continued use in the program |
|
Chart Abstracted Measures |
|
|
Alcohol Use Screening, SUB-1 (NQF #1661) |
Costs associated with the measure outweigh the benefit of its continued use in the program |
|
Tobacco Use Screening, TOB-1 (NQF #1651) |
Measure performance among IPFs is so high and unvarying that meaningful distinctions and improvements in performance can no longer be made (“topped-out”) |
|
Hours of Physical Restraint Use, HBIPS-2 (NQF #0640) |
Measure performance among IPFs is so high and unvarying that meaningful distinctions and improvements in performance can no longer be made (“topped-out”) |
|
Hours of Seclusion Use, HBIPS-3 (NQF #0641) |
Measure performance among IPFs is so high and unvarying that meaningful distinctions and improvements in performance can no longer be made (“topped-out”) |
|
Tobacco Use Treatment Provided or Offered at Discharge and Tobacco Use Treatment at Discharge, TOB-3 and TOB-3a, (NQF #1656) |
Costs associated with the measure outweigh the benefit of its continued use in the program |
|
Attestation Measures |
|
|
Use of an Electronic Health Record |
Costs associated with the measure outweigh the benefit of its continued use in the program |
|
Assessment of Patient Experience of Care |
Costs associated with the measure outweigh the benefit of its continued use in the program |
Measures are being removed due to several reasons, including limited opportunity for additional improvement, the ability to be replaced by other measures that are more strongly associated with desired patient outcomes for the particular topics, being duplicative, and because the measure captures performance data also captured under another, more broadly applicable measure.
In addition, CMS is proposing to no longer require facilities to submit the size of the global sample if they choose to apply the global sampling methodology beginning with the FY 2020 Payment Determination (that is, data reported during summer of CY 2019).
Summary of Proposed Payment Updates
Update to IPF Payments: CMS estimates IPF payments to increase by 0.98 percent or $50 million in FY 2019. This amount reflects a 2.8 percent IPF market basket update less the productivity adjustment of 0.80 percentage point and less the 0.75 percentage point reduction required by law, for a net market basket update of 1.25 percent. Additionally, estimated payments to IPFs are reduced by 0.27 percentage point due to updating the outlier fixed-dollar loss threshold amount.
Wage Index: CMS proposes to update the IPF wage index for FY 2019.
Proposed Technical Corrections to IPF Regulations
CMS proposes to update regulation language that is out-of-date. This includes replacing references to 1) ICD-9-CM with references to the current ICD-10-CM and 2) the former Rehabilitation, Psychiatric, and Long-Term Care (RPL) market basket with references to the current IPF-specific market basket. These proposed corrections do not change any existing policy.
IPF PPS Refinements Comment Solicitation
CMS is also inviting public comment on differences in IPF costs, patient mix, and provision of drugs and laboratory services to better inform the refinement process.