The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for inpatient psychiatric facilities (IPFs) for fiscal year (FY) 2023, which begins Oct. 1, 2022. Key highlights of the proposal include:
- A 2.9% increase to the IPF federal per diem base rate for providers that comply with the CMS IPF quality reporting program (QRP) requirements, resulting in a proposed rate of $856.80, up from the current $832.94.
- A 2.9% increase to the electroconvulsive therapy per diem payment rate from the current $358.60 to $368.87 for providers that comply with the CMS IPFQRP requirements.
- A permanent policy to smooth the impact of year-to-year IPF payment reductions related to decreases in the wage index. The CMS is proposing that an IPF’s wage index for FY 2023 and subsequent years would not be less than 95% of its prior year wage index.
- A slight increase in the labor-related share from the current 77.2% to 77.4%, which will increase payments for IPFs with a wage index greater than 1.0.
- A 51% increase in the outlier threshold amount from the current $16,040 to $24,270 to maintain estimated outlier payments at 2% of total estimated aggregate IPF PPS payments. This will result in fewer cases qualifying for an outlier payment.
- No changes to the IPFQRP, but the CMS included a request for information on several quality reporting-related topics:
- General framework that could be used across the CMS QRPs, including principles for selecting quality measures for stratified reporting and a discussion of the benefits and drawbacks of various reporting methods.
- Approaches that could be used in the IPFQRP to address health equity, including statistical methods to identify specific drivers of inequities and quality measures assessing facility performance in addressing health equity.
- The concepts described in the previous sections and thoughts about disparity measurement or stratification guidelines for the CMS QRPs.
The MHA will review details of the proposed rule and provide IPFs with an estimated impact analysis for Medicare FFS patients soon. The CMS is accepting comments until May 31. Members with questions should contact Vickie Kunz at the MHA.