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 federal fiscal year (FY) 2025.
Key provisions of the proposed rule include:
- Increasing the Electroconvulsive Therapy (ECT) payment per treatment by 71% from $385.58 to $660.30 for IPFs that comply with IPF quality reporting program (QRP) requirements and $647.45 for IPFs that fail to report data.
- Decreasing the IPF PPS federal per diem base rate by a net 2.3% after all adjustments, from $895.63 to $874.93. IPFs that fail to comply with the CMS IPF Quality Reporting Program (QRP) requirements would be paid using a base rate of $857.89.
- Updating the wage index using the most recent Office of Management and Budget (OMB) statistical area delineations based on the 2020 Decennial Census.
- Increasing the labor-related share from the current 78.7% to 78.8%.
- Increasing the cost outlier threshold by 6% from the current $33,470, to $35,590 to achieve the 2% target for outlier payments as compared to aggregate IPF payments, decreasing the number of cases that qualify for outlier payments.
- Maintaining the existing facility-level adjustment factors for rural location, teaching status and emergency department.
- Changes to the IPFQR Program:
- Adopting the 30-Day Risk-Standardized All-Cause Emergency Department (ED) Visit Following an IPF Discharge measure beginning with the FY 2027 payment determination.
- Modifying reporting requirements to require IPFs to submit patient-level data on a quarterly basis.
- Requesting comments on future revisions to the IPF PPS facility-level adjustment factors and development of the new standardized IPF Patient Assessment Instrument (IPF-PAI), required by the Consolidated Appropriations Act, 2023, for rate year 2028.
The MHA will provide IPFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by May 28 and to contact the MHA with issues identified by May 21.
Members with questions should contact Vickie Kunz at the MHA.