Tag: inpatient psychiatric facilities

CMS Releases FY 2027 Inpatient Psychiatric Facilities Proposed Rule

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities (IPF) for fiscal year (FY) 2027.

Key provisions of the proposed rule include:

  • Increasing the IPF prospective payment system (PPS) federal per diem base rate by a net 2.2% after all adjustments, from $892.87 to $912.58 for IPFs that comply with the CMS IPF Quality Reporting Program (QRP) requirements. The rate for providers that fail to report quality data is $894.74.
  • Increasing the electroconvulsive therapy payment per treatment by a net 2.2% from $673.85 to $688.73 for IPFs that comply with IPF QRP requirements and $675.26 for IPFs that fail to report data.
  • Increasing the labor-related share from the current 79% to 79.1%.
  • Continuing to use the pre-reclassification and pre-floor hospital inpatient PPS wage indexes while soliciting input on alternative data sources, such as Bureau of Labor Statistics data for the IPF wage index.
  • Decreasing the cost outlier threshold by 3.9%, from $39,360 to $37,820, to achieve the 2% target for outlier payments compared with aggregate payments.
  • Limiting total outlier payments to no more than 20% of a facility’s total payments. If finalized, facilities that exceed this cap would no longer receive outlier payments.
  • Updating the IPF QRP to:
    • Remove two measures:
      • Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention (SUB-2/2a) measure.
      • Tobacco Use Treatment Provided or Offered at discharge (TOB-3/3a) measure.
    • Implement the IPF-Patient Assessment Instrument (IPF-PAI) to collect and submit certain standardized patient assessment data beginning Oct. 1, 2027, for the FY 2029 payment determination. The CMS proposes two methods for IPF-PAI data submission: a free CMS-developed web application or two Fast Healthcare Interoperability Resource (FHIR) application programming interfaces. This would be the first time the CMS would include data submission via the FHIR standard in a QRP.

The MHA will provide facilities with a facility-specific impact analysis and additional details on the proposed rule in the coming weeks.  Members are encouraged to submit comments to the CMS by June 1 and notify Vickie Kunz at the MHA of any issues identified by May 22.

MHA Testifies in House Oversight Subcommittee, IMLC and AOT Legislation Passes Senate

Member News

The MHA provided testimony May 21 to the House Oversight Subcommittee on Public Health & Food Security on certain challenges related to behavioral health patients and the need for inpatient psychiatric beds across the state.

The House Oversight Subcommittee on Public Health & Food Security heard about patients facing behavioral health crises and their experiences with emergency department boarding based on insurance status. Taylor Alpert, government relations manager, advocacy, MHA shared data the association began collecting in 2023 on emergency department length of stay for patients with a behavioral health diagnosis. The data revealed more than 155 patients with a behavioral health diagnosis waiting in a hospital emergency department daily. Patients with Medicaid coverage experience longer wait times than those with commercial insurance, with one in three Medicaid patients spending more than 48 hours in the emergency department before being admitted or discharged.

Adam Carlson, senior vice president, advocacy, MHA outlined the process of the current preadmission screening assessment completed by providers for patients with a behavioral health diagnosis and illustrated for the committee how the process is unnecessarily complicated for those with Medicaid coverage. Carlson provided information on how member hospitals in the state are actively trying to expand or undergo capacity improvement projects to address this growing issue, but federal Medicaid threats, staffing gaps and state behavioral health beds per capita remain a challenge.

The MHA has been exploring opportunities to address this issue at the state level and has been working with the legislature on changing the statutory requirements for preadmissions screening timelines. Senate Bill (SB) 316, sponsored by Sen. Roger Hauck (R-Mount Pleasant), enforces a three week timeline for completing a preadmission screening requirement for patients covered by Medicaid and was introduced earlier this week. The MHA will continue to educate legislators on this issue and support SB 316 to expand the assessment responsibility to improve the delivery of care for behavioral health patients in Michigan.

Additional behavioral health legislation advanced in the Senate this week:

  • SB 303, also sponsored by Sen. Roger Hauck, renews Michigan’s participation in the Interstate Medical Licensure Compact. It passed unanimously in the Senate and now moves to the House Health Policy Committee.
  • SBs 219–222, introduced by Sen. Kevin Hertel (D-St. Clair Shores), update procedures for Assisted Outpatient Treatment to improve care for individuals experiencing behavioral health crises.

In the House, the Rules Committee passed House Bill 4246, sponsored by Rep. Phil Green (R-Millington), which would establish a nurse licensure compact agreement in Michigan. The MHA has expressed support for each of these legislative efforts.

Members with additional questions should contact Elizabeth Kutter at the MHA.

CMS Releases FY 2026 Proposed Rule for Inpatient Psychiatric Facilities

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient psychiatric facilities (IPFs) for fiscal year (FY) 2026.

Key provisions of the proposed rule include:

  • Increasing the IPF PPS federal per diem base rate by a net 1.8% after all adjustments, from $876.53 to $891.99. IPFs that fail to comply with the CMS IPF Quality Reporting Program (QRP) requirements would be paid using a base rate of $874.57.
  • Increasing the Electroconvulsive Therapy payment per treatment by a net 1.8% from $661.52 to $673.19 for IPFs that comply with IPF QRP requirements and $660.04 for IPFs that fail to report data.
  • Increasing the labor-related share from the current 78.8% to 78.9%.
  • Increasing the cost outlier threshold by 3.3% from the current $38,110 to $39,360 to achieve the 2% target for outlier payments as compared to aggregate IPF payments, decreasing the number of cases that qualify for outlier payments.
  • Revising facility-level adjustment factors:
    • Rural adjustment from 1.17 to 1.18
    • Teaching adjustment from 0.5150 to 0.7981
  • Updating the IPF QRP to:
    • Remove four measures beginning with the calendar year 2024 reporting period and or FY 2026 payment determination:
      • Facility Commitment to Health Equity.
      • COVID-19 Vaccination Coverage among Health Care Personnel.
      • Screening for Social Drivers of Health.
      • Screen Positive Rate for Social Drivers of Health.
    • Modify the reporting period of the 30-day-Risk-Standardized All Cause Emergency Department Visit Following an Inpatient Psychiatric Facility Discharge measure (referred to as the IPF ED Visit measure) from a one year, calendar year to a two-year, fiscal year period.
  • Seeking feedback on three topics through requests for information for:
    • A potential future star ratings system for IPFs.
    • Future measures for the IPF QRP.
    • Using the Fast Healthcare Interoperability Resources standard for electronic exchange of healthcare information for patient assessment reporting.

The CMS is seeking comments on opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries and other interested parties participating in the Medicare program.

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 June 10 and to contact Vickie Kunz at the MHA with questions and  issues identified by May 27.