Tag: inpatient psychiatric facilities

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.

CMS Releases FY 2025 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 (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.