CMS Releases FY 2023 Inpatient Psychiatric Facility Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final 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. In response to comments received urging the CMS to recognize the inflationary pressures currently faced by IPFs and other providers, the final rule provides a 3.9% net rate increase, up from the proposed 2.9% net increase.

Key provisions of the final rule include a:

  • 3.9% increase in the IPF federal per diem base rate for providers that comply with the CMS IPF quality reporting (QR) program requirements, resulting in a rate of $865.63, up from the current $832.94.
  • 3.9% increase to the electroconvulsive therapy treatment rate from the current $358.60 to $372.67 for providers that comply with the CMS IPF QR program requirements.
  • Permanent limit of 5% for annual decreases to the wage index.
  • 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.
  • 54% increase in the outlier threshold amount from the current $16,040 to $24,630 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.

The MHA continues to review details of the final rule and will provide IPFs with an updated impact analysis for Medicare FFS patients in the near future. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report April 11, 2022

MHA Monday Report

MHA Covid-19 update

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Proposed Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023

The Centers for Medicare & Medicaid Services recently released a proposed ruleย to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities for fiscal year 2023, which begins Oct. 1, 2022. Key highlights of the proposal include …


CMS Releases FY 2023 Proposed Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services recently released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities for fiscal year 2023, which begins Oct. 1, 2022. Key highlights of the proposal include …


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Paul KeckleyThe Keckley Report

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โ€œLast Monday, Medicare Trustees released the 56th edition of their National Health Expenditures (NHE) Forecast for 2021-2030 which is widely used by policymakers and operators to gauge whatโ€™s ahead for U.S. healthcare. Regrettably, itโ€™s flawed.โ€

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The Circle of Life Awards recognize innovative palliative or end-of-life care providers that measure and evaluate the impact of their work on patients, family and/or the community. Part 1 applications for the 2023 awards will be accepted through May 31.

CMS Releases FY 2023 Proposed Rule for Inpatient Psychiatric Facilities

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 IPFโ€™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.

CMS Releases FY 2022 Inpatient Psych Facility Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (CMS) released a final rule ย to update the Medicare fee-for-service prospective payment system (PPS) for inpatient psychiatric facilities (IPFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.

The IPF rule will:

  • Provide a net 2.2 % increase to the federal per diem base rate, increasing it from $815.22 to $832.94 while also increasing the payment for electroconvulsive therapy treatment from $350.97 to $358.86. IPFs that fail to comply with CMS quality reporting program requirements are subject to a 2 percentage point reduction to the federal rates.
  • Result in a very slight decrease to the labor-related share from 77.3% to 77.2%
  • Decrease the cost outlier threshold by 4% from the current $14,630 to $14,030, which should result in slightly more cases qualifying for an outlier payment.
  • Update the IPF PPS teaching policy for IPF hospital closures and displaced residents, making it consistent with changes included in the FY 2021 inpatient PPS final rule.
  • Modify the IPF quality reporting program by:
    • Finalizing its proposal to incrementally begin requiring reporting of patient-level data information for numerators and denominators for nine chart-abstracted program measures. For FY 2023 payment determination, the CMS will permit voluntary patient-level data submission. For FY 2024 payment determination, IPFs will be required to submit the patient-level data for all the chart-abstracted measures.
    • Adopting the COVID-19 Healthcare Personnel Vaccination measure for the FY 2023 payment determination and subsequent years.
    • Replacing the Follow-up after Hospitalization for Mental Illness Measure with the Follow-up After Psychiatric Hospitalization measure for the FY 2024 payment determination and subsequent years.
    • Removing the Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care) measure starting with the FY 2024 determination.
    • Maintaining two measures that were proposed for removal: Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention (SUB-2/2a) and Tobacco Use Brief Intervention Provided or Offered and Tobacco Use Brief Intervention (TOB-2/2a).

The CMS continues to review input received on the agencyโ€™s Request for Information to close the health equity gap in the CMS quality programs to make reporting of health disparities based on social risk factors and race and ethnicity more comprehensive and actionable for facilities, providers and patients. The agency will respond to this input in a future rule.

The MHA will provide IPFs with an updated estimated impact analysis and summary of the final rule soon. Members with questions should contact Vickie Kunz at the MHA.

Association Submits Comments on Medicare Post-acute Care Proposed Rules

The MHA recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rules to update the Medicare fee-for-service (FFS) prospective payment systems for fiscal year (FY) 2022 for several post-acute care settings including:

The CMS proposes to adopt a new measure โ€” COVID-19 vaccination among healthcare personnel โ€” in the quality reporting program for these facilities and would collect data beginning Oct. 1, 2021, with the quarterly vaccination rate publicly reported on the Care Compare website. The MHA opposes the adoption of this measure prior to full approval by the Food and Drug Administration.

The CMS also included a request for information in each proposed rule seeking ways to close the health equity gap. While the MHA supports efforts to close the health equity gap, the comment letters expressed concern about the increased administration burden associated with additional quality measures and standardized patient assessment data elements. The MHA urged the CMS to honor its โ€œPatients Over Paperworkโ€ initiative and streamline, align and focus on measures that matter most for patient care and outcomes.

The MHA is preparing comments on the FY 2022 proposed rules to update the inpatient and long-term acute care hospital prospective payment systems and encourages hospitals to contact Vickie Kunz at the MHA by June 18 with any issues identified. Members will have access to the draft comment letters for these rules prior to the June 28 due date and are encouraged to submit their own comments. Members may direct questions on any of the proposed rules to Vickie Kunz at the MHA.