On July 27, 2023, the Facilities for Medicare & Medicaid Providers (CMS) issued a last rule (CMS-1783-F) to replace Medicare fee insurance policies and charges for the Inpatient Psychiatric Facility Potential Cost System (IPF PPS) for fiscal yr (FY) 2024. CMS is publishing this last rule in step with the authorized necessities to replace Medicare fee insurance policies for IPFs on an annual foundation.
This reality sheet discusses the main provisions of the ultimate rule, together with annual updates to the possible fee charges and the outlier threshold. As well as, the rule finalizes CMS’s proposals to rebase and revise the IPF market basket and to change laws to permit hospitals to open and start billing Medicare for an excluded IPF unit anytime inside the fee reporting yr. CMS believes it will assist enhance entry to important inpatient psychiatric providers and accessible beds.
This last rule additionally features a abstract of the request for info (RFI) that was included within the proposed rule to tell future revisions to the IPF PPS, that are required by the Consolidated Appropriations Act, 2023 (CAA, 2023) (Pub. L. 117- 328).
Lastly, for the IPF High quality Reporting (IPFQR) Program, CMS is adopting 4 new measures, modifying one current measure, eradicating two current measures, and adopting and implementing a knowledge validation pilot. Three of the measures being adopted will assist combine details about facility dedication to well being fairness and social drivers of well being knowledge into IPF high quality efficiency measurement as a part of our broader dedication to well being fairness. One of many measures being adopted is a affected person expertise survey measure, which satisfies a requirement of the CAA, 2023, to undertake such a measure no later than FY 2031. CMS can be codifying the IPFQR Program’s necessities and insurance policies at 42 C.F.R. § 412.433 in alignment with CMS’s different high quality reporting packages.
The FY 2024 IPF PPS last rule might be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection/2023-16083/medicare-program-fy-2024-inpatient-psychiatric-facilities-prospective-payment-system—rate-update.
Modifications to Funds Below the IPF PPS
Updates to IPF Cost Charges
Whole estimated funds to IPFs are estimated to extend by 2.3%, or $70 million, in FY 2024 relative to IPF funds in FY 2023. For FY 2024, CMS is updating the IPF PPS fee charges by 3.3%, primarily based on the ultimate 2021-based IPF market basket enhance of three.5% much less a 0.2 proportion level productiveness adjustment. Moreover, CMS is updating the outlier threshold in order that estimated outlier funds stay at 2.0% of complete funds. CMS estimates that updating the outlier threshold will end in a 0.9% lower to combination funds. (Notice: Resulting from rounding, the three.3% enhance to fee charges and the 0.9% lower because of outlier fee adjustments end in a 2.3% general enhance in IPF funds).
Rebasing and Revising the IPF PPS Market Basket
For the reason that IPF PPS was carried out, the market basket used to replace IPF PPS funds has been rebased and revised to mirror more moderen knowledge on IPF value constructions. CMS final rebased and revised the IPF market basket within the FY 2020 IPF PPS last rule, the place a 2016-based IPF market basket, utilizing Medicare value report knowledge for each Medicare-participating freestanding psychiatric hospitals and hospital-based psychiatric items, was adopted. For FY 2024, we’re adopting a 2021-based IPF market basket and finalizing adjustments to the market basket value weights, worth proxies, the market basket proportion enhance, and labor-related share.
Replace to the Labor-Associated Share
Because of the rebasing and revising of the IPF market basket, the ultimate FY 2024 labor-related share (LRS) is 78.7%, which is a 1.3 proportion level enhance relative to the FY 2023 LRS of 77.4%. This larger labor-related share is primarily as a result of incorporation of the 2021 Medicare value report knowledge, which elevated the Compensation value weight by 0.9 proportion level in comparison with the 2016-based IPF market basket.
Modification to the Regulation on Excluded Items Paid Below the IPF PPS
In response to elevated behavioral well being wants nationwide, together with the necessity for the provision of inpatient psychiatric beds, CMS is finalizing adjustments to the laws to permit higher flexibility for hospitals to open and invoice Medicare for brand spanking new excluded inpatient psychiatric distinct half items. Starting in FY 2024, CMS is amending the laws at 42 C.F.R. § 412.25(c) to permit hospitals to open a brand new excluded IPF unit at any time throughout the cost-reporting interval reasonably than solely firstly of a hospital’s cost-reporting interval. This transformation will permit a hospital’s excluded IPF unit to begin being paid below the IPF PPS if the hospital supplies not less than 30 days’ discover to the CMS Regional Workplace and Medicare Administrative Contractor. CMS believes this transformation will alleviate pointless burden and administrative complexity positioned upon hospitals when opening new excluded psychiatric items, serving to to broaden entry to behavioral well being care in keeping with the CMS Behavioral Health Care Strategy.
RFI to Inform the Revisions to the IPF PPS Required by the Consolidated Appropriations Act, 2023 (CAA, 2023)
New provisions in the CAA, 2023, require CMS to revise funds below the IPF PPS for Fee Yr 2025 (which, below the IPF PPS, is FY 2025) because the Secretary determines applicable. Accordingly, CMS included an RFI within the proposed rule that will probably be used to tell future fee revisions. Within the proposed rule, CMS addressed the precise varieties of knowledge and knowledge that the CAA, 2023 suggests CMS could accumulate and solicited feedback on further knowledge and knowledge that may very well be collected to tell future fee revisions. Commenters provided varied strategies of affected person traits and components we might contemplate for evaluation. CMS will take these feedback into consideration for future rulemaking.
Background on the Inpatient Psychiatric Facility High quality Reporting (IPFQR) Program
The IPFQR Program requires that every one IPFs paid below the IPF PPS should submit sure specified high quality knowledge to CMS in a kind and method and throughout the timeframes that CMS prescribes. IPFs that don’t submit the desired knowledge on high quality measures as required by the IPFQR Program obtain a 2.0 proportion level discount to their annual fee replace.
The IPFQR Program goals to evaluate and foster enchancment within the high quality of care offered to sufferers in IPFs. By requiring IPFs to submit high quality knowledge to CMS yearly and by publicly reporting these knowledge below the IPFQR Program, CMS ensures that IPFs are conscious of greatest practices and that sufferers could make extra knowledgeable choices about their healthcare choices.
The IPFQR Program started amassing knowledge in FY 2013. Every year because the IPFQR Program started, roughly 97% of taking part IPFs meet all IPFQR Program necessities and obtain their full fee replace.
Remaining Updates to the IPFQR Program
CMS is adopting three measures centered on well being fairness for the IPFQR Program. First, CMS is adopting the Facility Dedication to Well being Fairness measure, starting with reporting of CY 2024 knowledge for the FY 2026 fee willpower. This measure assesses an IPF’s dedication to well being fairness by asking the IPF to attest to its efforts to handle well being fairness throughout 5 domains: (1) Fairness is a Strategic Precedence; (2) Information Assortment; (3) Information Evaluation; (4) High quality Enchancment; and (5) Management Engagement. Second, CMS is adopting the Screening for Social Drivers of Well being (SDOH) measure starting with voluntary reporting of CY 2024 knowledge adopted by obligatory reporting of CY 2025 knowledge for the FY 2027 fee willpower. This measure assesses the proportion of sufferers, aged 18 years and over on the time of admission, who’re screened for 5 particular health-related social wants (HRSNs) — meals insecurity, housing instability, transportation wants, utility difficulties, and interpersonal security. Third, CMS is adopting the Display Optimistic Fee for SDOH measure starting with voluntary reporting of CY 2024 knowledge adopted by obligatory reporting of CY 2025 knowledge for the FY 2027 fee willpower. This course of measure assesses the p.c of sufferers screened below the Screening for SDOH measure who display optimistic for every of the 5 HRSNs, which is calculated and reported as 5 separate charges for every HRSN.
CMS can be adopting one affected person expertise of care measure (the Psychiatric Inpatient Expertise (PIX) survey measure), which might fulfill the requirement below the CAA, 2023, so as to add a measure to the IPFQR Program on a affected person’s expertise of care no later than FY 2031. The PIX survey measure calculates scores as 5 separate charges, one for every of the 4 domains (relationship with remedy crew, nursing presence, remedy effectiveness, and therapeutic surroundings) and an general rating, primarily based on affected person responses to a 23-item survey administered starting 24 hours previous to discharge. CMS is adopting the PIX survey measure starting with voluntary reporting of CY 2025 knowledge adopted by obligatory reporting of CY 2026 knowledge for the FY 2028 fee willpower.
As well as, CMS is modifying the COVID-19 Vaccination Protection Amongst Healthcare Personnel measure, starting with the fourth quarter of CY 2023 and affecting the FY 2025 fee willpower. The present model of this measure reviews solely on whether or not healthcare personnel (HCP) had obtained the first vaccination sequence for COVID-19, whereas the modification of this measure would require IPFs to report the cumulative variety of HCP who’re up-to-date with really helpful COVID-19 vaccinations in accordance with the CDC’s most up-to-date steering. CMS has proposed the identical modification to this measure for different high quality reporting packages, together with, however not restricted to, acute care hospitals and long-term care hospitals.
CMS can be eradicating two measures starting with the FY 2025 fee willpower. The primary measure being eliminated is the Sufferers Discharged on A number of Antipsychotic Medicines with Applicable Justification (HBIPS-5) measure. CMS is eradicating this measure as a result of the medical pointers, which kind the premise for this measure, have been up to date, and the measure now not aligns with the present medical pointers. The second measure being eliminated is the Tobacco Use Transient Intervention Supplied or Provided and Tobacco Use Transient Intervention Supplied (TOB-2/2a) measure. Particularly, we discovered that having two measures addressing tobacco cessation interventions within the IPFQR Program (that’s, the TOB-2/2a and the Tobacco Use Remedy Supplied or Provided at Discharge and Tobacco Use Remedy at Discharge (TOB-3/3a) measures), is unnecessarily duplicative. As well as, the TOB-2/2a measure is now not endorsed by the consensus-based entity. The opposite tobacco cessation intervention measure, the TOB-3/3a measure, will stay within the IPFQR Program’s measure set.
CMS can be adopting a knowledge validation pilot program starting with knowledge submitted in CY 2025 and persevering with till a full knowledge validation program is proposed and adopted in future rulemaking.
Lastly, CMS is codifying the IPFQR Program’s necessities and insurance policies associated to statutory authority, participation and withdrawal, knowledge submission, high quality measure retention and elimination, extraordinary circumstances exceptions, and public reporting at 42 C.F.R. § 412.433, in alignment with CMS’s different high quality reporting packages.
