On April 7, 2021, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would update Medicare payment policies and rates for the Inpatient Psychiatric Facility Prospective Payment System (IPF PPS) for Fiscal Year (FY) 2022 and propose changes to the IPF Quality Reporting (IPFQR) Program. CMS is publishing this proposed rule consistent with the legal requirements to update Medicare payment policies for IPFs on an annual basis. This fact sheet discusses the major provisions of the proposed rule.

Proposed changes to payments under the IPF PPS

Updates to the IPF Teaching Policy

In FY 2022 and for subsequent years, CMS is proposing to adopt conforming changes to the IPF PPS teaching policy with respect to displaced residents from IPF hospital closures and closures of IPF teaching programs, thus aligning IPF teaching policy with changes that the Inpatient Prospective Payment System (IPPS) finalized in the FY 2021 IPPS/LTCH PPS final rule. 

Updates to IPF Payment Rates

Total estimated payments to IPFs are estimated to increase by 2.3% or $90 million in FY 2022 relative to IPF payments in FY 2021.  For FY 2022, CMS is proposing to update the IPF PPS payment rates by 2.1% based on the proposed IPF market basket update of 2.3%, less a 0.2 percentage point productivity adjustment. CMS is proposing that if more recent data becomes available (for example, a more recent estimate of the market basket or multi-factor productivity adjustment), we would use these data, if appropriate, to determine the FY 2022 market basket update and multi-factor productivity adjustment in the final rule.  Accounting for an additional update to the outlier threshold so that estimated outlier payments remain at 2.0% of total payments, results in a 0.2% overall increase to aggregate payments due to updating the outlier threshold results.

Background on the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program

The IPFQR Program requires IPFs to submit quality data to CMS in accordance with the IPFQR Program’s requirements or receive a payment reduction of 2.0 percentage points to their annual update.  CMS makes the IPFQR Program data submitted by IPFs publicly available.  This public reporting helps consumers make more informed decisions about their healthcare options.

Proposed Changes to the IPFQR Program

Consistent with Executive Order 13985 on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, CMS is soliciting comments on addressing health equity in the IPFQR Program. CMS is committed to addressing the significant and persistent inequities in health outcomes in the United States through improving data collection to better measure and analyze disparities across programs and policies. CMS is working to make healthcare quality more transparent to consumers and providers, enabling them to make better choices as well as promoting provider accountability around health equity. We are seeking feedback in this RFI on ways to attain health equity for all patients through policy solutions. Specifically, CMS is requesting comment on future potential stratification of quality measure results by dual eligibility and other social risk factors in facility-specific reports, ways to improve demographic data collection, and the potential creation of a facility equity score to synthesize results across multiple measures and social risk factors.

For the FY 2023 payment determination and subsequent years, CMS is proposing to add the COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP) measure to the IPFQR Program. The measure addresses the quality priority of “Promote Effective Prevention & Treatment of Chronic Disease” through the Meaningful Measures domain of Preventive Care. The process measure was developed by the Centers for Disease Control and Prevention (CDC) to track COVID-19 vaccination coverage among HCP in the IPF setting.  This measure would be reported using the COVID-19 Modules on the CDC’s National Healthcare Safety Network web portal.

For the FY 2024 payment determination and subsequent years, CMS is proposing to add the Follow-up After Psychiatric Hospitalization (FAPH) measure to the IPFQR Program. This claims-based measure expands the cohort of the Follow-up After Hospitalization for Mental Illness (FUH) measure, which is currently in the IPFQR Program, to include patients with substance use disorders. It also expands the provider types who can provide follow-up care to include primary care providers. CMS is proposing to remove the FUH measure from the IPFQR Program if the FAPH measure is adopted because the FAPH measure is more broadly applicable to a larger patient population.

In efforts to reduce provider burden, CMS is also proposing to remove three chart-abstracted measures from the IPFQR Program for the FY 2024 payment determination and subsequent years because the costs associated with these measures outweigh the benefits of continuing to retain them in the IPFQR program.  These measures are Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention, Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment, and Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or any Other Site of Care). The removal of these measures would reduce information collection burden by nearly 750,000 hours or approximately $30.6 million per year across all IPFs. We are not proposing to remove the Alcohol and Other Drug Use Disorder Treatment Provided or Offered at Discharge and Alcohol and Other Drug Use Disorder Treatment at Discharge measures, or the Tobacco Use Treatment Provided or Offered at Discharge and Tobacco Use Treatment at Discharge measures.

Additionally, CMS is proposing to transition to patient-level reporting for chart-abstracted measures beginning with voluntary reporting of data for the FY 2023 payment determination and transitioning to required patient-level reporting for the FY 2024 payment determination and subsequent years. Reporting aggregate measure data increases the possibility of human error, such as making typographical errors while entering data, which cannot be detected by CMS or by data submission systems. We believe that patient-level data will improve the data accuracy without increasing provider burden.

For more information:

The FY2022 IPF PPS and IPFQR proposed rule can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection/current

CMS encourages comments on this proposed rule and will accept comments until June 7, 2021

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