Posted on May 04, 2017
As part of the proposed rule to update the inpatient prospective payment system for fiscal year (FY) 2018, the Centers for Medicare & Medicaid Services (CMS) proposed changes for the Medicare fee-for-service (FFS) inpatient psychiatric facility (IPF) quality reporting (QR) program. As previously adopted, IPFs that do not successfully participate in the IPFQR program are subject to a 2 percentage point reduction to the marketbasket update for the applicable year.
Highlights of the proposed rule include seeking input on whether the CMS should account for social risk factors in the IPFQR program, and if so, the factors that should be included and how the collection should be operationalized. In the rule, the CMS proposed:
- Measure removal factors
- Criteria for determining when a measure is topped out
- Measure retention factors
The CMS proposed one additional measure — medication continuation following inpatient psychiatric discharge — for payment determinations for FY 2020 and subsequent years. The measure uses Medicare FFS claims to identify whether patients admitted to IPFs with diagnoses of major depressive disorder, schizophrenia or bipolar disorder had filled at least one prescription for an evidence-based medication during the period of two days prior to discharge through 30 days post-discharge. If this measure is adopted, the number of measures for the FY 2020 payment determinations would total 19.
The agency also seeks comments on two measures for future inclusion in the IPFQR program:
- Medication reconciliation on admission
- Identification of opioid use disorder among patients admitted to IPFs.
In addition, the CMS seeks comments on new measures it is evaluating in these areas:
- Family and caregiver engagement
- Patient experience of care
- Opioid use and treatment
- Access to care
- Inpatient assaults and violence
The MHA encourages IPFs to email their concerns and comments to Vickie Kunz by June 2 for inclusion in the MHA’s comment letter. Before the CMS’s June 13 due date, the MHA will make its comments available to assist members in preparing their own comment letters. A final rule is expected by Aug. 1 for the Oct. 1 effective date.
This summer, the CMS is expected to release the annual payment updates for IPFs for FY 2018. The MHA will provide member IPFs with hospital-specific analyses after the updates are issued. Members with questions should contact Vickie Kunz at the MHA.
Posted in: Member News