CMS Proposes IPF PPS Reforms and FY 2025 Increase of 2.6%
The Centers for Medicare & Medicaid Services (CMS) on Thursday proposed a net update of 2.6 percentage points for fiscal year (FY) 2025 payment levels relative to FY 2024 levels for hospitals and units reimbursed under the inpatient psychiatric facility prospective payment system (IPF PPS).
The update moderately varies by provider types, with a 2.2% increase for urban, freestanding for-profit providers, and a 2.4% increase for urban, freestanding not-for-profit hospitals, as well as for urban, for-profit and not-for-profit units.
The IPF PPS rule also proposed budget-neutral adjustments to the Medicare severity diagnosis related groupd (DRG), which are payment categories that reflect a patient’s principal diagnosis, selected comorbidities, patient age, and the variable per diem adjustments. The proposed changes also include:
- Maintaining the current 17 DRGs.
- In response to the growing volume of these cases, CMS proposes to make these two current DRGs eligible for payment add-ons: DRGs 917 (Poisoning and toxic effects of drugs w MCC) and 918 (Poisoning and toxic effects of drugs w/out MCC). See Table 4 in the rule for more details.
- Replacing DRGs 080 (Nontraumatic stupor & coma w MCC) and 081 (Nontraumatic stupor & coma w/o MCC) with DRGs 947 (Signs and Symptoms w MCC) and 948 (Signs and Symptoms w/out MCC), because volume in these current DRGs have decreased significantly and CMS said the proposed replacement DRGs are a more appropriate fit. See Table 3 in the rule for more details.
Regarding comorbidity payment add-ons, in an overall budget-neutral manner, CMS proposes multiple changes to these payment adjustment rates, as outlined in Table 8 in the
rule.
To maintain this payment system’s 2.0% outlier pool, CMS proposed to increase the fixed dollar loss threshold to $35,590 from $33,470, which will result in fewer cases qualifying for outlier payments.
The rule also proposes to increase payments for electroconvulsive therapy to $660.30 in FY 2025 from the current rate of $385.58.
Due to these adjustments, the base per diem was reduced to $874.93 from $895.63 (a 2.3% reduction) to ensure that overall payments remained budget neutral. And our analysis will further explain this reduction and its overall financial impact to the industry.
In addition, under the congressional mandate from the
Consolidated Appropriations Act, 2023, the rule includes two requests for information (RFI) on potential future IPF PPS reforms. For the first RFI, CMS revisits and builds upon its 2022 technical report by flagging several potential future reforms to the current adjustments for rural IPFs, teaching IPFs, and “safety-net” IPFs.
The second RFI in the rule proposes to develop a standardized IPF patient assessment instrument, which will be designed to implement in 2028.
Please see the agency’s fact
sheet for additional information about the proposed rule. Public comments are due by
Tuesday, May 28.
Also, please join NABH via
Zoom on Tuesday,
April 16 from 2 p.m. – 3 p.m. ET, when we’ll discuss the rule in greater detail, as well as priority issues that NABH will address in the association’s official comment letter.
View the NABH 2024 Annual Meeting Preliminary Program!
Earlier this week NABH shared its 2024 Annual Meeting
preliminary program with members and meeting registrants. Unless noted otherwise, meeting sessions are open to all Annual Meeting attendees.
Please remember to
register for the Annual Meeting and
reserve your hotel room today if you haven’t done so yet.
We look forward to seeing you in Washington!
Deadline to Advertise in the 2024 NABH Exhibitor and Sponsor Guide is Today, March 29!
NABH will distribute the
2024 NABH Exhibitor and Sponsor Guide to all registrants at the 2024 NABH Annual Meeting from May 13-15 at the Salamander Washington, DC. Be sure your organization is included in it!
All ads are due today, Friday, March 29, 2024. Please click
here for details about advertising options, requirements, payment, and more.
The association also will send the guide to all NABH members after the meeting and post it on the NABH Annual Meeting webpage.
Register for Part II of Our Foundation’s Talent-Recruitment Webinar Series!
Please join us on
Thursday, April 18 at 2 p.m. ET for Part II of the NABH Education and Research Foundation’s talent-recruitment webinar series, which will explore long-term solutions.
NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P. president and CEO, Rutgers University Behavioral Health Care and senior vice president, Behavioral Health and Addictions Service Line, RWJBarnabas Health, will lead the April webinar along with Kuhn and workforce consultant
John Pallasch of One Workforce Solutions. Pallasch served previously as the assistant secretary for employment and training at the U.S. Labor Department.
This interactive webinar will explore how to develop partnerships for apprenticeships and other “grow your own” programs.
Please click
here to register.
ICYMI: Watch Part I of Our Foundation’s Talent-Recruitment Webinar Series!
On March 26, our foundation hosted Part I of its two-part, talent-recruitment webinar series, which focused on short-term solutions.
If you missed it, please click
here for the webinar’s recording,
here for the presentation slides, and
here for the poll question results.
U.S. Labor Department Seeks Information in Parity Enforcement Survey
The U.S. Labor Department is conducting an 11-question survey to better understand stakeholder views about the department’s federal parity law oversight and enforcement efforts.
In particular, the survey focuses on compliance enforcement for non-quantitative treatment limitations, which include prior authorization protocols, network adequacy standards, and timeliness requirements.
Click
here to complete the survey, which opened on Wednesday, March 27 and closes on
Wednesday, April 10.
Reminder: Please Submit Data to NABH’ Denial-of-Care Portal
NABH thanks all members who have submitted data to the association’s
Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials.
With guidance from our members, NABH has improved the portal by adding two elements:
- Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
- The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs
Emily Wilkins.
Fact of the Week
Perinatal mood and anxiety disorder (PMAD) diagnoses among privately insured people nationwide increased by 93.3% from 2008 to 2020, growing faster in 2015–20 than in 2008–14, according to a new study published in
Health Affairs.
For questions or comments about this CEO Update, please contact Jessica Zigmond.