CMS Proposes 3% Increase in Payment Rates to Inpatient Psychiatric Facilities for 2024
The Centers for Medicare & Medicaid Services (CMS) is proposing to update Inpatient Psychiatric Facility Prospective Payment System (IPF PPS) payment rates by 1.9% in fiscal year (FY) 2024, or $55 million, relative to current rates.
This update includes a 3.2% market basket increase, a 0.2 percentage point productivity cut, and a 1.0% decrease to outlier payments.
Other notable components of the agency’s proposed IPF PPS rule this week include:
Proposed Modification to the Regulation on Excluded Units Paid Under the IPF PPS:
Responding to increased mental health needs—including the need for available inpatient psychiatric beds—CMS is proposing greater flexibility for hospitals to open and bill Medicare for a new IPF distinct part unit.
Specifically, beginning in FY 2024, CMS would allow hospitals to open a new unit at any time during the cost reporting period, with 30-day advance notice to the CMS regional office and Medicare administrative contractor.
An announcement about the proposed rule said “CMS believes this proposal would alleviate unnecessary burden and administrative complexity placed upon hospitals when opening new psychiatric units, helping to expand access to behavioral healthcare” in line with the agency’s behavioral healthcare strategy.
Proposed Updates to the IPFQR Program
The rule also proposes to adopt three quality measures focused on health equity for the IPFQR Program. First, beginning in FY 2026, a Facility Commitment to Health Equity measure would ask IPFs to attest to its efforts to address health equity across five domains: (1) Equity is a Strategic Priority; (2) Data Collection; (3) Data Analysis; (4) Quality Improvement; and (5) Leadership Engagement.
Second, a Screening for Social Drivers of Health (SDOH) measure would assess the percentage of patients over 17 who are screened for five specific health-related social needs (HRSNs) — food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety. Voluntary reporting would begin in the calendar year 2025, with payments affected beginning in FY 2027.
Finally, CMS would adopt a Screen Positive Rate for SDOH measure beginning with voluntary reporting in CY 2024 and payment impact in FY 2027. This process measure assesses the percentage of patients who screen positive for each of the noted HRSNs in this quality measure.
Request for Information (RFI) to Inform the Revisions to the IPF PPS Required by the Consolidated Appropriations Act, 2023 (CAA, 2023):
Meanwhile, CMS noted in the rule that it has continued to analyze more recent IPF cost and claim information in an ongoing effort to refine the IPF PPS. In its FY 2023 IPF PPS proposed rule, CMS issued a technical report and sought comments on the results of the latest refinement analysis in preparation to propose IPF PPS patient-level and non-regression-derived refinements to be effective in FY 2024. Subsequently, new provisions in the CAA, 2023 require CMS to revise payments under the IPF PPS for Rate Year 2025 (or FY 2025 under the IPF PPS) as the U.S. Health and Human Services secretary determines appropriate.
Consequently, CMS has included a request for information (RFI) that will be used to inform future payment revisions.
Also in the proposed rule, CMS has addressed the specific types of data and information that the CAA, 2023 suggests CMS may collect, as well as soliciting comments on additional data and information that could be collected to inform future payment revisions.
CMS will accept public comments on the proposed rule through Monday, June 5.
Final Medicare Advantage Rule for 2024 Addresses Many NABH Priorities
Earlier this week, the Centers for Medicare & Medicaid Services (CMS) issued its contract year 2024 final rule related to the Medicare Advantage (MA) program, which addresses multiple, long-standing concerns of the NABH. In particular, we are pleased with the rule’s extensive improvements related to prior authorization, network adequacy, and quality of care, including measures that:
- Require MA plans to comply with the general coverage and benefit conditions of the Traditional Medicare program, along with national and local coverage determinations (LCD), and related regulations;
- Apply prior authorization approvals to a patient’s full course of treatment for medically reasonable and necessary care, as determined by the treating physician;
- Codify appointment wait time standards for behavioral healthcare and other services;
- Add a 10 percentage point credit to insurers’ network adequacy assessment for the inclusion of clinical psychologists and licensed clinical social workers;
- Exempt emergency behavioral health services from the prior authorization process;
- Require MA organizations to:
- include behavioral health services in their care coordination programs;
- base medical necessity determinations on the individual circumstances of a specific patient, rather than on a proprietary algorithm or software;
- create a utilization management committee that annually reviews coverage policies to ensure that coverage is “no more restrictive than traditional Medicare coverage criteria;’ and
- include in their advertisements a specific Medicare Advantage plan name and ban the use words or imagery that is “misleading, confusing, or misrepresents the plan.”
- Clarify that insurers may deny care using proprietary criteria, only if traditional Medicare coverage rules are not fully established and the in-house coverage standards are based on “current evidence in widely used treatment guidelines or clinical literature made publicly available to CMS, enrollees, and providers.”
Of concern, is CMS’ exclusion of providers of medication for opioid use disorder from its network adequacy criteria. This proposal was not finalized because the elimination of the x-waiver requirement for buprenorphine providers removed the data source necessary for CMS to track those providers.
The rule also explained that there are too few opioid treatment programs (OTPs) to establish access standards, and reminded MA organizations that they are required to include OTPs as part of their Part B coverage for OTP services or arrange out-of-network care at in-network cost sharing.
New Resource: ‘Using Contingency Management To Combat Stimulant Use Disorder’ Fact Sheet
NABH has produced Using Contingency Management To Combat Stimulant Use Disorder, a brief fact sheet that explains contingency management (CM) and highlights the association’s legislative request for Congress to direct federal agencies to replace the current $75 CM incentive payment limitation with scientifically proven incentive levels.
“Decades of research and peer-reviewed literature validate the effective use of CM, which uses positive reinforcement to encourage abstinence from stimulant use,” NABH’s fact sheet explains. “Positive behavior reinforcement takes the form of predictable and meaningful financial incentives, such as gift cards (with restricted purchase guidelines) or prizes, which can be earned only when specific ‘target behaviors’ are achieved, such as drug-free urine samples.”
The new resource is available on NABH’s homepage under “Latest Content” and also posted on NABH’s “Be an Advocate” page.
Reminder: Please Submit NABH’s Behavioral Health Information Technology Survey by April 12
NABH is seeking feedback from all system members about their experiences with behavioral health information technology as the association urges Congress and the Biden administration to extend incentives to behavioral healthcare organizations for adopting electronic health records.
Please submit this brief survey by Wednesday, April 12. Your responses will help NABH in its advocacy efforts to urge Congress and the Biden administration to extend these incentives to behavioral healthcare organizations.
Please e-mail Rochelle Archuleta if you have questions.
2023 Exhibitor and Sponsor Guide Advertising Deadline is Approaching!
NABH will distribute the 2023 NABH Exhibitor and Sponsor Guide to all registrants at the 2023 NABH Annual Meeting from June 12-14, 2023 at the Salamander Washington, DC. Be sure your organization is included in it!
All ads for the guide are due by April 21, 2023. 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.
2023 ExNABH Annual Meeting Hotel Cut-Off Date is May 11!hibitor and Sponsor Guide Advertising Deadline is Approaching!
Please reserve your hotel room today at the Salamander Washington, DC (formerly the Mandarin Oriental hotel) for the 2023 NABH Annual Meeting from June 12-14, 2023!
The hotel’s cut-off date is Thursday, May 11, 2023. And please visit our Annual Meeting webpage to register for the meeting, if you have not done so yet.
We look forward to seeing you in Washington!
Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts
Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness.
Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.
Fact of the Week
A recent Health Affairs study found that the proportion of adult primary care visits that addressed mental health concerns increased to 15.9% by 2016 and 2018 from 10.7% of visits in 2006–07.
For questions or comments about this CEO Update, please contact Jessica Zigmond
