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CMS Expects FY 2021 IPF Payments to Increase by 2.4%

The Centers for Medicare & Medicaid Services (CMS) on April 10 said it expects payments to inpatient psychiatric facilities to increase by 2.4% in fiscal year 2021, boosting the federal per diem base rate to $817.59 from $798.55.

An announcement about CMS’ proposed inpatient psychiatric facility prospective payment system (IPF-PPS) rule said the agency estimates total IPF payments to increase by $100 million next year. The rule will be published in the Federal Register on Tuesday, April 14.

According to the proposed rule, CMS will adopt the Office of Management and Budget (OMB) guidelines regarding geographic delineation of statistical areas, which CMS said should result in wage index values better representing the actual labor costs in a given area.

“CMS is proposing that all IPF providers negatively impacted in their wage index, regardless of the circumstance causing the decline, be capped at a 5-percent decrease for FY 2021,” the announcement said. Table 6 at the start of page 57 in the proposed rule shows changes in 2021 from 2020 for different facility types.

The agency said it is not making changes to the IPF Quality Reporting Program.

NABH is analyzing the proposed rule and will submit comments by the June 9 deadline.

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HHS Announces $30 Billion in Covid-19 Relief Funding for Providers

HHS announced on Friday it is distributing $30 billion immediately to healthcare providers fighting the deadly Covid-19 pandemic. The funding is the first portion of the $100 billion allotted to hospitals and other providers as part of the Coronavirus Preparedness and Response Supplemental Appropriations (CARES) Act that President Trump signed on March 27.

The funding will arrive via direct deposit to eligible providers starting on Friday, April 10. HHS’ announcement said the money is in the form of payments, not loans, so the money will not need to be repaid.

Eligible healthcare providers include all facilities and providers that received Medicare fee-for-service reimbursements in 2019. According to HHS, payments to practices that are part of larger medical groups will be sent to the group’s central billing office. Click here to learn how HHS will determine the payments and what eligible providers need to do.

To receive funding, providers must agree not to seek to collect out-of-pocket payments from a Covid-19 patient that are greater than what the patient would have otherwise been required to pay if an in-network provider had provided care, HHS said.

HHS has created a public website that shows all Covid-19 grant and cooperative agreement awards, which features a U.S. map detailing the amounts awarded by states, graphics highlighting the numbers of awards, amounts awarded by agency, and more.

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White House Proposes Changes IMD Exclusion in 2021 Budget

The White House on Monday released a $4.8 trillion budget for 2021 that would modify Medicaid’s Institutions for Mental Diseases (IMD) exclusion to provide states with flexibility to provide inpatient mental health services to beneficiaries with serious mental illness (SMI).

The budget requests $94.5 billion for HHS, a 10-percent decrease from the 2020 enacted level. Although Congress is likely to reject President Trump’s proposal, the budget is significant for outlining the president’s top policy priorities as he seeks re-election in November. Notably for NABH, those priorities address mental health and addiction treatment services.

These provisions include changes to the IMD exclusion, which under current law states Medicaid cannot pay for certain inpatient stays at IMDs. The president’s budget would provide more than $5 billion in new federal funding to states to ensure the full continuum of care exists to provide help to people with SMI. These changes—which appear in summary tables at the end of the budget proposal—would exempt Qualified Residential Treatment Programs (QRTPs) from the IMD exclusion.

The budget also includes $225 million for Certified Community Behavioral Health Clinics (CCBHC) expansion grants, and would extend, through 2021, the CCBHC Medicaid demonstration programs to improve community mental health services for the eight states participating currently in the demonstration. In addition, the White House has proposed $25 million to expand primary healthcare services to address homelessness. These provisions, together with the changes to the IMD exclusion, are “part of a comprehensive strategy that includes improvements to community-based treatment,” the budget proposal noted.

Meanwhile, the president’s 2021 budget would continue 2020 funding to expand medication assisted treatment (MAT) from a small pilot program to half of all eligible Bureau of Prisons (BOP) facilities and provide an additional $37 million to complete MAT expansion to all eligible BOP facilities.

NABH will continue to analyze the Trump administration’s budget proposal and keep NABH apprised of any additional details regarding the IMD exclusion, MAT funding, and other topics related to the association’s policy priorities.

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ONDCP Issues 2020 National Drug Control Strategy and Treatment Plan

The Office of National Drug Control Policy (ONDCP) has issued its 2020 National Drug Control Strategy (Strategy) and accompanying National Treatment Plan (NTP) that includes action items for federal agencies and external stakeholders to increase access to care and close the addiction treatment gap.

The Strategy is presented using the domains of prevention, treatment and recovery, and supply-side strategies for reducing the availability and consumption of illicit drugs. These domains are established as ‘pillars’ that undergird the federal initiatives of expanding the early intervention, treatment and recovery infrastructure; improving the delivery system; and improving quality.

Specifically, the NTP calls for treatment expansion and improved quality by:

  • Developing protocols for medically managed withdrawal including MAT to prevent relapse and promote stabilization;
  • Increasing emergency department use of addiction medicine specialty services;
  • Exploring the inclusion of stimulant disorder treatment in opioid treatment programs;
  • Increasing access to all medication and psychosocial services, promoting syringe exchange, interim methadone, mobile methadone vans, and peer outreach. One objective of the federal Performance and Reporting System is to make sure 100% of all specialty providers offer MAT by 2020;
  • Adopting model state specialty SUD treatment licensing laws;
  • Developing mobile and online platforms with updated information on treatment slot availability with online appointment capacity;
  • Encouraging public and private payers to cover comprehensive services and improve reimbursement rates where out-of-network rates are higher;
  • Urging providers to subsidize and provide treatment scholarships; and
  • Exploring the idea of developing national consensus standards for addiction treatment to consolidate treatment quality standards.

If you have questions about the Strategy or NTP, please contact Sarah Wattenberg, NABH’s
director of quality and addiction services.

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CDC Reports U.S. Drug Overdose Death Rate Down, Opioid Overdose Death Rate Up in 2018

The age-adjusted rate of U.S. drug overdose deaths in 2018 was 4.6% lower than the rate in 2017, the Centers for Disease Control and Prevention reported Thursday.

New data from the National Vital Statistics System also show there were 67,367 drug overdose deaths in the United States in 2018, 4.1% fewer than the 70,237 deaths reported in 2017.

Despite the decline in overall drug overdose deaths, there was a 10% increase in the rate of drug overdose deaths involving synthetic opioids other than methadone, such as fentanyl, in 2018 compared with 2017.

Furthermore, the age-adjusted rate of overdose deaths involving cocaine more than tripled from 2012 through 2018, while the rate of deaths involving certain psychostimulants, such as methamphetamine, increased nearly five-fold.

The CDC also reported that decreases in life expectancy between 2014 and 2017 were driven mostly by deaths due to unintentional injuries, suicide, and Alzheimer’s disease.

Improvements in life expectancy between 2017 and 2018, meanwhile, were driven by decreases in  mortality from cancer, unintentional injuries, and chronic lower respiratory diseases. The positive contributions to the change in life expectancy were offset, in part, by the rising number of deaths by suicide, chronic liver disease, and cirrhosis.

Unintentional injuries and suicide remain in the top ten leading cause of death in the United States.

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NABH Alert: CMS Announces 1.5-percent Increase for Inpatient Psychiatric Facilities for 2020 in Final Rule

The Centers for Medicare and Medicaid Services (CMS) announced a Medicare payment increase of 1.5 percent next year for inpatient psychiatric facilities in the final Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) rule the agency released today.

Compared with the 2019 payment rate, the increase reflects a total increase of $65 million for Medicare-participating inpatient psychiatric facilities in fiscal year 2020. The payment update aligns with the agency’s proposed rule earlier this year.

The rule also adds one new claims-based measured starting in fiscal year 2021 payment determination and continuing in subsequent years. The measure—Medication Continuing Following Inpatient Psychiatric Discharge (National Quality Forum #3205)—assesses whether patients admitted to IPFs with diagnoses of Major Depressive Disorder, schizophrenia, or bipolar disorder filled at least one evidence-based medication within two days before discharge or during the 30-day, post-discharge period.

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CMS Releases Emergency Medical Treatment and Labor Act (EMTALA) Memorandum

The Centers for Medicare & Medicaid Services (CMS) on July 2 released Frequently Asked Questions on the Emergency Medical Treatment and Labor Act (EMTALA) and Psychiatric Hospitals, a six-page memo addressing common concerns psychiatric hospitals and hospital emergency departments have regarding compliance with EMTALA.

EMTALA has been a top regulatory priority for NABH and our team has worked closely with CMS on this issue. In March, NABH released The High Cost of Compliance: Assessing the Regulatory Burden in Inpatient Psychiatric Facilities, a detailed report that quantifies the compliance costs related to EMTALA for inpatient psychiatric care providers. The analysis—which NABH commissioned Manatt Health to produce—also addresses ligature risk, a topic CMS addressed this past April in draft guidance.

Here are key excerpts from CMS’ July 2 FAQ Memo:

  • How do surveyors evaluate whether a staff person is qualified to perform a Medical Screening Exam?
    • The surveyor can review state scope of practice as well as hospital bylaws or rules and regulations to determine if the medical screening exams being performed are within a professional’s scope of practice.
  • What is the expectation of a psychiatric hospital when a medical emergency presents in terms of who can conduct a medical screening exam?
    • EMTALA requires hospitals to perform medical screening examinations within their capabilities. If the psych hospital doesn’t have the ability to perform a comprehensive medical screening exam (or provide stabilizing treatment), but the screening exam it performs indicates that the patient may have an emergency medical condition, the hospital is required to arrange an appropriate transfer to a facility for further evaluation and treatment. The hospital is expected to use its resources to perform the exam and provide care within its capabilities prior to transfer. This might be as simple as performing ongoing assessments with repeat vital signs and ensuring the patient is in a safe environment.
  • What is required in terms of stabilization and transfer for non-psychiatric emergencies?
    • There is no expectation that a psych hospital with basic clinical services would be expected to provide the same level of comprehensive medical assessments or treatment as an acute care hospital.
  • How does EMTALA intersect with admission?
    • If the hospital has the staff and facilities to stabilize the emergency medical condition, it is expected to do so. This includes inpatient admission, as appropriate. Having an empty inpatient bed does not always translate to having the capability or capacity to stabilize the emergency medical condition.
  • Can an ER physician in a facility that does not provide psychiatric care conduct the mental health screening?
    • It is within the scope of practice for ED physicians and practitioners to evaluate patients presenting with mental health conditions, same with any other medical, surgical, or psychiatric presentation. The ED practitioner may utilize hospital resources to assist with the examination and treatment or arrange appropriate transfers if additional resources are needed.

Read the full memo here.

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