CEO Update | 66
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 Systems (IPF PPS) rule the agency released earlier this week.
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.
CMS Proposes Slight Payment Increase for PHPs and CMHCs in 2020
The CMS has proposed a hospital-based partial hospitalization program (PHP) payment rate of $228.20 for 2020, up from the 2019 rate of $220.86, in the Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS/ASC) proposed rule the agency released on July 29.
CMS also proposed an increase for community mental health centers (CMHCs), which could see a payment rate of $124.59 in 2020 if the rule is made final. By comparison, CMHCs received a payment rate of $120.58 in 2019.
The rates set in the proposed CY 2020 rule are not based on the most recent average cost data from the PHP program, a deviation from CMS’ long-standing policy. When CMS calculated the average PHP program cost for the CY 2020 proposed rule, the agency found it had decreased by nearly 15 percent for CMHCs and 11 percent for hospitals-based PHPs.
After finding this decrease, CMS reviewed the data sets and found that a single provider in the CMHC set and a single provider in the hospital-based set had such dramatically lower reported costs that it significantly skewed the average cost for both data sets.
Because the lower average costs were the result of single providers and could significantly reduce access for beneficiaries, CMS decide to use the CY 2019 cost average as a floor for both type of PHP rates in the CY 2020 rule. If not for this change, the rate for both types of PHPs would have been significantly lower than what CMS proposed in the rule.
It is important to note that CMS stressed that it does not intent to carry this policy forward: “To be clear, this policy would only apply for the CY 2020 rate setting,” the agency said in the rule.
CY 2020 Rates
Level 1 Health and Behavior Services $28.59
Level 2 Health and Behavior Services $81.06
Level 3 Health and Behavior Services $130.27
Partial Hospitalization (3 or more services) for CMHCs $124.59
Partial Hospitalization (3 or more services) for Hospital-based PHPs $228.20
NABH will submit comments on the proposed rule to CMS by the Sept. 27 deadline.
CMS Addresses OUD Treatment in OTPs and Office Settings in Proposed Rule
Also this week, CMS issued a proposed rule for establishing a Medicare Part B benefit and payment bundles for opioid use disorder (OUD) treatment services in opioid treatment program (OTP) settings and new HCPCS codes and bundled rates for office-based treatment of OUD.
The proposal implements Section 2005 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act.
The rule proposes:
- A definition of OUD treatment services and OTPs, including an explanation that services include access to all FDA-approved medications, counseling and therapy, and toxicology testing;
- Enrollment policies that align with SAMHSA OTP regulation and that do not have additional conditions of participation;
- Bundled payment methodologies that separate drug from non-drug treatment components, account for different medications and variable intensity of services, provide for service add-ons and partial- and full-billing for weekly episodes;
- Use of audio-video communication technology; and
- Zero beneficiary cost-sharing requirement for a time-limited period.
- Coverage of OUD management, care coordination, psychotherapy, and counseling; medication to be billed and reimbursed under existing Medicare Part B or D; toxicology testing to be billed under Clinical Lab Fee Schedule;
- Bundled payment methodologies that are based on monthly billing cycles to better align with office-based practices; one bundle for the initial month of treatment that is more service-intensive; and a second bundle for subsequent “maintenance months,” service add-on codes, and not restricted to addiction specialists;
- Three new HCPCS codes to Category I of the list of Medicare telehealth services for office-based substance use disorder (SUD)/OUD services, permitting a patient’s home as a telehealth originating site; and
- No changes to cost-sharing.