The Centers for Medicare & Medicaid Services (CMS) has approved six measures to meet the requirements of the Affordable Care Act’s (ACA) mandate for both psychiatric hospitals and psychiatric units to begin reporting inpatient quality measures. The ACA requires that, as of rate year 2014 (starting October 1, 2013), all facilities reimbursed under the inpatient psychiatric facility prospective payment system (IPF PPS) must report data on at least six measures to CMS for the purpose of public reporting, payment updates, and pilot pay-for-performance programs.

The measures CMS selected are six of the seven Hospital-Based Inpatient Psychiatric Services (HBIPS) core measures, which are already required of psychiatric hospitals by The Joint Commission (and available for use by psychiatric units to meet ORYX reporting requirements):

  • HBIPS-2 Hours of physical restraint use (patient safety);
  • HBIPS-3 Hours of seclusion use (patient safety);
  • HBIPS-4 Patients discharged on multiple antipsychotic medications (pharmacotherapy);
  • HBIPS-5 Patients discharged on multiple antipsychotic medications with appropriate justification (pharmacotherapy);
  • HBIPS-6 Post discharge continuing care plan created (care coordination); and
  • HBIPS-7 Post discharge continuing care plan transmitted to next level of care provider upon discharge (care coordination).

The CMS-approved measures respond to significant concerns voiced by NABH members and others in the behavioral health field about the importance of keeping measures focused and actionable and not layering-on additional – and potentially contradictory – measures and definitions. NABH was represented on the Technical Expert Panel convened by CMS to recommend measures for this ACA-mandated Inpatient Psychiatric Facilities Quality Reporting (IPFQR) Program. The association has been actively working for many years (through a public-private partnership) with The Joint Commission on core measure development and implementation.

NABH members have also been in the forefront of testing, refining, and successfully reporting these HBIPS measures to The Joint Commission over a significant period of time. With more than 450 hospitals using the measures – and reporting value in having the data available to help improve patient care – we believe that these measures represent the best thinking and experience of the field. The measures evolved from a consensus-driven, evidence-based process that has been supported by both the private and public sectors.

IMPORTANT RESOURCES: or (for the latest updates from CMS)

8/22/16 — CMS final rule on inpatient PPS for acute-care hospitals (including sections on IPF Quality Reporting Program, observation status, and uncompensated care).  Also see 10.5.16 correction.

8/5/15 — CMS final rule: “Medicare Program; Inpatient Psychiatric Facilities Prospective Payment System-Update for FY16” (including IPF Quality Reporting measures on pages 46694-46719)

8/6/14 — CMS final rule:  “Medicare Program: IPF Prospective Payment System-Update for FY15.” See quality reporting requirements pages 45961-45980.

8/19/13 — CMS final rule on quality reporting requirements for inpatient psychiatric facilities (see pages 50887-50901).


NABH comment letter on CMS proposed rule on quality reporting requirements for inpatient psychiatric facilities