2022 FINAL RULES INPATIENT PSYCH

 

An Analysis and Commentary on Federal Health Care Issues by Larry Goldberg

CMS Releases Final FY 2022 Inpatient Psychiatric Facility PPS Update  

 The Centers for Medicare and Medicaid Services (CMS) have issued a final rule to update the Medicare Inpatient Psychiatric Facility (IPF) Prospective Payment System (PPS) for Fiscal Year (FY) 2022.

This rule updates the prospective payment rates, the outlier threshold, and the wage index for Medicare inpatient hospital services provided by Inpatient Psychiatric Facilities (IPFs) for discharges occurring during the FY 2022 beginning October 1, 2021 through September 30, 2022. 
This rule also updates and clarifies the IPF teaching policy with respect to IPF hospital closures and displaced residents and proposes a technical change to the 2016-based IPF market basket price proxies. 

In addition, the rule updates quality measures and reporting requirements under the Inpatient Psychiatric Facilities Quality Reporting (IPFQR) Program. 

A copy of the 201-page document is currently available at: https://public inspection.federalregister.gov/2021-16336.pdf. The rule is scheduled to be published on August 4, 2021, upon which this link will be superseded. 

Addendum A summarizes the FY 2022 IPF PPS payment rates, outlier threshold, cost of living adjustment factors (COLA) for Alaska and Hawaii, national and upper limit cost-to-charge ratios, and adjustment factors. Addendum B shows the complete listing of ICD-10 Clinical Modification (CM) and Procedure Coding System (PCS) codes, the FY 2022 IPF PPS comorbidity adjustment, and electroconvulsive therapy (ECT) procedure codes. 

 Addenda A and B are available online at: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientPsychFacilPPS/tools.html. 
 

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CMS Issues Correction Rule to FY 2022 Inpatient Psychiatric PPS Update

The Centers for Medicare and Medicaid Services (CMS) have issued a correction rule to the August 4, 2021 final FY 2022 Inpatient Psychiatric Facilities Prospective Payment System (PPS) Update rule. The 16-page document is available at: https://public-inspection.federalregister.gov/2021-21546.pdf. Publication in the Federal Register is scheduled for October 4.
 
There are 2 major items being corrected. First, the outlier fixed dollar loss threshold amount is changed from “$14,470” to “$16,040”. Second, based on the corrected calculation of the outlier fixed dollar loss threshold amount, the correct estimate of increased transfers from the federal government to IPF providers should be $70 million. In other words, the outlier threshold increase will result in $10 million less in FY 2022 payments than previously quoted.

Additionally, CMS is making several changes to footnotes in the August rule regarding quality program items. Also, CMS is revising the rule’s table 7 to read as follows:
 
TABLE 7: Patient-level data submission requirements for CY 2014 IPFQR Program
measure set
 

NQF#	Measure ID	Measure	Patient-Level Data Submission
0640	HBIPS-2	Hours of Physical Restraint Use	Yes, numerator only
0641	HBIPS-3	Hours of Seclusion Use	Yes, numerator only
0560	HBIPS-5	Patients Discharged on Multiple Antipsychotic Medications with Appropriate Justification	Yes
0576	FUH	Follow-Up After Hospitalization for Mental Illness	No (claims-based)
N/A	SUB-2 and SUB-2A	Alcohol Use Brief Intervention Provided or Offered and  SUB-2a Alcohol Use Brief Intervention	Yes
N/A	SUB-3 and SUB-3a	Alcohol and Other Drug Use Disorder Treatment Provided or Offered at Discharge and SUB-3a Alcohol and Other Drug Use Disorder Treatment at Discharge	Yes
N/A	TOB-2 and TOB-2a	Tobacco Use Treatment Provided or Offered and TOB-2a Tobacco Use Treatment	Yes
N/A	TOB-3 and TOB-3a	Tobacco Use Treatment Provided or Offered at Discharge and TOB-3a Tobacco Use Treatment at Discharge	Yes
1659	IMM-2	Influenza Immunization	Yes
N/A	N/A	Transition Record with Specified Elements Received by Discharged Patients (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care)	Yes
N/A	N/A	Screening for Metabolic Disorders	Yes
2860	N/A	Thirty-Day All-Cause Unplanned Readmission Following Psychiatric Hospitalization in an Inpatient Psychiatric Facility	No (claims-based)
3205	Med Cont	Medication Continuation Following Inpatient Psychiatric Discharge	No (claims-based)
TBD	COVID HCP	COVID-19 Healthcare Personnel (HCP) Vaccination Measure	No (calculated for HCP)

 

Please note the table head says, “2014.” The August 4 rule identifies table 7 as the CY 2024 IPFQR Program measure set. No doubt this is another error.

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