CMS Issues Proposed Rulemaking for the FY 2020 Inpatient Psychiatric Facilities Prospective Payment System

King & Spalding

The display copy of the proposed rulemaking for the FY 2020 Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) was posted on the Federal Register website last week (the Proposed Rule).  The IPF PPS pays psychiatric hospitals, psychiatric units in acute care hospitals and critical access hospitals on a per diem basis for inpatient psychiatric services.  The Proposed Rule, which is scheduled to be published in the Federal Register on April 23, 2019, proposes to update the IPF PPS payment rates for FY 2020 based on the most recently available data, and to update the quality reporting program for psychiatric facilities.  The deadline to submit comments to the proposed rule is June 17, 2019.

The Proposed Rule proposes to rebase and revise the IPF market basket with data from FY 2016, which will replace the existing market basket that was last updated using FY 2012 data.  After applying a 1.25 percent reduction required by statute, CMS estimates that the updated market basket will increase payment rates by 1.85 percent.  Estimated payments are further reduced by 0.15 percent to update the threshold amount used in calculating outlier payments.  In all, total IPF payments are expected to increase by 1.7 percent in FY 2020 ($75 million). 

CMS is also proposing to adopt a new claims-based measure for the IPF quality reporting program.  The measure, known as the Medication Continuation Following Inpatient Psychiatric Discharge (National Quality Forum #3205), assesses whether patients admitted to IPFs with diagnoses of Major Depressive Disorder (MDD), schizophrenia, or bipolar disorder filled at least one evidence-based medication within two days prior to discharge or during the 30-day discharge period.  CMS is seeking to implement this measure staring with FY 2021 payment determinations. 

The display copy of the Proposed Rule is available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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