Proposed FY 2016 Medicare Payment and Policy Changes For Inpatient Psychiatric Facilities

On April 24, 2015, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule outlining proposed fiscal year (FY) 2016 Medicare payment policies and rates for the Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS).

The proposed rule also updates the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program, which requires participating facilities to report on quality measures or incur a reduction in their annual payment update. This proposed rule would expand the measure sets in future fiscal years and change certain data reporting requirements for these measures.

The FY 2016 proposals are summarized below.
SUMMARY OF PAYMENT UPDATES AND PROPOSED CHANGES TO THE IPF PPS
Federal Per Diem Base Rate Update: CMS is proposing to update the estimated payments to IPFs in FY 2016 relative to estimated payments in FY 2015 by 1.6 percent (or $80 million). This amount reflects 2.7 percent IPF-specific market basket estimate less the productivity adjustment of 0.6 percentage point and less the 0.2 percentage point reduction required by law, for a net update of 1.9 percent. Estimated payments to IPFs are reduced by 0.3 percent due to updating the outlier fixed-dollar loss threshold amount.

Stand-alone IPF Market Basket and Labor Related Share for FY 2016: CMS is proposing an IPF-specific market basket to replace the Rehabilitation, Psychiatric and Long-Term Care (RPL) market basket. The proposed IPF market basket would be based on 2012 Medicare cost report data (the RPL market basket is based on 2008 data) for both freestanding and hospital-based IPFs. The proposed FY 2016 Labor Related Share (LRS) of the IPF-specific market basket is 74.9 percent, which is an increase from the FY 2015 LRS of 69.294 percent.

Wage Index: CMS is proposing to update the Core Based Statistical Areas (CBSAs) with the Office of Management and Budget (OMB) Bulletin No. 13-01 and 2010 US Census Data. To implement this update, CMS is proposing to adopt the newest OMB delineations for the FY 2016 IPF PPS wage index using a 1-year transition with a 50/50 blended wage index for all providers. The FY 2016 wage index for each provider would consist of a blend of fifty percent of the FY 2016 wage index using the current OMB delineations and fifty percent of the FY 2016 wage index using the revised OMB delineations.

As a result of the proposed adoption of the new OMB delineations for the FY 2016 IPF PPS wage index, 37 IPF providers would have their status changed from rural to urban, and therefore would lose their 17 percent rural adjustment. CMS is proposing a gradual phase-out of their rural adjustment, so that these 37 providers would receive two-thirds of the rural adjustment in FY 2016, one-third of the rural adjustment in FY 2017, and no rural adjustment for FY 2018 and subsequent years.

QUALITY MEASURE UPDATES AND OTHER IPFQR PROGRAM CHANGES
Background on the IPFQR Program. The IPFQR Program is a pay-for-reporting program established by the Affordable Care Act (ACA) and added to the Social Security Act. IPFs are subject to a reduction of two percentage points in their annual payment update for failure to meet administrative and data reporting requirements on certain quality measures. Our current IPFQR Program measure set includes 14 measures. CMS proposes to increase the IPFQR Program measure set to 16 measures by proposing the addition of five measures and the removal of three measures. The proposed rule also proposes several policies that would lessen the burden on reporting entities.

Measures Proposed for Adoption for FY 2018 Payment Determination and Subsequent Years

• One Tobacco Treatment Measure. TOB-3 – Tobacco Use Treatment Provided or Offered at Discharge and a subset measure TOB-3a Tobacco Use Treatment at Discharge (NQF #1656) measures patients 18 and older who have used tobacco products and who were referred to counseling and received or refused a prescription for cessation medication upon discharge, and the subset measure includes only those patients who received counseling and cessation medication at discharge.
• One Substance Use Measure. SUB-2 – Alcohol Use Brief Intervention Provided or Offered and a subset measure SUB-2a Alcohol Use Brief Intervention (NQF #1663) measures patients 18 and older to whom a brief substance-abuse intervention was provided, or offered and refused, and the subset measure includes only those patients who received a brief intervention.
• Two Transition Record Measures.
• Transition Record with Specified Elements Received by Discharged Patients (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care) (NQF #0647) measures the percentage of patients discharged from an inpatient facility, or their caregivers, who received a transition record with specified elements at the time of discharge.
• Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care) (NQF #0648) measures the percentage of patients discharged from an inpatient facility for whom a transition record was transmitted to the health care setting designated for follow-up care within 24 hours of discharge.
• One Screening for Metabolic Disorders Measure. Screening for Metabolic Disorders measures the percentage of discharges with an antipsychotic prescription for which a structured metabolic screening for (1) BMI; (2) blood pressure; (3) glucose or HbA1c; and (4) a lipid panel elements was completed in the past year.

Measures Proposed for Removal
Beginning with FY 2017 Payment Determination. HBIPS 4 (Patients Discharged on Multiple Antipsychotic Medications) is proposed for removal due to the loss of NQF endorsement, and because CMS believes that HBIPS-5 Patients Discharged on Multiple Antipsychotic Medications with Appropriate Justification sufficiently includes the data that HBIPS-4 was intended to collect.

Beginning with FY 2018 Payment Determination. HBIPS 6 (Post-Discharge Continuing Care Plan Created) and HBIPS 7 (Post-Discharge Continuing Care Plan Transmitted to Next Level of Care Provider Upon Discharge) because these measures would be duplicative of two measures CMS is proposing for FY 2018 and the measures proposed for removal are not as robust as the proposed new measures. 

Other Changes CMS is also proposing changes to the data reporting requirements for IPFQR Program measures. Specifically, CMS is proposing to require IPFs to report measure data as a single, yearly count rather than by quarter and age because obtaining data for each quarter and by age is burdensome to providers and the resultant number of cases is often too small to allow public reporting. In addition, CMS is proposing to require IPFs to report aggregate population counts for discharges as a single, yearly count rather than by quarter. CMS is also proposing to change sampling requirements to give providers the option of obtaining one global sample for most measures, rather than having different sampling requirements for different measures. CMS believes that uniform sampling will decrease provider burden and allow streamlined procedures.