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Comment Letter to CMS on FY 2016 Inpatient Psychiatric Facility Prospective Payment System Proposed Rule

June 23, 2015

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Attention: CMS-1627-P
P.O. Box 8010 Baltimore, MD 21244-1850

Re: CMS 1627-P, Medicare Program; Inpatient Psychiatric Facilities Prospective Payment System – Update for Fiscal Year Beginning October 1, 2015 (FY 2016)

Dear Mr. Slavitt:

On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions including free-standing and hospital unit inpatient psychiatric facilities, we appreciate the opportunity to comment about the Centers for Medicare & Medicaid Services’ (CMS) Inpatient Psychiatric Facility (IPF) prospective payment system proposed rule.

Core-Based Statistical Area (CBSA)

HAP understands the update to the Core-Based Statistical Areas; however, the rural to urban change impacts facilities in five counties in Pennsylvania.

The proposed rule suggests that the rural adjustment for these counties (Adams, Franklin, Columbia, Montour, and Monroe) be phased out gradually (Fiscal Year 2016 receive 2/3 rural adjustment, Fiscal Year 2017 receive 1/3 of the rural adjustment).

HAP is concerned that the facilities in three of the Pennsylvania counties (Columbia, Monroe, and Montour) will be significantly impacted by this change. These counties serve a higher than state average Medicare population.

HAP would encourage CMS to consider phasing the rural adjustment out during an additional year (Fiscal Year 2016 receive 3/4 rural adjustment, Fiscal Year 2017 receive 1/2 of the rural adjustment, Fiscal Year 2018 receive 1/4 of the rural adjustment). This would provide facilities another year to adjust to the payment change, while still meeting the care needs of a vulnerable population.

Quality Reporting Program

According to the proposed rule, quality measures evaluate critical processes of care that have a significant impact on patient outcomes, and improve quality and efficiency of care.

Following this logic, CMS suggests removing one measure, HBIPS-4 Patients Discharged on Multiple Antipsychotic Medications, as it did not assess the quality of care received in the IPF.

HAP also supports the removal of HBIPS-4, as the measure no longer is endorsed by the National Quality Forum (NQF). 

CMS proposes to add the following measures:

  • SUB-2 Alcohol Use Brief Intervention Provided or Offered
  • SUB-2a Alcohol Use Brief Intervention
  • TOB 3 Tobacco Use Treatment Provided or Offered at Discharge
  • TOB 3a – Tobacco Use Treatment at Discharge and Screening for Metabolic Disorders

And substitute the following measures:

  • NQF #0647 Transition Record with Specified Elements Received by Discharged Patients for HBIPS-6 Post-Discharge Continuing Care Plan
  • NQF #0648 Timely Transmission of Transition Record for HBIPS-7 Post Discharge Continuing Care Plan Transmitted to the Next Level of Care Provider Upon Discharge

HAP understands the importance of offering alcohol screening and treatment in IPF facilities, as alcohol use may be factor contributing to the mental health of the patient. Similarly, the tobacco and metabolic measures may be helpful in improving and evaluating the overall health of the individual patient.

In Pennsylvania, many IPFs also are accredited by The Joint Commission. Requiring IPFs to report on the NQF transition measures and the HBIPS-6 and HBIPS-7, required by The Joint Commission, will be duplicative and burdensome for providers.

Although HAP appreciates CMS’s stated intent in the substitution of the HBIPS-6 and HBIPS-7 measures—to provide additional, timely information upon discharge and improve patient outcomes—the HBIPS measures have promoted significant improvements in the IPFs and should be retained.

HAP also is concerned about the decision to propose new quality measures or change current measures in these areas for the following reasons:

  • The proposed measures provide limited to no insight about the quality of psychiatric care received in the IPF setting.
  • The continual revision of the quality measures does not provide reliable data on which to base decisions about patient care and evaluate care improvement over time.
  • The increased data collection for the new quality measures is burdensome for providers with no impact on the quality of psychiatric services provided to patients.
  • Additional screenings and tests may be provided to patients prior to discharge with no real impact on stabilizing the patient’s psychiatric health and treating their conditions.

HAP suggests CMS revisit the addition of these measures as called for in the proposed rule. HAP also strongly supports efforts to develop measures that are directly related to care in an IPF.

CMS is developing a 30-day psychiatric readmission measure similar to the readmission measures in other quality reporting programs. We urge CMS to ensure that any readmissions measures it proposes are adjusted for economic and sociodemographic factors.

Studies have shown that there are greater costs in preventing readmissions given socioeconomic and demographic challenges of patients. This adjustment would provide additional resources to hospitals serving vulnerable populations.

Thank you for your consideration of our comments about the IPF prospective payment system proposed rule. If you have any questions, please feel free to contact me at (717) 561-5344, or Jamie Buchenauer, vice president, regulatory advocacy, at (717) 561-5308.


Paula A. Bussard
Chief Strategy Officer

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