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CHA Comments on FFY 2020 Inpatient Psychiatric Facility PPS Proposed Rule

For CEOs, CFOs, Government Relations Staff, Quality & Patient Safety Staff

CHA has submitted comments on the Centers for Medicare & Medicaid Services (CMS) federal fiscal year (FFY) 2020 inpatient psychiatric facility prospective payment system proposed rule, raising significant concerns about CMS’ proposed use of the FFY 2020 wage index file.

While CHA does not oppose the proposal to eliminate the current one-year lag in wage index data by using the concurrent fiscal year’s pre-rural floor, pre-reclassified inpatient prospective payment system wage index for the inpatient psychiatric facility prospective payment system (IPF PPS) wage index, CHA does oppose the proposal to use the current FFY 2020 wage index data file that was released as a public use file on April 30. CHA also comments on CMS’ proposal to add one quality measure — Medication Continuation following Discharge from an IPF (NQD #3205) — to the IPF quality reporting program beginning with FFY 2021.

In addition to the comment letter, CHA has issued hospital-specific analyses of the FFY 2020 Medicare IPF PPS proposed rule. The analysis is intended to show providers how Medicare fee-for-service payments would change from FFY 2019 to FFY 2020 based on the proposed rule’s policies. A summary of the proposed rule can be found here.

The analysis incorporates changes to IPF payments implemented by CMS, including a market basket update, Affordable Care Act-mandated market basket reductions, a wage index budget-neutrality adjustment, and updated wage index values.

The impacts provided do not include the 2% sequestration reduction to all lines of Medicare payment authorized by Congress through FFY 2027.

More information is available in the analysis description.