The Centers for Medicare & Medicaid Services (CMS) has released the fiscal year (FY) 2025 inpatient psychiatric facility (IPF) and inpatient rehabilitation facility (IRF) final rules.
In the FY 2025 IPF prospective payment system (PPS) final rule, CMS finalized a 2.8% rate update, resulting in a per diem base rate of $876.53. CMS also increased the electroconvulsive therapy treatment payment rate from $385.58 to $661.52 based on more recent data. CMS also finalized updates to the patient-level adjustment factors for the first time since FY 2005. In the proposed rule, CMS had also requested information on updates to facility-level adjustment factors for rural and teaching status. While GNYHA supported updating patient-level adjustment factors, we argued in our comments that it would be more appropriate from a technical standpoint for CMS to simultaneously update the facility-level adjustment factors, which would also benefit our members. CMS said it will update the facility-level adjustment factors in the future. CMS also finalized its proposal to add one new measure to the IPF quality reporting program (QRP) but did not finalize its proposal to require IPFs to submit patient-level quality data for certain measures on a quarterly basis (versus the current annual basis). This was based on stakeholder concerns that some IPFs would be unable to meet this requirement.
In the IPF PPS proposed rule, CMS had requested comments on the potential inclusion of the Medicare Safety Net Index (MSNI) developed by the Medicare Payment Advisory Commission. While GNYHA supports a safety net adjustment conceptually, we expressed concern about the MSNI, partly due to the associated -28% budget neutrality offset to the base rate. GNYHA urged CMS to release additional data so that stakeholders can fully evaluate the proposed index. CMS also sought comments on the collection of Standardized Patient Assessment Data Elements through an IPF patient assessment instrument. GNYHA recommended that CMS collect only a limited set of data elements that captures the resource use associated with increased staffing costs. CMS will consider comments on both issues in future rulemaking.
In the FY 2025 IRF PPS final rule, CMS finalized a 3% rate update, resulting in a standard conversion factor of $18,907. CMS also finalized the adoption of four social determinants of health measures in the FY 2028 IRF QRP, which GNYHA supported, and modified the transportation measure to require collection only at admission rather than admission and discharge. GNYHA recommended that CMS allow facilities to collect this information within any timeframe that meets staff workflow and patients’ health and social needs before they are discharged. Lastly, CMS finalized the removal of the admission class assessment item beginning in FY 2028.