Behavioral Health

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

OVERVIEW: 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).

Under contract with the federal government, the Substance Abuse and Mental Health Services Administration (SAMHSA) recently released revised the Federal Guidelines for Opioid Treatment Programs (OTPs). The agency indicates that the guidelines “should be the primary reference and central measure for program staff, accreditation bodies and other stakeholders on the delivery of care in OTPs that is both high quality and in compliance with federal regulations,” noting that state-specific regulations also may apply.

Medicare Improper Payment Report for Behavioral Health Services

The following information is from the 2014 Medicare Improper Payments Report by the Department of Health and Human Services.

This table shows the Improper Payment Rates by Provider Type and Type of Error for Medicare Part B claims:

    Provider Type

    Improper Payment Rate

Services at Other than Regularly Scheduled Office Hours

Problem

Leaving money on the table for services that are performed after hours and at other special times.

From a CPT coding perspective there are special adjunctive codes that are used in addition to the basic service(s). This code series ranges from 99000 to 99099.

Within this series are important codes that deal with special service situations. These codes include services at "other than regularly scheduled" office times.

PQRS Information

It is essential for healthcare providers to understand how the Physician Quality Reporting System (PQRS) affects their practice. All Eligible Professionals (EPs) who did not satisfactorily reported data on quality measures for covered professional services in 2014 your CMS payment will incur a 2% PQRS penalty (payment cut) om 2016. This PQRS non-participation payment penalty of 2% continues (based on PQRS participation two years ago) for as long as you do not participate in the PQRS program.

Adaptive Behavior Coding

On July 1, 2014, 16 new codes (0359T through 0374T) were added for reporting adaptive behavior assessments/interventions services. These codes were included with the mid-year release of CPT Category III codes.

These new codes have been added to Section H-Procedure Coding in the Behavioral Health MultiBook. and may be used by any physician or other qualified licensed healthcare professional.

The June 2014 edition of CPT Assistant stated the following about these codes (emphasis added):

Human Resources (Resource 125)

Finding the right supportive and productive staff is essential to every healthcare office. Knowing how to find the right people and keep them must be balanced with state and federal regulations regarding employees. You need to be concerned about:

EHR Hardship Exemption

The following information is from the Centers for Medicare & Medicaid Services (CMS) regarding the Electronic Health Records (EHR) payment reduction hardship exemption:

    Hardship Exceptions for Medicare EPs

The National Council for Behavioral Health is sponsoring a webinar entitled "How Can We Better Detect and Predict Suicide Risk?" on Tuesday, February 24, 2015 (2:00 PM - 3:00 PM EST)

The presenters are Jane Pearson, Ph.D., Chair, National Institute of Mental Health’s (NIMH) Suicide Research Consortium and Lisa Colpe, Ph.D., Chief, Office of Clinical and Population Epidemiology Research at NIMH

Supplies Resources (Resource 347)

Providing medical supplies to your patients can benefit both the patient and your practice. However, there are specific protocols that need to be followed in order to properly bill supplies. Not only do the proper codes need to be selected, but the appropriate use of modifiers is essential. Also, some payers have their own specific requirements that must be followed. For information on codes and modifiers, refer to Section I-Supply Codes of the Behavioral Health MultiBook.

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