2027 IPF PPS Final Rule

CMS published the FY 2027 Inpatient Psychiatric Facility Quality Reporting program Final Rule.

CMS recently published the FY 2027 Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) Final Rule which finalized changes to the Inpatient Psychiatric Facility Quality Reporting (IPFQR) program. All IPFs, which include psychiatric hospitals and psychiatric units of an acute care hospital or critical access hospital, paid under the IPF PPS must meet IPFQR reporting requirements. For the full text of the final rule, see the Federal Register.

2027 IPF PPS Final Rule

In this final rule, CMS finalized the removal of two measures beginning with the CY 2026 reporting period/FY 2028 payment determination: Alcohol Use Brief Intervention Provided or Offered (SUB-2) and subset Alcohol Use Brief Intervention (SUB-2a) measure and the Tobacco Use Treatment Provided or Offered at Discharge (TOB-3) and subset Tobacco Use Treatment at Discharge (TOB-3a) measure. CMS finalized removal of SUB-2/SUB-2adue to the costs associated with the measure outweigh the benefit of its continued use in the program and the measure can be replaced by a more broadly applicable measure. CMS will retain the Alcohol and Other Drug Use Disorder Treatment Provided or Offered at Discharge (SUB-3) and the subset Alcohol and Other Drug Use Disorder Treatment at Discharge (SUB-3a) measure in the program since it addresses both alcohol and substance use disorder treatment in the IPF setting. CMS finalized removal of TOB-3/3a due to the costs associated with the measure outweigh the benefit of its continued use in the program.

CMS finalized the implementation of a standardized IPF Patient Assessment Instrument (IPF-PAI) as mandated by the Consolidated Appropriations Act (CAA) of 2023. The assessment must be standardized to make meaningful comparisons across IPFs, so each IPF will administer the same assessment with identical questions, response options, standards and definitions. CMS finalized that IPFs issue the assessment to patients aged 18 years and older. For patients whose length of stay is less than 3 calendar days, IPFs will be required to collect limited items from the discharge assessment item set as part of the admission assessment.

CMS finalized the following assessment items for each of t he five data categories required by the statute:

CAA Category	Assessment Item
Functional status	Mobility: Chair/Bed-to-Chair Transfer (collected at admission only)
Cognitive function and mental status	Suicide Screening
Special services, treatments, and interventions	Special Services, Treatments, and Interventions in the Inpatient Psychiatric Setting (Psychiatric Treatments, Restrictive Interventions) (collected at discharge only, with an extended lookback period of the entire IPF stay, from admission through discharge)
Medical conditions and comorbidities	Primary Medical Condition Category
Impairments	Hearing; Speech Clarity; Vision
Administrative: Assessment items required for record matching and database management	Legal Name of Patient, Birth Date, Sex, and Medicare Number (if Medicare is primary payer), Facility Provider Numbers (National Provider Identifier, CMS Certification Number), Admission/Discharge Date, Payer Information—Primary Payer, Type of Record, Assessment Reference Date, Reason for Assessment, Type of Admission/Type of Discharge, IPF-PAI Completion Date

CMS has finalized 3 quarters of voluntary reporting ofthe IPF-PAI beginning with Q4 2027 (October 1 – December 31, 2027) through Q22028 (April 1 – June 30, 2028). Mandatory reporting will begin with Q3 2028 (July1 – Sept 30, 2028) and Q4 2028 (October 1 – December 31, 2028), which willimpact CY 2030 payment determination. Then, the reporting period will be thefull calendar year occurring two years prior to the applicable payment year(for example, quarterly data from January 1 through December 31, 2029 will impactFY 2031 payment determination).

CMS finalized that IPF-PAI data is submitted on aquarterly basis, with each quarter’s data due by the 15th day of the secondmonth following the end of that quarter. The submission deadlines for eachquarter are outlined below.

CMS finalized that an IPF would need to complete 100 percent of the IPF-PAI assessment items on 50 percent of the IPF-PAIs submitted for the Q3 and Q4 2028 and CY 2029 reporting periods and increase to 70 percent for CY 2030 and subsequent reporting periods to satisfy the IPFQR Program data reporting requirements for the applicable annual payment determination. An IPF that fails to submit 100 percent of the assessment items on at least the required percent of the IPF-PAIs submitted to CMS would be deemed non-compliant with the IPF Quality Reporting Program reporting requirements and, as a result, would be subject to a 2-percentage point reduction to its APU. In future rulemaking, CMS plans to incrementally increase the completion rate that an IPF would need to achieve to be considered compliant with the IPF Quality Reporting Program. The following tables excerpted from the FY 2027 IPF PPS Final Rule outline the reporting requirements.

IPFs will be able to submit IPF-PAI data either through aCMS-developed web application which CMS has named the Patient AssessmentReporting Interoperability Tool (PARIT), or via Application ProgrammingInterfaces (APIs) built on the Health Level Seven (HL7) Fast HealthcareInteroperability Resources (FHIR®) standard. This marks the first CMS statutoryquality reporting program to use the FHIR® standard for patient assessment datasubmission.

CMS has provided resources for IPF-PAI here.

If you have questions about reporting your IPFQR measures, please contact us.

Healthcare AI Data Foundation

2027 IPF PPS Final Rule

CMS published the FY 2027 Inpatient Psychiatric Facility Quality Reporting program Final Rule.