Partial hospitalization has long been a level of care offered by NAPHS members. In a recent NAPHS Annual Survey, more than half (56.8%) of all NAPHS members responding offered psychiatric partial hospitalization services for their communities, and more than a third (35%) offered partial hospital addiction services. Throughout the years, these NAPHS members have been a stable group of providers working hard to meet a community need. Patients may use partial hospitalization either as a transition from a hospital program or as an alternative to inpatient care.
NAPHS has been a major proponent and supporter of the Medicare partial hospitalization benefit since the inception of the benefit in the late 1980s. NAPHS worked with Congress in crafting the legislation, which became the basis for this benefit. The original intent of the benefit was to provide Medicare beneficiaries with an alternative to inpatient psychiatric care that would allow patients to move more quickly out of the hospital to a less intensive, “step-down” program or that would prevent the need for hospitalization. Before the advent of this benefit, Medicare’s mental health benefit structure was limited to inpatient psychiatric hospital care or outpatient, office-based visits. The partial hospitalization benefit created an important intermediate service between outpatient, office-based visits and inpatient psychiatric care.
The benefit continues to have a very important place as psychiatric reimbursement has moved to prospective payment and the importance of placing patients at the appropriate level of care has been re-emphasized. Without partial hospitalization as an option, one could imagine even more patients in overcrowded emergency departments. There is much evidence that emergency department care is an inefficient and very expensive way to care for patients experiencing a mental health crisis.
The current implementation of healthcare reform places ever-more emphasis on the importance of the care continuum. Essential to reform implementation is the creation of a system that makes it possible for patients to receive treatment at the most appropriate, cost-effective level with well-coordinated transition to the next level of care. We believe partial hospitalization is critical for helping the mental health system meet its goal of a robust continuum of services.
NAPHS comment letter on proposed rule on Hospital Outpatient Prospective Payment System (OPPS)
CMS proposed rule: "Medicare Program: Hospital Outpatient PPS and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs;....EHR Incentive Programs; Payment to Certain Off-Campus Outpatient Departments of a Provider; Hospital Value-Based Purchasing Program" (NOTE: partial hospitalization section begins on p.45667)
Medicare Learning Matters article (MM9961): "July 2016 Integrated Outpatient Code Editor (I/OCE) Specifications Version 17.2” including planned partial hospitalization code edits
MEMBERS: Background handout for today's Hot Topics webinar titled “IPF and Partial Hospital Program PEPPER Update”
Medicare Learning Matters Special Edition Article (SE1607): "Enforcement of the Partial Hospitalization Program (PHP) 20 Hours per Week Billing Requirement". [Also see 7.7.16 suspension of July 1, 2016, implementation of code edits.]
NAPHS letter to House Energy and Commerce Committee: "Partial hospitalization should be exempt from site-neutral provision"
CMS final rule on the Medicare outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY16.
NAPHS comment letter on proposed Medicare hospital outpatient PPS/partial hospitalization program (OPPS/PHP) rates for CY16
CMS proposed rule on the Medicare hospital outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY16
Center for Medicaid and CHIP Services (CMCS)/SAMHSA informational bulletin on “Coverage of Behavioral Health Services for Youth with Substance Use Disorders”
CMS final rule on the Medicare outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY15.
NAPHS comment letter on proposed Medicare hospital outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY15.
CMS proposed rule on the Medicare outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY15 and OPPS quality measures.
CMS final rule on Medicare Hospital Outpatient Prospective Payment System (including CY14 partial hospitalization rates). See pages 75045-75054.
NAPHS comment letter on proposed Medicare hospital outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY14
OIG Report: "Vulnerabilities in CMS's and Contractors' Activities To Detect and Deter Fraud in Community Mental Health Centers" (OEI-04-11-00101)
CMS final rule with comment period: "CMS-1589-FC: Medicare: Hospital Outpatient Prospective Payment System..." (including CY13 partial hospitalization rates, pages 68404-68418).
NAPHS comment letter on proposed Medicare hospital outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY13 [View]
OIG report on "Questionable Billing by Community Mental Health Centers" [View]
CMS final decisions on the recommendations of the Hospital Outpatient Payment Panel on supervision levels for select services (also see 5/18/12 NAPHS comment letter) [View]
NAPHS comment letter on CMS' preliminary decisions on the recommendations of the Hospital Outpatient Panel on Supervision Levels for Select Services
MedLearn Matters article (MM7672): January 2012 Update of the Hospital Outpatient Prospective Payment System [View]
CMS final rule: "Medicare Hospital Outpatient Prospective Payment, etc." including partial hospital rates for 2012 (see pages 74346-74352) [View]
CMS clarifies outpatient supervision policy (Transmittal 128) [View]
Tricare final rule: Hospital-based psychiatric partial hospital programs (TRICARE approval of a hospital is sufficient for its psychiatric partial hospitalization program to be an authorized TRICARE provider) [View]
Medically unnecessary edits (MUEs) for certain partial hospitalization codes [View]
Recurring: CMS: outpatient PPS pricers (check periodically for most recent) [View]