GNYHA Comments on FY 2025 Medicare IPF and IRF Proposed Rules

June 17, 2024

GNYHA recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the fiscal year (FY) 2025 inpatient psychiatric facility (IPF) and inpatient rehabilitation facility (IRF) proposed rules.

In the FY 2025 IPF prospective payment system (PPS) proposed rule, CMS proposed updates to the patient-level adjustment factors for the first time since FY 2005 and requested information on updates to facility-level adjustment factors. GNYHA supported updating IPF PPS adjustment factors and argued that CMS should simultaneously update the facility-level adjustment factors. Additionally, CMS requested information on the potential inclusion of the Medicare Safety Net Index (MSNI)—developed by the Medicare Payment Advisory Commission—in the IPF PPS. While GNYHA conceptually supports a safety net adjustment, our comments expressed concern about the MSNI and urged CMS to release additional data to stakeholders so that the index can be fully evaluated. Lastly, GNYHA recommended that CMS collect a limited set of data elements through the IPF patient assessment instrument (PAI), which captures the resource use associated with increased staffing costs.

GNYHA also commented on the FY 2025 IRF PPS proposed rule to support the collection of social determinants of health information in rehabilitation settings as well as the addition of new data elements on living situation, food, and utilities in the IRF PAI.