As we’ve noted previously, current reimbursement for inpatient psychiatric units fails to cover the full cost of providing care. [...] Increase in the Electroconvulsive Therapy (ECT) Payment per Treatment We strongly support CMS’s proposal to positively update payment rates for ECT. [...] We think it would be equally difficult to implement the index in the IPF setting as well. [...] If CMS proceeds with the development of the PAI, APA would like to emphasize the importance of ensuring measurements are standardized only in areas that are more easily universally measured. [...] We recommend focusing on the measurement of function rather than symptoms, as existing symptom measurement strategies would not be sufficiently broadly applicable to meaningfully assess or improve quality in care. [...] It is also important for CMS to only consider standardized tools in the public domain and not those that are proprietary or incur a cost for utilization. [...] Proposed Addition of the 30-day ED Visit Quality Measure in IPFQR APA is concerned that adoption of this measure in the IPFQR will have several unintended consequences. If the overall goal is to reduce hospital admission and Length of Stay (LOS), Emergency Department (ED) visits should not be seen as a failure. [...] If clinicians are penalized for ED visits, they may keep a patient in the hospital longer initially which would likely be more costlythan an ED visit. [...] With interoperability still a huge barrier between hospital systems, it is difficult for a clinician to be aware when a patient is seen in the ED and should not be penalized for it. [...] Each of these measures serves a unique role in assessing care coordination and post-discharge outcomes. Adding an ED visit measure is overly punitive and will not improve the quality of care for patients discharged from psychiatric facilities. Thank you for your review and consideration of these comments. If you have questions or want to discuss these comments in more detail, please cont
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