NABH Chief: CMS’ Plan to Streamline Psychiatric Hospital Compliance Misses Mark

Psychiatric hospitals that participate in Medicare will soon see changes to the way they’re surveyed for compliance.

Currently, providers are surveyed twice to ensure compliance with two different sets of guidelines, or conditions of participation (CoPs). But starting in March, those surveys will be consolidated into one, the Centers for Medicare & Medicaid Services (CMS) announced Monday.

While CMS billed the move as a way to cut down on administrative burdens to providers, industry leaders argue the change doesn’t get to the heart of the problem.


“We appreciate CMS’ attention on the special psychiatric CoPs, which is long overdue,” Shawn Coughlin, president and CEO of the National Association for Behavioral Healthcare (NABH), told Behavioral Health Business in a statement. “At the same time, shifting these components into a single survey without reforming these CoPs does not provide relief to providers.”

Psychiatric hospitals that participate in Medicare are currently bound by two separate sets of guidelines: general hospital CoPs and special psychiatric hospital CoPs, the latter of which were originally established in 1966 and clarified in 1986.

Consequently, such hospitals are surveyed separately to ensure compliance with both sets of rules. The State Survey Agency (SSA) conducts a survey to ensure compliance with hospital requirements, while an outside contractor selected by the SSA conducts a survey to ensure compliance with psychiatric requirements. 


But starting in March, the psychiatric hospital program survey will be fully integrated into the hospital program survey, which SSA will perform, notifying hospitals of any citations in one report rather than two.

“The policy of multiple inspections for psychiatric hospitals is emblematic of the absurd status quo in healthcare,” CMS Administrator Seema Verma said in a press release announcing the news. “For too long, fragmented and misaligned processes have increased burden and administrative costs.”

However, Coughlin believes those burdens will continue, even with the new streamlined process.

Coughlin takes issue with psychiatric CoPs specifically, arguing that they need to be updated to reflect current best practices. As they exist today, CoPs require providers to do an inappropriate amount of paperwork, he said, taking time and money away from patient care.

For example, current CoPs require providers to extensively and particularly document individualized treatment plans and progress notes, adding immense burden to providers with little payoff for patients, according to a recent NABH report.

About 80% of psychiatric hospitals surveyed by NABH reported having at least one citation in their three most recent compliance surveys, according to the association. On top of that, such citations cost an estimated $622 million per year, as they often require providers to update forms and policies to be updated and re-train staff.

“The special psychiatric CoPs are no longer appropriate in today’s environment of care,” Coughlin said in the statement. “CMS should update the interpretive guidance to reflect modern methods of psychiatric services.”

CMS is working on an online training to prepare states for the upcoming change. More details will be released soon.

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