(Alexandria, VA) The American Therapeutic Recreation Association (ATRA) has provided comments to the Centers for Medicare and Medicaid Services in support of the implementation of a prospective payment system for inpatient psychiatry to assist in cost efficiencies as well as cost effectiveness. ATRA's Executive Director, Ann Huston explains, “We are cautiously optimistic that the implementation of this prospective payment system, based on valid and reliable data, will not impact the quality of care for this underserved and often neglected Medicare beneficiary.”

Of primary concern to ATRA is the lack of research findings to support the proposed payment system. Huston explains, “The completion of the Research Triangle Inc. (RTI) research is absolutely necessary to develop a legitimate and reliable payment system. Implementation of a prospective payment system without support of reliable data is inconsistent with the purpose of the payment system and will unduly impact the providers of inpatient psychiatry services.”

In addition, ATRA is extremely concerned with the proposed co-morbidities' categories; arguing that the list is simply inadequate. According to Huston, "Rarely is an inpatient psychiatry patient presented for admission without several co-morbidities. In fact, our members report that inpatient psychiatry patients often present with 3-12 co-morbidities and one member reported an average of 6.1 co-morbidities per patient on the gero-psychiatry unit". ATRA expressed concern to CMS that with these co-morbid confounding factors, the adjustment(s) for co-morbidities is totally inadequate and will not sufficiently cover the costs for care. ATRA recommends CMS revisit the co-morbidities included in the proposed list and revisit the cost adjustment for each co-morbidity.

Although this is a proposed payment system, the impact on quality of care is evident. Additional issue that ATRA provided specific comment on include; the issue of recidivism and the implementation of the Systematic Nomenclature of Medical Terminology (SNOMED). ATRA is very concerned that the Inpatient Psychiatric Facility PPS is proposed for implementation prior to SNOMED implementation. Implementation of Inpatient Psychiatric Facilities PPS without sufficient evidence based data (RTI research) AND the implementation of SNOMED is imprudent.

ATRA President Melinda Conway-Callahan states, “We look forward to working with CMS and the psychiatry industry to develop appropriate criteria for the Medicare beneficiary requiring inpatient psychiatry services.”

For more information, please contact the ATRA National Office at (703) 683-9420 or at www.atra-tr.org <http://www.atra-tr.org.
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