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AHPA submitted comments on: Medicare Program; FY 2027 Inpatient Psychiatric Facilities Prospective Payment System Rate Update; CMS-1847-P Click here for the full comment letter. Below are some key takeaways.

• Support standardized patient assessment data for inpatient psychiatric care: AHPA supports CMS’s goal of improving the consistency, comparability, and usefulness of behavioral health data. Thoughtfully implemented standardized assessments could help CMS, providers, and patients better understand patient needs, care processes, and outcomes across inpatient psychiatric settings.
• Provide additional implementation flexibility for the IPF-PAI: AHPA recommends that CMS reconsider whether the proposed October 1, 2027, implementation date gives facilities sufficient time to establish new admission and discharge workflows, train staff, implement internal monitoring, and coordinate reporting across clinical, quality, compliance, information technology, and operational teams.
• Establish an initial non-punitive testing period: AHPA recommends treating the fourth quarter of 2027 as a transition or testing period. During this time, inpatient psychiatric facilities could begin collecting and submitting IPF-PAI data without having that initial quarter affect future Medicare payment determinations.
• Delay payment consequences until facilities complete a full reporting cycle: AHPA recommends postponing payment-related compliance determinations until facilities have more experience with the assessment and submission requirements. Allowing at least one full reporting cycle would give facilities time to address workflow problems, train staff, validate data, and resolve technical or vendor-related issues.
• Continue stakeholder engagement and support a realistic digital transition.=: AHPA supports CMS’s long-term movement toward digital quality reporting, including the potential use of FHIR-based submission methods. However, it recommends continued engagement with psychiatric facilities, health systems, clinicians, quality teams, electronic health record vendors, and other technology partners to address differences in technical readiness and prevent smaller or under-resourced providers from being disadvantaged.