In recent years, the healthcare industry has witnessed significant changes and advancements, particularly with the growth of Medicare and its regulatory standards. Psychiatric hospitals that participate in Medicare are subject to strict guidelines to ensure quality and safety for patients. However, a recent announcement from the Centers for Medicare & Medicaid Services (CMS) has made waves within the behavioral healthcare industry. Starting in March, psychiatric hospitals will undergo significant changes in the way they are surveyed for compliance.
While the move to consolidate surveys into a single process might sound like a simplification, industry leaders argue that the real issues, such as outdated guidelines and excessive paperwork, have yet to be addressed. This shift, which CMS framed as a solution to reduce administrative burdens, has raised concerns from those who believe that without true reform, the core problems within the psychiatric healthcare system will persist.
In this blog post, we will delve into the changes announced by CMS, explore the issues surrounding the current psychiatric hospital conditions of participation (CoPs), and analyze whether the new survey process will alleviate the existing challenges or simply perpetuate the status quo.
What Is Changing for Psychiatric Hospitals Under Medicare?
Currently, psychiatric hospitals that participate in Medicare are required to comply with two separate sets of guidelines: one set for general hospitals, known as the Conditions of Participation (CoPs) for hospitals, and another for psychiatric hospitals, referred to as the special psychiatric CoPs. These psychiatric CoPs were initially established in 1966 and later clarified in 1986, but many argue that they have not kept pace with modern practices in psychiatric care.
The existing structure requires hospitals to undergo two separate surveys to ensure compliance with both sets of CoPs: one conducted by the State Survey Agency (SSA) to assess general hospital CoPs, and another conducted by an outside contractor to assess compliance with the psychiatric CoPs. As you can imagine, this system has often led to increased administrative workload for providers, with hospitals receiving two sets of survey results and citations, making the entire process cumbersome and time-consuming.
Starting in March, CMS will integrate the psychiatric hospital program survey into the hospital program survey. This means that SSA will conduct a single, unified survey, with a single report that consolidates both sets of guidelines. Hospitals will no longer receive two separate sets of citations; instead, the findings will be presented in one report. CMS has hailed this change as a significant move toward reducing unnecessary burdens on healthcare providers, claiming that the multiple inspections were emblematic of an outdated and inefficient system that increased administrative costs.
In essence, the new survey process will streamline the inspections, offering hospitals the potential to reduce redundancies and simplify compliance. However, while this might appear to be a step forward in reducing administrative overhead, industry experts warn that the real issues may not be solved by merely consolidating the surveys.
Why Industry Leaders Are Skeptical About the Change
While CMS is positioning this change as an effort to reduce the burden on psychiatric hospitals, many in the behavioral health community have expressed concerns that the real issue lies in the outdated nature of the psychiatric CoPs themselves. Shawn Coughlin, president and CEO of the National Association for Behavioral Healthcare (NABH), has been outspoken about this issue, arguing that simply consolidating the surveys does little to address the root causes of the challenges faced by psychiatric providers.
“We appreciate CMS’ attention on the special psychiatric CoPs, which is long overdue,” Coughlin said in a statement. “At the same time, shifting these components into a single survey without reforming these CoPs does not provide relief to providers.”
The special psychiatric CoPs have been in place for decades, with minimal updates, and many feel they are no longer suited to the modern healthcare landscape. The documentation requirements, in particular, are seen as burdensome and often disconnected from the reality of patient care.
The Burden of Outdated Psychiatric CoPs
One of the major complaints about the current psychiatric CoPs is the extensive paperwork required by providers. Hospitals are often mandated to create individualized treatment plans, progress notes, and other forms of documentation for each patient. While documentation is important for ensuring care quality and continuity, critics argue that the current CoPs place an inordinate amount of time and energy into paperwork that could be better spent on direct patient care.
A recent report from the NABH highlighted that about 80% of psychiatric hospitals surveyed reported receiving at least one citation during their most recent compliance survey. Furthermore, these citations can be costly: it’s estimated that psychiatric hospitals face a staggering $622 million in costs each year due to these compliance issues. Much of this cost is tied to the need for hospitals to revise forms and policies and retrain staff to meet the regulatory requirements, rather than improving the quality of care.
“The special psychiatric CoPs are no longer appropriate in today’s environment of care,” Coughlin stated. He argued that many of the requirements, such as overly specific documentation, don’t reflect modern psychiatric treatment methods or patient-centered care. For example, individualized treatment plans are often required to be highly detailed, creating a significant administrative burden for providers with limited benefits for patients.
Instead of focusing on outdated documentation practices, many behavioral health providers feel the guidelines should be updated to reflect evidence-based practices and current standards of psychiatric care. The role of psychiatric care has evolved considerably over the years, with a growing emphasis on patient-centered care, integrated care teams, and community-based interventions. In light of these changes, mental health professionals argue that the existing CoPs need to be overhauled to better support these advancements.
The Economic Impact of Compliance Costs
Aside from the time spent on paperwork, the economic burden of compliance is a significant concern for psychiatric hospitals. According to the NABH, the costs associated with compliance citations are not only steep but also unnecessary. Compliance issues often require hospitals to invest in updating forms, revising policies, and retraining staff. These efforts are costly in terms of both time and money, diverting resources away from patient care and reducing the overall effectiveness of psychiatric services.
Given the financial strain that psychiatric hospitals are already under, especially in underserved and rural areas, these compliance costs can be particularly challenging. The burden is even heavier for smaller hospitals with fewer resources, which may struggle to keep up with the extensive administrative requirements while still providing high-quality care.
CMS’s Role and the Need for Further Reform
CMS is certainly taking steps toward addressing some of the administrative burdens faced by psychiatric hospitals with its new consolidated survey process. However, as many experts point out, this change may only be a partial solution to the larger issue. Without addressing the fundamental problems within the special psychiatric CoPs, the new survey process could merely be a cosmetic change that doesn’t truly alleviate the burden on providers or improve the quality of care for patients.
The focus, many argue, should be on updating the CoPs to align with modern psychiatric practices. Reforms could include eliminating unnecessary paperwork, incorporating new care models, and allowing more flexibility in documentation requirements to prioritize patient care over administrative tasks. Additionally, a more patient-centered approach could help hospitals tailor their practices to meet the specific needs of their patients, rather than following rigid, outdated guidelines.
In response to the upcoming changes, CMS has announced that it will provide online training to help states prepare for the new survey process. However, details about the specifics of this training remain limited. While this is a positive step in ensuring smoother transitions for providers, the focus must also be placed on reforming the underlying CoPs to truly make a difference.
Conclusion: A Step in the Right Direction, But More Is Needed
While the consolidation of psychiatric hospital surveys under Medicare is a step toward streamlining administrative processes, it does not fully address the deeper, more complex challenges facing psychiatric providers today. The outdated psychiatric CoPs, with their excessive documentation requirements and rigid guidelines, continue to place a significant burden on providers, diverting valuable resources away from patient care.
Industry leaders like Shawn Coughlin argue that CMS’s focus should not only be on survey consolidation but also on modernizing the psychiatric CoPs to reflect current best practices and patient-centered care models. Without such reform, the healthcare system risks continuing its reliance on outdated rules that do little to improve patient outcomes and only serve to increase administrative costs.
As CMS works to implement these changes, it is clear that further steps are needed to create a more efficient, effective, and patient-centered psychiatric care system. Only then can we ensure that psychiatric hospitals are truly able to provide the high-quality care that patients need, without being bogged down by burdensome administrative requirements.
