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FAQ: Corrected Amendment 4 of the 2022 Acute Hospital RFA

This FAQ provides answers to questions that have come up about Amendment 4 of the 2022 Acute Hospital RFA.

Notwithstanding Section 5.D.19.B.1 of the Rate Year 2022 Acute Hospital RFA, hospitals must submit the required attestation no later than May 27, 2022. In the near future, EOHHS will publish an amendment to the RFA to formally implement this change.

Corrected Amendment 4 of the 2022 Acute Hospital RFA outlines the supplemental payment for which acute hospitals are eligible if they are able to attest to providing a subset of psychiatric services to ED-presenting Psychiatric Members.

Table of Contents

Qualifying Services

Some hospitals do not currently offer an “Enhanced Service” as defined in the 2022 Acute Hospital RFA.

Are those hospitals allowed to participate in the Supplemental Payment to Promote Hospital Capacity to Provide Enhanced Emergency Department Psychiatric Services?


Hospitals that do not currently offer an Enhanced Service may be eligible for a Supplemental Payment to Promote Hospital Capacity to Provide Enhanced Emergency Department (ED) Psychiatric Services. To be eligible, the hospital must comply with the terms and conditions in Section 5.D.19 of Corrected Amendment 4.

For example, a hospital seeking to participate as a Tier 1 provider would need to ensure that, among other things, it expands its capacity to provide Enhanced Services to each of its ED-Presenting Psychiatric Members, once within 48 hours of any member’s presentation to the hospital’s ED, and then at least once every three days afterwards until each that member transfers to an inpatient (IP) behavioral health bed. In accordance with section 5.D.19 of Corrected Amendment 4, a hospital will demonstrate the required capacity if at least 90% of its ED-Presenting Psychiatric Members receive at least one Enhanced Service at the required frequency from May 1, 2022, through October 31, 2022.

Are there specific age limits for the specific services for children described in section 5.D.19.A.7.d of Amendment 4?


No. Services should be provided according to applicable standards or best practices for the member’s age.

What are “stabilization interventions” and how do they differ from “baseline services”?


Stabilization interventions include solution-focused therapy or other de-escalation strategies to stabilize or resolve the presenting emergency.

Baseline services include family support and education, screening for substance use disorder (SUD), referring members to ongoing providers, and observation for those with suicidal ideation or homicidal ideation. Our expectation is that EDs are already providing baseline services, since these services are necessary to maintain the safety of psychiatric patients while in the ED.

Providers of Enhanced Services

Must the psychiatrist or advanced practice clinical nurse specialist personally render the Enhanced Services? 

Please see the recently published Corrected Amendment 4 to the RY22 RFA, which modifies the definition of “Enhanced Services” as follows:

Mental health or substance use disorder services provided to ED-Presenting Psychiatric Members by any hospital staff, whether employed or contracted, who is qualified to deliver such services within their scope of practice. Such services may be provided to assess such individual’s mental status or consult on a member’s behavioral health needs, including proper medications, with the Hospital’s medical staff. Such services may include, as clinically indicated:

a.  Medication evaluation. 

b.  Medication management. 

c.  Stabilization interventions (e.g., solution-focused therapy, de-escalation strategies, peer supports, etc.).

d.  Specific services for children that may include:

i.  Applied Behavior Analysis: A service that focuses on the analysis, design, implementation, and evaluation of social and other environmental modifications to produce meaningful changes in human behavior. This service provides for the performance of behavioral assessments; interpretation of behavior analytic data; development of a highly specific treatment plan; supervision and coordination of interventions; and training other interveners to address specific objectives or performance goals in order to treat challenging behaviors that interfere with a youth’s successful functioning.

ii.  Family Therapy: the psychotherapeutic treatment of more than one member of a family simultaneously in the same visit.

e.  Group therapy: the application of psychotherapeutic or counseling techniques to a group of persons, most of whom are not related by blood, marriage, or legal guardianship.

f.  Partial Hospitalization Program interventions (either in person or via telehealth). These services offer short-term day mental health programming available seven days per week, as an alternative to inpatient hospital services. These services include daily psychiatric management.

Eligible ED-Presenting Psychiatric Members/Days

Section 5.D.19.B.1.a of Corrected Amendment 4 covers attestation.
Is MassHealth directing hospitals to include patients awaiting inpatient level of care? Could it be interpreted as patients who were awaiting an IP bed at one point during the ED stay, even if final disposition has changed?


For purposes of the attestation, a hospital may include only those bed-days on which an ED-Presenting Psychiatric Member who requires an inpatient psychiatric or community-based acute treatment (CBAT) level of care was awaiting admission to an inpatient psychiatric or CBAT bed.

Other

Some hospitals are not looking to participate in the Supplemental Payment to Promote Hospital Capacity to Provide Enhanced Emergency Department Psychiatric Services.

Do they still have to complete and return Corrected Amendment 4 to the Acute Hospital RFA?   


Yes. All hospitals must execute and return Corrected Amendment 4 to the Acute Hospital RFA.  

The only reference to the provision of Enhanced Services via telehealth is in the bullet related to partial hospitalization programs.

Are hospitals allowed to provide the other services (consultation, group or individual therapy, family therapy, etc.) through telehealth?


Hospitals may provide any of the Enhanced Services via telehealth when those services are clinically appropriate. The services must follow all applicable laws, regulations, and subregulatory guidance. MassHealth members may decline to receive services via telehealth in order to receive such services in person. See M.G.L. c. 118E, § 79(d).

To qualify as a Tier 2 provider, at least one Enhanced Service must be provided each day. Does this include weekends?


Yes.

May we provide a different Enhanced Service at the identified intervals to qualify as a Tier 1 or Tier 2 provider? For instance, if a facility is Tier 2 provider, and medication evaluation was provided to a boarding patient on one day, and on the next day the patient participated in group therapy, would that qualify?


Yes.

Should patients in observation status be included in the number of bed days on the attestation form?


No. Hospitals may include only those bed days corresponding to members who are ED-Presenting Psychiatric Members, as that term is defined in the RFA. Hospitals may bill for observation, or they may count those days toward the supplemental payment. They cannot do both. MassHealth will address the issue of payment for observation and ED boarding in an upcoming policy announcement.

Some MassHealth patients are in the ED for a long period of time, treated for psychiatric diagnosis, and then discharged home.

Would these patients qualify for the supplemental payment?


A hospital may include only those bed days corresponding to members who are ED-Presenting Psychiatric Members, as that term is defined in the RFA.

Date published: May 13, 2022

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