The Centers for Medicare & Medicaid Services (CMS) has proposed a significant new development in the 2024 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) regulations for the 2024 calendar year (CY): the Intensive Outpatient Program (IOP).
This comprehensive healthcare initiative aims to fill one of the primary gaps in behavioral health coverage under Medicare. The proposal outlines the IOP’s scope, doctor certification requirements, billing and coding protocols, and payment rates. IOP services could be extended to hospital outpatient departments, Community Mental Health Centers (CMHCs), Federally Qualified Health Centers (FQHCs), and Rural Health Clinics (RHCs), subject to the finalization of the proposal.
What is the scope of IOP services?
The IOP, as outlined by CMS under the directive of Section 4124 of The Consolidated Appropriations Act (CAA) of 2023, is designed to provide psychiatric services to people suffering from acute mental illnesses or substance use disorders. It will function as an organized and distinct outpatient initiative, offering a range of behavioral health services that will be charged on a per-diem basis. These charges will be under the OPPS or other relevant payment systems when provided in designated settings, such as hospital outpatient departments, CMHCs, FQHCs, and RHCs. The cost per diem of IOP services will be based on those that have been and continue to be covered by Medicare as part of the Partial Hospitalization Program (PHP) benefit – or under the broader OPPS.
Amendments brought forward by Section 4124(a) of the CAA for 2023, in Section 1861(ff)(1) of the Social Security Act, necessitate a physician’s involvement in IOP implementation. Under the proposed regulation, a doctor will need to ascertain that each patient requires at least nine hours of IOP services per week. This certification process will have to be repeated no less frequently than every other month. CMS is looking to enshrine this rule in the regulations governing IOP provisions across all settings and is currently seeking public commentary on the recertification period.
The IOP’s establishment under Medicare will contribute significantly to expanding access to necessary behavioral healthcare, creating an inclusive, robust system that can cater to the diverse needs of Medicare beneficiaries.
CMS welcomes your thoughts and contributions to the ongoing discussion on this proposed rule.
Healthcare has been transitioning toward a more digital, interconnected ecosystem for many years, but the pace and magnitude of current changes represent a fundamental shift.
Has anyone asked you to remember a short list of words, in this case certain nouns? Well, recently, my husband and I were reading some
Please log in to your account to comment on this article.
Accurately determining the principal diagnosis is critical for compliant billing, appropriate reimbursement, and valid quality reporting — yet it remains one of the most subjective and error-prone areas in inpatient coding. In this expert-led session, Cheryl Ericson, RN, MS, CCDS, CDIP, demystifies the complexities of principal diagnosis assignment, bridging the gap between coding rules and clinical reality. Learn how to strengthen your organization’s coding accuracy, reduce denials, and ensure your documentation supports true medical necessity.
Denials continue to delay reimbursement, increase administrative burden, and threaten financial stability across healthcare organizations. This essential webcast tackles the root causes—rising payer scrutiny, fragmented workflows, inconsistent documentation, and underused analytics—and offers proven, data-driven strategies to prevent and overturn denials. Attendees will gain practical tools to strengthen documentation and coding accuracy, engage clinicians effectively, and leverage predictive analytics and AI to identify risks before they impact revenue. Through real-world case examples and actionable guidance, this session empowers coding, CDI, and revenue cycle professionals to shift from reactive appeals to proactive denial prevention and revenue protection.
Sepsis remains one of the most frequently denied and contested diagnoses, creating costly revenue loss and compliance risks. In this webcast, Angela Comfort, DBA, MBA, RHIA, CDIP, CCS, CCS-P, provides practical, real-world strategies to align documentation with coding guidelines, reconcile Sepsis-2 and Sepsis-3 definitions, and apply compliant queries. You’ll learn how to identify and address documentation gaps, strengthen provider engagement, and defend diagnoses against payer scrutiny—equipping you to protect reimbursement, improve SOI/ROM capture, and reduce audit vulnerability in this high-risk area.
Only ICD10monitor delivers what you need: updates on must-know changes associated with the FY26 IPPS, including new ICD-10-CM/PCS codes, CCs/MCCs, and MS-DRGs, plus insights, analysis and answers to your questions from two of the country’s most respected subject matter experts.
Stay ahead of the 2026-2027 audit surge with “Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue,” a high-impact webcast led by Michael Calahan, PA, MBA. This concise session gives hospitals and physicians clear insight into the most likely federal audit targets, such as E/M services, split/shared and critical care, observation and admissions, device credits, and Two-Midnight Rule changes, and shows how to tighten documentation, coding, and internal processes to reduce denials, recoupments, and penalties. Attendees walk away with practical best practices to protect revenue, strengthen compliance, and better prepare their teams for inevitable audits.
As AI reshapes healthcare compliance, the risk of biased outputs and opaque decision-making grows. This webcast, led by Frank Cohen, delivers a practical Four-Pillar Governance Framework—Transparency, Accountability, Fairness, and Explainability—to help you govern AI-driven claim auditing with confidence. Learn how to identify and mitigate bias, implement robust human oversight, and document defensible AI review processes that regulators and auditors will accept. Discover concrete remedies, from rotation protocols to uncertainty scoring, and actionable steps to evaluate vendors before contracts are signed. In a regulatory landscape that moves faster than ever, gain the tools to stay compliant, defend your processes, and reduce liability while maintaining operational effectiveness.
Get clear, practical answers to Medicare’s most confusing regulations. Join Dr. Ronald Hirsch as he breaks down real-world compliance challenges and shares guidance your team can apply right away.
Federal auditors are zeroing in on Inpatient Rehabilitation Facility (IRF) and hospital rehab unit services, with OIG and CERT audits leading to millions in penalties—often due to documentation and administrative errors, not quality of care. Join compliance expert Michael Calahan, PA, MBA, to learn the five clinical “pillars” of IRF-PPS admissions, key documentation requirements, and real-life case lessons to help protect your revenue.
Prepare for the 2025 CMS IPPS Final Rule with ICD10monitor’s IPPSPalooza! Click HERE to learn more
Get 15% OFF on all educational webcasts at ICD10monitor with code JULYFOURTH24 until July 4, 2024—start learning today!
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24
