APA WF# 24-29 Diagnosis Clarification for Inpatient Psychiatric Services
These proposed policy changes are being promulgated as Permanent Rules.
These proposed policy revisions pertain to diagnoses criteria for inpatient psychiatric treatment admission. Specifically, Autism Spectrum Disorder (ASD) and Intellectual Disability (ID) will no longer be primary diagnoses for admission to inpatient psychiatric services. The primary diagnosis for admission into an inpatient psychiatric facility must be consistent with the primary reason for admission. ASD and ID may be secondary diagnoses, but not primary. These changes will apply to inpatient psychiatric services for both adults and children and shall not be used preclude or exclude any member with ASD or ID.
Update 12/17/24: The draft regulatory text has been revised in response to feedback received from the public and advocates. Please review the updated draft and share any additional comments or suggestions via the comment box.
Please view the revised circulation document here: APA WF# 24-29
Circulation Date: 12/2/2024
Comment Due Date: 1/6/2025
Public Hearing: 1/6/2025
Board Meeting: 1/15/2025
Submit a Comment
After you submit your comment, you should be re-directed to a confirmation page. If you are not, please submit your comment through e-mail to federal.authorities@okhca.org.
Please note that all comments must be reviewed and approved prior to posting. Approved comments will be posted Monday through Friday between the hours of 7:30 a.m. – 4 p.m. Any comments received after 4 p.m. will be posted on the following business day.
Comments
Aimee:
The population described in the proposed rule change is included in the federal ADA LAW and this exclusion is not allowable.
https://www.ada.gov/topics/intro-to-ada/
Examples of Disabilities
- There is a wide variety of disabilities, and the ADA regulations do not list all of them. Some disabilities are visible and some are not. Some examples of disabilities include:
- Cancer
- Diabetes
- Post-traumatic stress disorder
- HIV
- Autism
- Cerebral palsy
- Deafness or hearing loss
- Blindness or low vision
- Epilepsy
- Mobility disabilities such as those requiring the use of a wheelchair, walker, or cane
- Intellectual disabilities
- Major depressive disorder
- Traumatic brain injury
The ADA grants rights and prohibits discrimination. Failing to observe this federal law which has been in place since 1990, opens the State of Oklahoma up to federal intervention and lengthy and expensive legal proceedings by the U.S. Department of Justice, Civil Rights Division, Disability Rights Section.
It seems like we could avoid having to comply with yet another federal consent decree for Oklahoma state government programs. Please reject this proposed rule change.
OHCA Response:
This policy revision is intended to clarify existing prior authorization and claims submission processes related to primary and secondary diagnoses for inpatient psychiatric care. When providers submit claims to OHCA, they often include multiple diagnoses. OHCA seeks to ensure that the primary diagnosis reflects the presenting behaviors observed at the time of admission.
Please be assured that this clarification does not mean admissions will be denied for individuals with autism or intellectual disabilities who are experiencing behavioral health concerns. Instead, it ensures that the primary diagnosis aligns with the presenting behaviors.
This revision will not create exclusionary criteria for members with ASD/IDD, and OHCA will work to ensure that such exclusions do not occur at the facility level.
Cara:
I have concerns about how vaguely this policy is written. Sometimes children with autism/id need to access in-patient psych care with this as their primary diagnoses, not secondary. The way this is written leaves significant room for interpretation for providers to deny care just because a person has ASD or ISD.
OHCA Response:
This policy draft has been revised to clarify existing prior authorization and claims submission processes related to primary and secondary diagnoses for inpatient psychiatric care. When providers submit claims to OHCA, they often include multiple diagnoses. OHCA seeks to ensure that the primary diagnosis reflects the presenting behaviors observed at the time of admission.
Please be assured that this clarification does not mean admissions will be denied for individuals with autism or intellectual disabilities who are experiencing behavioral health concerns. Instead, it ensures that the primary diagnosis aligns with the presenting behaviors.
This revision will not create exclusionary criteria for members with ASD/IDD, and OHCA will work to ensure that such exclusions do not occur at the facility level.
Carley
This is abhorrent, and the room for interpretation will cost Oklahomans with autism and ID their actual lives.
OHCA Response:
This policy draft has been revised to clarify existing prior authorization and claims submission processes related to primary and secondary diagnoses for inpatient psychiatric care. When providers submit claims to OHCA, they often include multiple diagnoses. OHCA seeks to ensure that the primary diagnosis reflects the presenting behaviors observed at the time of admission.
Please be assured that this clarification does not mean admissions will be denied for individuals with autism or intellectual disabilities who are experiencing behavioral health concerns. Instead, it ensures that the primary diagnosis aligns with the presenting behaviors.
This revision will not create exclusionary criteria for members with ASD/IDD, and OHCA will work to ensure that such exclusions do not occur at the facility level.
