The High Cost of Compliance: Assessing the Regulatory Burden on Inpatient Psychiatric Facilities

Inpatient psychiatric facilities operate under a heavy burden of federal regulatory requirements. The National Association for Behavioral Healthcare (NABH) commissioned Manatt Health to assess the burdens that certain federal laws and regulations impose on inpatient psychiatric facilities. This report focuses on three federal regulatory domains that attach to participation in the Medicare program:

1. The so-called “B-tag” requirements, a detailed set of standards for patient evaluations, medical records, and staffing in inpatient psychiatric facilities. These conditions of participation (CoPs) are defined in regulations by the Centers for Medicare & Medicaid Services (CMS), and discussed at length in CMS’ interpretive guidance...