IMPACT ACT of 2014… Does it IMPACT you?

Last year, the sitting Chairmen and Ranking Members of the House Ways and Means and Senate Finance Committees invited Medicare post-acute care (PAC) stakeholders to provide ideas for post-acute care reform. The resounding theme across the more than 70 letters received was the need for standardized post-acute assessment data across Medicare PAC provider settings.

The Improving Medicare Post-Acute Care Transformation (IMPACT) Act signed by President Barack Obama on October 6th directs the US Department of Health and Human Services (HHS) to standardize patient assessment data, quality, and resource use measures for PAC providers including home health agencies (HHAs), skilled nursing facilities (SNFs), inpatient rehabilitation facilities (IRFs), and long-term care hospitals (LTCHs).

The lack of comparable information across PAC settings undermines the ability of policymakers to evaluate and providers to determine appropriate care settings for patients based on clinical evidence and quality metrics while differentiating between PAC providers. The IMPACT Act acknowledges this information gap and requires collection and analyses of data that will enable Medicare to: (1) compare quality across PAC settings; (2) improve hospital and PAC discharge planning; and (3) use this information to reform PAC payments (via site neutral or bundled payments, for example) while ensuring continued beneficiary access to the most appropriate setting of care.

The new law:

    • Requires PAC providers to begin reporting standardized patient assessment data at times of admission and discharge by October 1, 2018, for SNFs, IRFs, and LTCHs and by January 1, 2019, for HHAs. This will include acute hospitals, cancer hospitals, and critical access hospitals by 2019.
    • In addition to the required standardized assessment data above, there would also be new requirements for quality measure reporting (Oct. 1, 2016, for SNFs, IRFs and LTCHs, and Jan 1, 2017, for HHAs), that will include functional status changes, skin integrity and changes, medication reconciliation, incidence of major falls and patient preference regarding treatment and discharge options.
    • Requires resource use measures by October 1, 2016, including Medicare spending per beneficiary, discharge to community, and hospitalization rates of potentially preventable readmissions.
    • Requires the Secretary of HHS to provide confidential feedback reports to providers. The Secretary will make PAC performance available to the public in future years.
    • Requires MedPAC and HHS to study alternative PAC payment models, with reports due to Congress in 2016 for MedPAC and 2021-2022 for HHS.
    • Requires the Secretary to develop processes using data to assist providers and beneficiaries with discharge planning from inpatient or PAC settings.