October deadline looms for quality measure reporting under the IMPACT Act

On October 6, 2014, President Obama signed into law the Improving Medicare Post-Acute Care Transformation Act of 2014, an amendment to the Social Security Act that requires the submission of standardized data by the several kinds of providers of post-acute care.

The Act is the result of an invitation issued by the sitting chairmen and ranking members of the House Ways and Means and Senate Finance Committees to 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.

Patients may receive post-acute care – care following surgery or a stroke, for example – from four different providers, each of which, prior to the passage of the Act, had its own set of complicated rules, procedures and costs:

  • a skilled nursing facility (SNF),
  • a hospital-based inpatient rehabilitation facility (IRF),
  • a long-term care hospital (LTCH), or
  • from a home health agency (HHA).

The new law:

  • Requires PAC providers to begin reporting standardized patient assessment data at times of admission and discharge by October 1, 2018, for skilled nursing facilities, hospital- based inpatient rehabilitation facilities, and long-term care hospitals, and by January 1, 2019, for home health agencies. This will include acute hospitals, cancer hospitals, and critical access hospitals by 2019.
  • Adds 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.

The IMPACT Act intends to address all of the priorities within the CMS Quality Strategy, which are:

  • Making care safer by reducing harm caused in the delivery of care.
  • Ensuring that each person and family is engaged as partners in their care.
  • Promoting effective communication and coordination of care.
  • Promoting the most effective prevention and treatment practices for the leading causesof mortality, starting with cardiovascular disease.
  • Working with communities to promote wide use of best practices to enable healthy living.
  • Making quality care more affordable for individuals, families, employers, and governments by developing and spreading new healthcare delivery models.

The Secretary is directed to reduce by 2% the update to the market basket percentage for skilled nursing facilities that do not report assessment and quality data. The Act directs the Secretary to study the effect of individuals' socioeconomic status on quality, resource use, and other measures for individuals under the Medicare program, and the impact on such measures of specified risk factors.



The Act


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