Executive Summary

The Improving Medicare Post-Acute Care Transformation Act (IMPACT), which requires post-acute providers to compile and submit quality, performance, and resource use data, gives hospitals an opportunity to work closely with the providers to which they discharge patients.

  • The Act standardizes data collection and data sharing among post-acute providers. The data will eventually be reported publicly.
  • The IMPACT Act is part of the CMS emphasis on basing reimbursement on quality. Currently, post-acute providers are paid on a fee-for-service basis.
  • The Act gives post-acute providers an incentive to work on initiatives to reduce readmissions to collaborate with hospitals on improving transitions.

A Congressional act requiring post-acute providers to track and submit data gives hospitals a great opportunity to develop close working relationships with post-acute providers, says Wanda Pell, MHA, BSN, a director with Novia Strategies, a national healthcare consulting firm.

The Improving Medicare Post-Acute Care Transformation Act (IMPACT), passed in the fall of 2014, requires home health agencies, skilled nursing facilities, long-term acute care hospitals, and inpatient rehabilitation facilities to submit standardized data, including quality measures, resource use, and other measures.

“This is an opportunity for hospitals to work more closely with skilled nursing facilities and other post-acute providers and communicate better, improve transitions, and as a result, experience fewer readmissions,” Pell says.

The Act is intended to help spur the trend of more integrated care throughout the continuum, says Kurt Hopfensperger, MD, JD, senior medical director of audit, compliance, and education at Executive Health Resources, a Newtown Square, PA, healthcare consulting firm.

“This is part of the Centers for Medicare & Medicaid Services’ [CMS’] push for overall quality as it moves from voluntary reporting of quality measures to mandatory reporting to basing reimbursement on the data reported. It is part of the move from fee for services to fee for value and quality,” he says.

The IMPACT Act standardizes data collection and data sharing, Hopfensperger says. “The idea behind IMPACT is that standardizing data improves transitions of care and results in better care and more affordable care,” he adds.

Dates for implementation vary among the types of providers and the different domains. The earliest that providers will be required to report data is Oct. 1, 2016. CMS will make the performance data public beginning in 2018.

IMPACT requires providers to collect standardized data in the following domains: skin integrity and changes in skin integrity; functional status, cognitive function, and changes in function and cognitive function; medication reconciliation; incidence of major falls; transfer of health information and care preferences when a patient transitions; resource used measures, including that total estimated Medicare spending per beneficiary; discharge to the community; and all-condition, risk-adjusted potentially preventable hospital readmission rates, according to Elizabeth Hogue, Esq, a Washington, DC-based attorney specializing in healthcare issues.

Through the IMPACT Act, CMS will require collaboration between levels of care as well as effective discharge planning, enhanced transition services, and support for caregivers at home, Hogue says.

In the first phase, CMS is requiring the post-acute providers to collect standardized data, Pell says. After analyzing the data, CMS will report back to Congress. CMS will require some types of providers to report data in some domains as early as Oct. 1, 2016, phasing in the others over a three-year period. Providers that do not report data will receive a reduction in reimbursement. CMS will develop a mechanism for public reporting of performance data beginning in 2018.

“This Act will put hospitals and all post-acute providers on a level playing field by giving them the same incentives,” Pell says.

In requiring post-acute providers and facilities to collect data, CMS is trying to get a consistent approach across the board, Pell says. “CMS is going to pick and choose data points and compare them all. This is just a preview of coming attractions. CMS says it wants to develop a uniform payment system, regardless of the site of services. This is the next wave and it seems likely that the end result will be some kind of bundled payment system,” she says.

IMPACT gives hospitals a great opportunity to work on improving readmissions from post-acute providers, Pell says. “Hospitals that have relationships with skilled nursing facilities and meet regularly with them tend to have lower readmissions rates. The same is true about hospitals that collaborate with home health agencies and rehabilitation facilities,” she says.

The requirements of the Act give post-acute providers an incentive to work on initiatives to help avoid hospital readmissions, Hogue says.

“Savvy facilities are already collaborating with hospital case managers and discharge planners. When they understand that they will be monitored, they’ll get on board. This Act should make them realize that the day is not too far off when they’ll be in the same situation as hospitals and will face penalties for readmission,” Hogue says.

So far, there are no penalties for readmissions from post-acute providers but this is likely to be forthcoming, Hogue says. “Soon, both sides will have skin in the game,” she says.

Case managers should be building collaborative relations with post-acute providers, Hogue says.

“We now are calling on discharge planners and case managers to do a whole lot more to improve transitions, including developing collaborative relationships with post-acute providers. It’s no easy task and it will take some time for the resources to catch up with what is now required,” Hogue says.

Hogue suggests that case managers study the interpretive guidelines in the Medicare Conditions of Participation to help them develop relationships with post-acute providers and develop effective discharge plans. “The interpretive guidelines include suggestions about effective discharge planning and lay out in detail what case managers and discharge planners are supposed to be doing. Not only do they specify what is required in great detail, but they also include suggestions,” Hogue says.

Case managers have to give patients a choice when it comes to post-acute providers, but when the IMPACT Act is fully implemented, they will have another way to assist patients in choosing, Pell points out. “Eventually, patients will be able to look at quality measures for home health agencies and skilled nursing facilities so they’ll have more than just a subjective way to choose. This ties into the entire trend you see now for hospitals and other providers becoming patient-centered,” she says.