The IMPACT Act
October 14th, 2016
The IMPACT Act (Improving Medicare Post-Acute Care Transformation) became law in 2014 to clarify their discharge options.
Imagine an orthopedic unit with four patients who had total knee replacements. Patients are given four options of post-acute care (PAC) providers: home health services, an inpatient rehab unit, a long-term care hospital or a skilled nursing facility. How do patients make decisions when there is no clear data to assist them in this process?
Also, how does one determine payment reform with bundled payments, neutral site payments and value based purchasing in a system where this data is clearly lacking? One way is standardize the assessment data so we can compare apples to apples.
All four PACs must measure:
1) functional status and changes in function;
2) skin integrity and changes in skin integrity;
3) medication reconciliation;
4) incidence of major falls; and
5) patient preference regarding treatment and discharge options.
These new quality measures will be done through the post-acute care assessment instruments. This must be done by Oct. 1, 2018, for SNF, IRF and LTCH and Jan. 1, 2019, for HHA.
All four post-acute care providers must complete same standardized assessment. The assessment tool must be interoperable to allow for exchange of data among the providers. Using common standards and definitions will help providers coordinate care and improve Medicare patient outcomes. The standardized patient assessment data shall include functional status, cognitive function and mental status, special services and interventions (chemotherapy, ventilator, central line insertion, TPN and dialysis), medical condition, impairments (sensory loss, incontinence, visual loss, inability to swallow), prior functioning levels, and any other categories as stated by the secretary to be necessary and appropriate. Hospitals and other PACs will have to revise their assessment tool to capture this patient assessment data.
There are requirements for resource use measures. The secretary needs to specify resource use and other measurement date by Oct. 1, 2016. This must include at a minimum: 1) Medicare spending per beneficiary; 2) discharge to community; and 3) hospitalization rates of potentially preventable readmissions.
This allows for comparison of the data across all four providers.
This new law will mean more work for post-acute care providers. Failure to follow these would result in payment reductions. These changes could result in a different billing structure in the future which could include site neutral payments or bundling. Providers should review this law carefully. Providers need to create a process to capture these quality measures and put into place quality improvement activities.
A copy of this federal law is available at no charge here.