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Repisodic Blog

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Explaining the IMPACT Act



Historically, the various facilities within post-acute care (PAC) have had no standardization in their data collection. Despite PAC types serving different purposes, there is a certain quality of care that should be universal. As the post-acute care continues to cost Medicare billions of dollars, it has become increasingly evident that reform is needed. This reform came in the form of a bill, The Improving Medicare Post-Acute Care Transformation Act (IMPACT Act). This bipartisan bill quickly passed on September 18, 2014 and was signed into law by President Obama on October 6, 2014. The overall goals of this act are to improve outcomes for Medicare beneficiaries through the following: standardized patient assessment data that is uniform and comparable data across post-acute care settings, improved access and reporting, and the infrastructure for future payment reforms. All these refinements improve the quality of care for the patients by making the healthcare system more patient-facing.1,2

The IMPACT Act endorses the previous efforts of the Affordable Care Act of 2010 with regard to the authority already distributed to the Center for Medicare and Medicaid Services (CMS), a push towards value-based care, and similar payment revisions; however, there is a stronger focus on post-acute care.3

The biggest component of the IMPACT Act is the standardization of patient assessment data.

Previously, each of the post-acute care facility types – Long-Term Care Hospitals (LTCHs), Skilled Nursing Facilities (SNFs), Home Health Agencies (HHAs), and Inpatient Rehabilitation Facilities (IRFs) ­– had their own way of collecting data. Even within a given facility type, quality data varied between facilities. This quality data measures patient conditions in terms of their health, wellness goals, ability to communicate, pain they are experiencing, etc. Therefore, without uniformity across facility types, it is hard to compare quality of care between providers. Throughout the early 2000s, CMS made attempts to standardize the data through various laws: Benefits Improvement & Protection Act (BIPA) of 2000, “which required the Secretary to report to Congress on standardized assessment items across PAC settings”; the Deficit Reduction Act (DRA) of 2005, “which required the standardization of assessment items used at discharge from an acute care setting and at admission to a PAC setting and established the Post-Acute Care Payment Reform Demonstration (PAC-PRD) to harmonize payments for similar treatments in PAC settings”; and the PAC Reform Demonstration requirement of 2006, “which mandated that data meet federal Health Information Technology (HIT) interoperability standards.”4 These laws attempted to make a universal tool, such as the Minimum Data Set (MDS) instrument, the Continuity Assessment Record and Evaluation Tool (CARE Tool), and the Outcome and Assessment Information Set (OASIS). These intentions have often hit a roadblock: each provider type has a different idea on which tool correctly assesses their facility best.5

To address this problem, the IMPACT Act implements standardized patient assessment data elements (SPADEs), which allows each facility to use the tool of their choice, since all the tools have the same data options and elements.6 The quality measure domains include “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 an individual transitions.” The resource use and other measure domains include “total estimated Medicare spending per beneficiary; discharge to community; and all-condition risk-adjusted potentially preventable hospital readmissions rates.” Finally, the assessment categories include, “functional status; cognitive function and mental status; special services, treatments, and interventions; medical conditions and co-morbidities; impairments; and other categories required by the Secretary.”7 Besides the uniform metrics, the IMPACT Act has also created a specific timeline for CMS and the different PAC types to report this data. There are 96 reporting dates with three phases of implementation: data collection and analysis, feedback, and reporting, with a “2% payment penalty for failing to report in a timely manner…and a 1-yr interval between each reporting milestone.”8

All of these changes will improve the quality of care for patients by capturing uniform data for the purpose of comparison, communication, and interoperability between PAC provider settings and hospitals. The collected and organized data will have the capabilities to be used for patient-facing research and policy changes that can focus on future reforms. This change in data collection will modernize and promote efficiency within the healthcare system as increased communication and common language reduces errors and expedites the exchange of patient information within the various types of care. All of these improvements will help with coordination of care and discharge.

In addition to standardizing data, the IMPACT Act pushes for a reformed payment system.

Currently, there is an emphasis in our healthcare system to be more patient centered and provide value-based care. Quality of care goes beyond the patient’s care experience; it extends to the payments they will deal with during and after their care. The IMPACT Act wants CMS, MedPAC, and ASPE to create a single “site neutral” payment system for all of the post-acute care facilities, which will focus on the patient rather than the facility or care type.9 This is an effort to shift the focus to the quality of care a patient receives rather than the environment in which the patient receives the care. Although there will be inevitable differences between patients and types of facilities, CMS is responsible for coming up with a way to adjust for the various risks and variability.

All these changes were made to improve outcomes for Medicare beneficiaries by allowing providers to have access to information for coordinated care as well as comparable data across PAC settings. The increased data collection will help with future improvements and research, such as: “(1) the effect of individuals’ socioeconomic status on quality, resource use, and other measures for individuals under the Medicare program; and (2) the impact on such measures of specified risk factors.”10 This is all in an effort to help make the health care system more patient centric, especially around discharge planning, and allow for improved provider access to shared information, leading to more harmonious care transitions.

While also trying to implement the discharge planning requirements of the IMPACT Act, in 2015, CMS proposed a rule that would make discharge planning more patient-centric. It would have more patient involvement, including their preferences and goals in the discharging process. Patient engagement often leads to more informed decisions in their healthcare choices. Better care and health outcomes for the patient results in lower costs for hospitals. “Under the proposed rule, hospitals and critical access hospitals would be required to develop a discharge plan within 24 hours of admission or registration and complete a discharge plan before the patient is discharged home or transferred to another facility, provide discharge instructions to patients who are discharged, have a medication reconciliation process with the goal of improving patient safety by enhancing medication management, patients who are transferred to another facility have their specific medical information sent, and establish a post-discharge follow-up process.”11 Due to the complexity of this rule and large influx in opinions, CMS has decided to push back its finalization of this rule until November 2019.

Repisodic is Committed to Transitional Care

Repisodic is the digital tool that expedites and simplifies the discharge process from hospitals to PACs. Our product, Repisodic Choice, allows hospital discharge planners to easily and efficiently search for the best PAC provider for each individual patient based on the patient’s location, insurance, and unique medical needs. Our solution helps case managers quickly present quality data to patients and their families to help them make informed post-acute care decisions. Like the IMPACT Act, we are committed to giving patients the care they deserve. Click here to learn more about getting Repisodic Choice at your hospital.

[1,3,5,6,8,9] “Coming to Terms With the IMPACT Act of 2014”

[2,7] “IMPACT Act of 2014 Data Standardization & Cross Setting Measures”

[4] “The IMPACT Act of 2014 and Data Standardization”

[10] “H.R.4994 – IMPACT Act of 2014”

[11] “Discharge Planning Proposed Rule Focuses on Patient Preferences”