Yesterday I participated in a Special Open Door Forum on the Improving Medicare Post-Acute Care Transformation Act of 2014 (i.e., the IMPACT Act) hosted by the Centers for Medicare & Medicaid Services. This was a bipartisan bill introduced in March of last year, passed on September 18th and signed into law on October 6th.
The IMPACT Act requires the tracking and reporting of standardized patient assessment data for:
Assessment and Quality Measures
Quality care and improved outcomes
Post-acute settings affected include home health agencies, skilled nursing facilities, inpatient rehabilitation facilities and long-term care hospitals. The impetus behind the standardization, in theory, is to allow for the exchange of data using common standards and definitions, to facilitate care coordination and to improve Medicare beneficiary outcomes. More importantly, it is a directed effort to develop an informational backbone in support of care coordination across PAC settings.
Categories for which data must be collected and reported include:
Cognitive function and mental status
Special services, treatments and interventions
Medical conditions and co-morbidities
Other categories required by the Secretary
SNFs, IRFs and LTCHs must begin reporting not later than October 1, 2018, while HHA have until January 1, 2019.
Question: If implementation is over three-plus years away, why worry about this now?
Answers: for starters, it’s a bipartisan initiative that isn’t likely to be rescinded regardless of what happens to the Affordable Care Act. Second, compliance with IMPACT is going to require a commitment of additional resources for most organizations, and spreading the effort out over a longer period will mean less dramatic of a short-term financial impact; and third – and most importantly – understanding and embracing the underlying systemic transformation that is driving these compliance requirements will accelerate organizational positioning toward integrated care delivery.
Additional information on the IMPACT Act can be found at CMS’s website on Post-Acute Care Quality Initiatives.