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IMPACT ACT to Standardize Data Collection for Post-Acute Care Facilities

On October 6, 2014, the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) was signed into law. The bill moved swiftly through both houses due to its joint development by the House Ways and Means Committee and the Senate Finance Committee. The Post-Acute Care (PAC) community also voiced strong support for the IMPACT Act.

Currently, PAC payments to Medicare are typically based on the setting of care. This payment system often results in PAC providers supplying comparable services, but receiving dramatically different reimbursement amounts due to their setting of care. Under the IMPACT Act, the US Department of Health and Human Services (HHS) is tasked with promulgating a reporting system for PAC providers, which includes long-term care hospitals, skilled nursing facilities, inpatient rehabilitation facilities, and home health agencies. PAC providers will be required to report standardized data regarding patient care assessment, resource use, and quality measures. This data collection will allow providers and policymakers to analyze and compare the cost, quality, and type of services offered across a range of PAC providers. It is important to note that the IMPACT Act does not apply to critical access hospitals.

Specifically with regards to quality measures, PAC providers will be required to report on the following issues:

  • Functional status and Cognitive function and changes to either;
  • Skin integrity and changes in skin integrity;
  • Incidence of major falls;
  • Medication reconciliation; and
  • The existence of, and providing for, transfer of care preferences and health information.

    Additionally, the IMPACT Act will require PAC providers to report standardized patient care assessment data at admission and discharge regarding:

  • Mental status and cognitive function;
  • Functional status;
  • Treatments, interventions, and special services;
  • Impairments;
  • Medical conditions and comorbidities (the simultaneous presence of two conditions in a patient); and
  • Other domains that the Secretary of HHS may specify.

    With regard to resource use, the IMPACT Act mandates that PAC Providers report estimated Medicare spending per beneficiary, discharge to community, and any measures to demonstrate risk-adjusted, all-condition, potentially preventable hospital readmission rates.

    Implementation of these reporting requirements will be phased in over a three-year period starting in 2016. Once the Medicare Payment Advisory Commission (MedPAC) collects and analyzes the data, the IMPACT Act requires it to report the merits of the new system to Congress and recommend specific features of the character-based payment system, so that providers can transition away from the current, settings-based system. Eventually, MedPAC and HHS must report to Congress regarding recommendations on a PAC prospective payment system that applies to all PAC providers.

    If you have questions regarding the IMPACT Act or how it may affect your practice, please contact an experienced healthcare attorney at 248-544-0888 or via email at We will continue to notify you of any new federal or state healthcare legislation. To remain updated on healthcare news, subscribe to Wachler & Associates’ health law blog by adding your email address and clicking “Subscribe” in the window on the top right of this page.

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