New Post-Acute Care Quality Measures Take Effect Oct. 1 The IMPACT Act requires facilities to report standardized patient assessment data. Are you ready? Bottom Line
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Bottom Line  |   June 01, 2016
New Post-Acute Care Quality Measures Take Effect Oct. 1
Author Notes
  • Sarah Warren, MA, is director of ASHA health care regulatory advocacy. swarren@asha.org
    Sarah Warren, MA, is director of ASHA health care regulatory advocacy. swarren@asha.org×
  • Tim Nanof, MSW, is director of ASHA health care policy and advocacy. tnanof@asha.org
    Tim Nanof, MSW, is director of ASHA health care policy and advocacy. tnanof@asha.org×
Article Information
Regulatory, Legislative & Advocacy / Attention, Memory & Executive Functions / Bottom Line
Bottom Line   |   June 01, 2016
New Post-Acute Care Quality Measures Take Effect Oct. 1
The ASHA Leader, June 2016, Vol. 21, 34-35. doi:10.1044/leader.BML.21062016.34
The ASHA Leader, June 2016, Vol. 21, 34-35. doi:10.1044/leader.BML.21062016.34
To control costs and improve outcomes, the federal government has launched several mechanisms to capture information on the quality and efficacy of health care. One of these is the 2014 IMPACT (Improving Medicare Post-Acute Care Transformation) Act, which establishes a uniform system of measure reporting across all post-acute care settings: home health, inpatient rehabilitation facilities (IRFs), skilled nursing facilities (SNFs) and long-term care hospitals (LTCHs).
What is the IMPACT Act?
Signed into law in October 2014, the IMPACT Act requires the Centers for Medicare and Medicaid Services (CMS) to develop standardized patient assessment data on specific quality measure domains for post-acute care facilities. Standardized data allows for comparisons across these settings and, possibly, for the development of one payment system for all four settings. Facilities, rather than individual providers, report IMPACT-related data.
What are the quality measures required under the IMPACT Act?
CMS will develop the following measures by specified deadlines:
  • Functional status, cognitive function, and changes in functional status and cognitive function (IRFs and SNFs: Oct. 1, 2016; LTCHs: Oct. 1, 2018; home health: Jan. 1, 2019).

  • Skin integrity and changes in skin integrity (IRFs, SNFs and LTCHs: Oct. 1, 2016; home health agencies: Jan. 1, 2017).

  • Medication reconciliation (home health: Jan. 1, 2017; IRFs, SNFs and LTCHs: Oct. 1, 2018).

  • Incidence of major falls (IRFs, LTCHs and SNFs: Oct. 1, 2016; home health agencies: Jan. 1, 2019).

  • Accurately communicating the existence of and providing for the transfer of health information and care preferences (IRFs, SNFs and LTCHs: Oct. 1, 2018; home health: Jan. 1, 2019).

  • Resource use (IRFs, SNFs and LTCHs: Oct. 1, 2016; home health: Jan. 1, 2017).

How does the law define the concepts of functional status and cognitive function?
Functional status is represented by concepts such as mobility and self-care, and the law indicates it could be demonstrated by change from admission to discharge.
Cognitive function is defined as the ability to express and understand ideas, and mental status such as depression or dementia. ASHA is working with CMS and other stakeholders to promote inclusion of functional cognitive measures related to attention, memory, problem-solving and executive function. ASHA’s proposal is based on previous efforts several years ago to develop cognitive assessment measures for the CMS Continuity Assessment and Record Evaluation. That assessment instrument, which could have been used across post-acute care settings, was never adopted—but integrating these items into existing tools is under consideration.
Standardized data should also capture this and other information:
  • Special services, treatments, and/or interventions such as ventilator use and chemotherapy.

  • Medical conditions and comorbidities such as pressure ulcers and chronic heart failure.

  • Impairments such as hearing and vision loss.

ASHA is working with CMS and other stakeholders to promote inclusion of functional cognitive measures related to attention, memory, problem-solving and executive function.

What is the IMPACT implementation process?
CMS is taking a variety of steps to be transparent in its implementation of IMPACT requirements. For example, CMS is using technical expert panels to develop measure specifications for the required quality domains. Once developed, these draft measure specifications are released for public comment—but stakeholders have raised concerns about the short comment periods. The measure specifications are also released for public comment through the annual proposed rules for each setting and through the National Quality Forum, a nonprofit membership-based organization leading the national effort to improve health care through measurement.
ASHA has been represented on several of the technical expert panels, most recently on the panel developing standardized patient assessment data.
Several measures CMS intends to use for IMPACT Act implementation have already been specified and, in some cases, adopted through the rulemaking process. For example, functional outcomes measures for self-care and mobility have been implemented in the IRF prospective payment system, and a technical expert panel is determining whether these measures would be appropriate for SNFs.
CMS has also included specific measures for discharge to community, Medicare spending per beneficiary, readmission and drug regimen review.
CMS has already included some measures as additional sections to existing assessment tools (for example, the Minimum Data Set in SNFs). This approach, although it allows each setting to maintain its current tools, may increase providers’ reporting burden.
Will CMS provide feedback reports or make the data publicly available in the future?
IMPACT requires reports to facilities at least every quarter, beginning within a year of the application date for a measure. For example, the functional status and cognitive function measure domain must be implemented by Oct. 1, 2016, in IRFs and SNFs, so the first feedback report for this measure in these settings is due by Oct. 1, 2017.
Public reporting will begin within two years of the application date. The same data on functional status and cognitive function measures in IRFs and SNFs would become public by Oct. 1, 2018. CMS must develop a process for providers to review information and submit corrections before data are publicly reported.
How will CMS develop a standardized payment methodology for post-acute care settings?
The law requires the Medicare Payment Advisory Commission to determine if a unified payment system for all post-acute care settings is possible. The first report is due June 30; the commission has preliminarily indicated that a system is feasible.
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June 2016
Volume 21, Issue 6