IMPACT Act: Post-Acute Care’s Turn at Standardization and Interoperability

March 2016

A bi-partisan piece of legislation signed into law by President Obama in September 2014 is finally making its way into the Post-Acute Care spectrum. The 2014 IMPACT Act seeks to “require that CMS make interoperable standardized patient assessment and quality measurement data, as well as other measures and uses, available to allow for its exchange among Post-Acute Care (PAC) and other providers to facilitate coordinated care and improved outcomes.”

That’s to say, CMS is going to require that certain long term care provider types transmit quality measurement and other data, in a common format so that its uses may be shared among the continuum of care spectrum. The data among the providers will have a standardized feel to it, and it can be easily retrieved by a number of resources along the provider, or CMS, system – or interoperable.

In order to ensure that this can happen, IMPACT is requiring Long-Term Care Hospitals, Skilled Nursing Facilities, Home Health Agencies and Inpatient Rehabilitation Facilities to submit standardized assessment data. In the past, these provider settings tended to transmit data in their own language. As such, information and data was analyzed accordingly. That became clunky, inefficient and ineffective. Now, CMS wants everyone on the same page speaking the same language so that it may be easily interpreted, analyzed, trended and communicated more efficiently across the post-acute care continuum – or standardized.

The new requirement, effective as early as October 1, 2016 for some providers, makes sense. This will mean that reports, averages, medians and percentages will be more accurate as everyone will be reporting data consistently. It also maximizes the ability to evaluate and analyze appropriate care settings for and by individuals and care givers.

Today’s quality reporting assessment guidelines are built upon a foundation of Fee-For-Service type programming. Given the shift and movement to more “value based” payment mechanisms, it was important for PAC to start reporting data in line with all major provider care settings. The importance is further highlighted given that the PAC industry represents over 32,500 care settings representing more than 6.8 million beneficiaries and 74 billion dollars in Medicare spending.

SNFs and IRFs will need to start reporting standardized assessment data on October 1, 2016, LTCHs October 1, 2018 while HHAs will start October 1, 2019. As different Quality Measure Domains are brought into the reporting criteria, other start dates are initiated, accordingly, to include those new data element features in the reporting standards.

PAC providers will need to report standardized assessment data for Functional Status, Cognitive Function/Mental Status, Special Services/Treatments/Interventions, Medical Conditions/Co-Morbidities, Impairments and Other Categories by October 1, 2018 (SNFs, IRFs, LTCHs) and October 1, 2019 (HHAs).

The data element standardization and report transmissions will allow for a shared understanding of clinical data, re-use of data elements, support exchange of patient assessment data in addition to broadening and supporting the CMS effort to “advance interoperable health information exchange and care coordination.”

As funding moves further away from standard fee-for-service contracts and “value based” payments take hold, the implementation of the IMPACT Act, according to CMS, will allow for:

  • Effective communication between sites
  • Create safer transitions of care for those with the most complex issues
  • Improved coordination of care across all sites with a shared care plan
  • A new reliance on the electronic exchange of standardized and interoperable information

As these features become more apparent, CMS includes in its goals a pathway to a shared nationwide health care system with the “ability of [the] system to exchange electronic health information with and use electronic health information from other systems without special effort on the part of the user.

For more information on the IMPACT Act, contact your BNN advisor at 1.800.244.7444.

Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.