IMPACT 2014: Where Are We Now?

Those in post-acute care should frequently check for any new reports on this subject.

The Centers for Medicare & Medicaid Services (CMS) sponsored an FAQ call on June 21 concerning IMPACT (Improving Medicare Post-Acute Care Transformation), which is directed by the legislation of the same name enacted in 2014.

This was a one-hour call, about half of which was devoted to presenting background and update information, and then the remainder was devoted to questions from listeners. The information provided by CMS was wide-ranging in specificity, while the questioners tended to have more detailed questions, because they were coming from a specific post-acute setting.

For the purposes of IMPACT, there are four settings:

• Home Health Agencies (HHAs)
• Inpatient Rehabilitation Facilities (IRFs)
• Long-Term Care Hospitals (LTCHs), and
• Skilled Nursing Facilities (SNFs)

Hospice was also mentioned during the discussions and will probably be included at some point in the future.

Areas of questions and discussion included:

• Quality resource use and other measures
• Public Reporting Standardized Patient Assessment Data Elements (SPADE)
• CMS Data Element Library (DEL)

CMS is using outside contractors, including RAND and RTI (Research Triangle Institute). Thus there is ongoing activity in these areas, including special studies and associated reports. This is a multi-year project, and anyone involved in post-acute care, which includes acute-care hospitals along with the identified post-acute providers, should frequently check to see what has developed and/or whether there are any new reports that are available.

One of the main concerns is the collection of standardized patient assessment data. There are separate payment systems for each of these four areas. Each of the payment systems already uses some sort of standardized patient assessment instrument (PAI). One of the overarching issues is whether there will be a single, unified patient assessment form, or whether the current forms will be modified and extended to meet the IMPACT needs. CMS is indicating that the current forms will be modified and extended. These different forms were developed for payment purposes, and the payment systems involved are quite different, so making changes for collecting some sort of uniform patent assessment data is a challenge.

Two areas in which questions were raised were the reporting of functional status and medication reconciliation. For HHAs, questions relating to ambulatory tests (e.g., walking and turning) are particularly pertinent because there may be little room in a beneficiary’s home to administer such tests. The measurement of medication reconciliation is one of redundancy. Section GG of MDS 3.0, LTCH CARE Data, and the 2019 release of OASIS were discussed through both the presentation and then the questions raised by participants. The main issue is that of consistency, and then also who will be performing and documenting the assessment. CMS seems to believe that this will be done by a multi-disciplinary team.

The use and meaning of the statistic for “Medicare spending per beneficiary” also raises questions. Exactly how this relates to quality measures is an interesting question.

Another area of concern is how the IMPACT data collection dovetails into the “meaningful measures Framework.” In theory, the alignment and provision of proper post-acute care should assist in meeting meaningful measures.

Although not discussed extensively, CMS also did indicate that there would be a SNF QRT Compare Website launched by Oct. 1, 2018.

CMS encourages all interested parties to access and study the Data Element Library. This is a centralized resource for CMS assessment instrument data elements and their associated mapping to nationally accepted health information technology standards (go online to https://del.coms.gov).

There is much activity going on with the implementation of IMPACT. This is a multi-year process, and there are other quality data gathering efforts with which IMPACT must be coordinated. Without a doubt, compliance issues will be recognized in connection with the implementation. Compliance personnel, along with quality assurance personnel, should monitor circumstances as IMPACT is implemented in the coming years.