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With post-acute care services following hospitalization accounting for approximately 23 percent of total annual Medicare spending, it’s no surprise that such services are being watched closely. The Improving Medicare Post-Acute Care Transformation Act (IMPACT Act) requires that post-acute providers, including skilled nursing facilities (SNFs), home health agencies, inpatient rehabilitation facilities (IRFs), and long-term care hospitals, submit standardized assessment data for quality, payment, and discharge planning, and for other purposes. 

On Feb. 4, the Centers for Medicare & Medicaid Services (CMS) held a national provider call to provide information related to the IMPACT Act, the use and exchange of clinically relevant assessment data, and health information technology standards. The slide presentation and transcript of that call can be located at the following link

We’ve addressed some key issues related to the IMPACT Act below. 


Quality is an expectation, and rightfully so! IRFs continue to see a rise in the required number of quality measures and increases in their ability to standardize quality measures across settings, allowing providers, patients, and payors to assess how effective, safe, efficient, and timely services are being delivered. By comparing outcomes – and, ultimately, best practices – across providers and provider settings, care delivery can become more effective and efficient.

While the Act requires reporting of standardized data on functional status, cognitive function, medical needs and conditions, impairments, and other categories deemed necessary, there are other unique data elements specific to IRFs that will continue to be required. The Act does, however, call for replacing duplicative data collection, so it is likely that we will see continuing modifications to the IRF-PAI document over time, along with ongoing updates to the quality reporting elements and requirements. 


The IMPACT Act establishes a framework for moving from fee-for-service (FFS) payment methodologies to value-based payments (VBP) – payments for outcomes and not for volume of services.  Under VBP models, providers are encouraged to improve the quality and safety of care through the reduction of adverse events, focusing on outcomes and managing resource utilization. Again, quality is an expectation, and providers will be incentivized for the provision of high-quality services and ultimately penalized for poor quality. IRFs need to closely follow the development of VBP models.

Communication: The Greatest Benefit

Interoperability, or the seamless exchange of diagnostic and assessment data, is a primary goal of the IMPACT Act, and it provides a cornerstone for improving quality of care through communication of key information. With a vision for high-quality care, lower costs, and a healthier population, CMS plans to create systems to exchange and use electronic health information for healthcare decision-making. While we currently report significant information through the IRF-PAI document, it is likely that the required reporting elements (either through this conduit or others) will increase over time. 

The Impact to IRFs 

IRFs, as well as all post-acute providers, need to focus on required data collection, finding processes that minimize the administrative burden of collecting the information, and training stakeholders in scoring the key items on the standardized assessment tools. 

With the significant implications for payment and utilization of services, IRFs need to be monitoring what’s happing with regulations and making sure that key stakeholders are taking advantage of all Medicare training opportunities in this area.

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Angela Phillips, PT

Angela M. Phillips, PT, is President & Chief Executive Officer of Images & Associates. A graduate of the University of Pennsylvania, School of Allied Health Professions, she has almost 45 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting Inpatient Rehabilitation Facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

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