Wednesday, 15 October, 2014

The IMPACT Act and CHAP Providers

On Monday, October 6, President Obama signed the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 into law. As we have highlighted in our previous updates, the Act includes a provision that requires hospice care programs to be surveyed by state or local agencies every three years. It also requires Medicare post-acute care providers to implement standardized data collection and reporting for patient assessments,care-quality metrics and resource use.

"CHAP applauds Congress and President Obama for passing and enacting the IMPACT Act”, said Karen Collishaw, CHAP President and CEO. “Patients deserve to receive the highest quality home and community-based care possible. The oversight and transparency measures found in this new law will help to ensure all Medicare providers of post-acute care abide by timetables similar to those that accredited agencies have been following for years.  In addition, standardizing the data to be collected by various providers of post-acute care will be helpful in comparing the value of care delivered in different settings. ”

Below, CHAP has summarized sections of the IMPACT Act that may be of importance to our customers. We will continue to follow the law as it enters the rule-making process and provide updates as they are made available.

Hospice Provisions

The law requires certified hospice programs to undergo a standard survey at least once every three years through fiscal 2025.

Surveys are to be conducted by state or local survey agencies or an approved accreditation organization.
The law requires the Department of Health and Human Services(HHS) to conduct eligibility recertification reviews of a hospice program that provides care to individuals if the number of cases in which care is provided for more than 180 days exceeds a percentage threshold of all care cases. The percentage threshold will be set by the department.

Data Requirements

HHS will set standards for unified post-acute care data that will be interoperable and exchangeable between providers. The standards will be designed to provide access to patient care history, foster coordination between care facilities and improve patient outcomes. The standards will apply to the respective reporting, assessment and payment systems used by the various types of post-acute care facilities.
Data and assessments that comply with the law’s requirements could be used by providers to satisfy similar or duplicative reporting requirements.

A “consensus-based entity” such as the National Quality Forum will have to endorse reporting and assessment requirements taken by HHS to unify provider data.

Quality Measures

Post-acute care providers are required to implement unified data and reporting standards for five care quality measures -- changes incognitive functions, skin integrity, medication reconciliation, the incidence of major falls and accurate communication of patients’ medical preferences.

Providers will be required to implement each of the measures over several years, starting Oct. 1, 2016, and ending Jan. 1, 2019. The implementation dates will vary based on the provider type.


HHS will consider potential adjustments to resource use and quality measures data to account for cost differences between providers. The department will have to standardize adjustments based on a patient’s length of stay in post-acute care, the risk assumed by a provider and geographic cost differences between providers.

The adjustment provisions will align post-acute care data with that used in the hospital value-based purchasing system.

Patient Assessment

Providers will be required to modify their patient assessments to include a patient’s functional status, such as mobility,cognitive function, special services and treatments used by the patient,chronic medical conditions, medical impairments and any other category of assessment the department identifies as necessary.

Home health agencies will be subject to the requirement on Jan. 1, 2019.

Discharge Planning

HHS will issue regulations by January 1, 2016, that would require post-acute care providers to use patient assessments and resource use reports to inform the discharge planning process. Providers will also have to account for patient treatment preferences and patient care goals in that planning process.

In developing the rules, HHS will hold town hall meetings and seek stakeholder input from providers and Medicare beneficiaries. Updated rules will have to be issued “periodically” and no less than once every five years.

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