The IMPACT Act: A step toward post-acute care reform
The Improving Medicare Post-Acute Care Transformation (IMPACT) Act (Pub. Law 113-185) was signed into law on October 6, 2014. The Act requires skilled nursing facilities (SNFs), home health agencies (HHAs), inpatient rehabilitation facilities (IRFs), and long-term-care hospitals (LTCHs) to report standardized patient assessment data with regard to quality measures, resource use, and other measures.
The Centers for Medicare & Medicaid Services (CMS) specifies the following Measure Domains to be standardized under the IMPACT Act:
- Skin integrity and changes in skin integrity
- Functional status, cognitive function, and changes in function and cognitive function
- Medication reconciliation
- Incidence of major falls
- Transfer of health information and care preferences when an individual transitions
- Resource use measures, including total estimated Medicare spending per beneficiary
- Discharge to community
- All-condition risk-adjusted potentially preventable hospital readmissions rates.
The IMPACT Act:
- Facilitates care coordination and improved Medicare beneficiary outcomes among post-acute care (PAC) and other providers
- Provides Congress with information about new payment models to consider for future reforms
- Protects the patient’s choice and access to care while encouraging the use of quality data in discharge planning.
Functional cognition
AOTA shared with CMS that under the umbrella of cognition, assessment of functional cognition is necessary to identify cognitive impairments that challenge a client’s ability to accomplish real-world tasks. Occupational therapy practitioners are experts in measuring functional cognition, which includes assessing everyday task performance (e.g., self-care, household management, childcare, workplace tasks). Occupational therapy practitioners treat cognitive impairments because these impairments have the potential to compromise the safety and long-term well-being of patients, both pre- and post-discharge. AOTA continues to advocate with CMS officials to ensure that they consider issues important to the profession of occupational therapy as they implement the IMPACT Act.
PAC payment reform
The Medicare Payment Advisory Commission (MedPAC) is using IMPACT data to recommend a post-acute care payment system or systems that “establish payment rates according to the characteristics of individuals (such as cognitive ability, functional status, and impairments) instead of according to the post-acute care setting where the Medicare beneficiary involved is treated.”
In addition, AOTA is represented on a Technical Expert Panel (TEP) tasked with developing a prototype for a unified PAC payment system. The TEP began meeting in 2018 and work is ongoing, with a target for completing the prototype and report to Congress by June 2022.
The U.S. Department of Health and Human Services cannot implement a new PAC payment system unless Congress passes legislation to authorize it.
IMPACT goal: Appropriate, quality care based on the individual patient
Congress’ objective in passing IMPACT is to capture better, consistent data; carefully and specifically document outcomes related to function and cognition; and rethink how services in SNFs, HHAs, IRFs, and LTCHs are provided, evaluated, and paid for. Ultimately, the goal is to ensure that appropriate, quality care is provided through equitable costs across these settings. The underlying message of IMPACT is that PAC settings must look more at the whole patient, just as occupational therapy practitioners consider all of their clients’ basic and instrumental activities of daily living needed to function and remain healthy (i.e., not re-hospitalized) when they move from PAC to community outpatient care.
CMS IMPACT Act of 2014 Data Standardization & Cross Setting Measures webpage