Industry Insights

The Impact of the IMPACT Act

November 2014
Author:  Sherri Robbins

Sherri Robbins

Senior Managing Consultant


Health Care

910 E. St. Louis Street, Suite 200
P.O. Box 1190
Springfield, MO 65801-1190 (65806)


President Obama signed the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 on October 7, 2014. The law is intended to modernize Medicare payments to post-acute care (PAC) providers by improving accountability and quality of care across all settings. PAC providers include services provided in long-term care hospitals (LTCH), inpatient rehabilitation facilities (IRF), skilled nursing facilities (SNF) and home health agencies (HHA).

The act was developed with recommendations from more than 70 health care stakeholders. Without comparable data across PAC settings, it's currently impossible to determine if care provided in various care settings is comparable and cost-effective. This act is intended to standardize data that will allow Medicare to do the following:

  1. Compare quality across PAC settings
  2. Improve hospital and PAC discharge planning
  3. Use the information to reform PAC payments (for example, via site neutral or bundled payments), while still ensuring the continued access to beneficiaries in the most appropriate PAC setting 

The IMPACT Act has drawn praise from the American Health Care Association (AHCA) and the National Association for the Support of Long Term Care. According to AHCA President and CEO Mark Parkinson, “IMPACT will standardize assessments for critical care issues across the spectrum of post-acute care (PAC) providers. Assessing improvement in areas such as functional outcomes, pressure ulcers and dementia goes a long way toward improving the health and well-being of our patients.” The National Association for Home Care and Hospice (NAHC) also has released a statement of support:  “Overall, NAHC is very supportive of the goals behind the IMPACT Act and fully supports the development of a uniform patient assessment and discharge planning process.”

To prepare for this shift, post-acute providers should begin closely monitoring and improving upon their quality metrics, resource utilization and process improvements, if not already doing so.

PAC providers currently use their own type of assessment. SNFs use the Minimum Data Set (MDS), HHAs use the Outcome and Assessment Information Set (OASIS), IRFs use the IRF Quality Reporting Program and LTCHs use the LTCH Quality Reporting Program. The act will amend title XVIII of the Social Security Act and add section 1899B. This will require PAC providers and others to report standardized assessment data with standardized quality measures and resource use measures. This will require modification of all PAC assessment data to allow for comparison across all PAC providers. Beginning October 1, 2018, for SNFs, IRFs and LTCHs (and January 1, 2019, for HHAs), PAC providers will be required to report standardized patient assessment data under the requirements of the applicable reporting provisions. 

At a minimum, reporting will be required at admission and discharge. The standardized assessment data will include functional status, cognitive function, special services, medical conditions, impairments and prior functioning levels—as well as any other categories determined necessary and appropriate. The act also requires existing patient assessment data elements that are duplicative or overlapping to be revised or replaced. 

In addition, standardized patient data will be required for inpatient hospitals, along with alignment with Medicare Part B therapy data, new quality measures and resource use measures. There also will be confidential feedback reports to PAC providers in 2017 followed by public reporting of PAC provider performance by 2018. The act indicates there will be payment consequences for PAC providers that fail to report the standardized assessment data, quality resource and other measures.

The IMPACT Act also requires the Centers for Medicare & Medicaid Services to survey hospices at least every three years for the next 10 years. “Prior to the IMPACT Act, there was no set time frame for frequency of hospice surveys, and the average length of time between surveys for hospice providers is six to eight years—with some hospices not having been surveyed in over a decade,” NAHC says. “More frequent surveys are a step toward helping ensure hospice provider compliance with regulations and proper administration of the hospice benefit.”

Stay tuned for additional information regarding the IMPACT Act. If you have additional questions, contact your BKD advisor.

BKD LinkedIn BKD Twitter BKD Youtube BKD Google Plus