On September 16, 2014, the United States House of Representatives passed by voice vote the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) (H.R. 4994/ S. 2553). The bipartisan, bicameral bill was introduced on June 26 in the House of Representatives by Dave Camp (R-MI) and Sandy Levin (D-MI) and in the Senate by Ron Wyden (D-OR) and Orrin Hatch (R-UT). The bill reflects feedback from stakeholders and is widely supported by the post-acute care (PAC) community. 

The IMPACT Act responds to both policymakers’ and PAC providers’ requests for standardized PAC assessment data across Medicare PAC settings. It requires PAC providers, including skilled nursing facilities (SNFs), long term care hospitals (LTCHs), inpatient rehabilitation facilities (IRFs), and home health agencies (HHAs), to report standardized patient care assessment data, quality measures and resource use and other measures.

  • Standardized patient care assessment data will include categories such as functional status; cognitive function and mental status; special services, treatments and interventions; medical conditions and comorbidities; impairments; and other categories specified by the Secretary of the Department of Health and Human Services.
  • Quality measures will address at least the following domains: functional status, cognitive function, and changes in function and cognitive function; skin integrity and changes in skin integrity; medication reconciliation; incidence of major falls; and accurately communicating the existence of and providing for the transfer of health information and care preferences.
  • Resource use and other measures will address at least the following domains: resource use measures, including total estimated Medicare spending per beneficiary; discharge to community; and measures to reflect all-condition risk-adjusted potentially preventable hospital readmission rates.

As noted in Table1, the data reporting requirements will be phased in by provider, measure type and domain. There will be payment consequences for PAC providers that fail to report the data.

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Importantly, while most observers are encouraged by the bi-partisan support for this legislation, the data collection effort mandated by the bill is simply the first step towards modifying how Medicare pays for PAC services. At this point, there is not the same widespread agreement regarding how to Congress should proceed once the data has been collected. Stakeholders and policymakers have varying opinions on how the data should be used and interpreted, and what policies should ensue. Thus, the ultimate effect of the IMPACT Act on the Medicare PAC system remains uncertain.