What is the IMPACT Act of 2014, and Should It Be Affecting Your Operations?

The IMPACT Act of 2014 was signed into law on October 6, 2014.  IMPACT stands for “Improving Medicare Post-Acute Care Transformation” and this is indeed what this Act has begun to do.  In summary, what the Act does is that it reforms how post-acute assessment data is collected across different Medicare settings.  There was a resounding need not only for a standardization in data, but also for the instruments which collect it.  Obviously, as this is specifically geared towards Medicare, this Act will streamline their processes first and foremost, and it will enable several beneficial things overall regarding the services which they oversee.  The Act will allow for the collection of data which will further allow for quality comparison, for improvement of hospital and post-acute care discharge planning, and for further scrutiny towards Medicare payments for post-acute care (United States Senate Committee on Finance, n.d.).  This Act will also benefit from the upcoming ICD-10 implementation we can look forward to in October, 2015.  The increased number of codes available at this time for not only diagnoses, but also procedures, equipment, services, etc., will allow for a much easier transition towards implementation of the IMPACT Act.  The ICD-10 implementation will be a huge step towards easier compliance from post-acute providers of all specialties.

The question becomes, how should this be effecting your operations at current?  The answer is not a simple one.  The Act requirements will be phased in over time which begins in October 2016, one year after the implementation of ICD-10 coding.  Our focus needs to shift towards the three broad aims that the IMPACT Act is working towards regarding quality which include better care, healthier people and communities, and affordable care (Centers for Medicare and Medicaid Services, 2014). Obviously, on the heels of doing this, we must also ensure that we are working towards the implementation of the required standardized forms into our operations, electronic health records, or other systems which we might use.  This information will need to be reported in some interoperable way when the Act begins to be implemented in earnest.  Many post-acute providers already have systems in place such as the OASIS (home health), RAI/MDS (skilled nursing facilities), IRF-Patient Assessment Instrument (inpatient rehabilitation facilities), and LTCH-Continuity Assessment Record and Evaluation (long-term acute care hospitals).  All of these required forms are in use today by providers, however the ability for them to be interoperable with each other is what we need to start questioning.  The main point here is to ensure that services are not being inadequately utilized and that there is no duplication of those services across providers.  This will force each of the different post-acute care types to ensure that they are using the same ICD-10 codes at that time as other providers, and that their information meets these new interoperability requirements.  Indeed, a tall order for providers who are already stretched in the area of resources.

Some important websites with further information:

Centers for Medicare and Medicaid Services. (2014). IMPACT Act of 2014 & Cross Setting Measures.  Retrieved from http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Post-Acute-Care-Quality-Initiatives/IMPACT-Act-of-2014-and-Cross-Setting-Measures.html

United States Congress. (2014). The Improving Medicare Post-Acute Care Transformation Act of 2014 (Full Text).  Retrieved from http://www.gpo.gov/fdsys/pkg/BILLS-113hr4994enr/pdf/BILLS-113hr4994enr.pdf

United States Senate Committee on Finance. (n.d.).  The Improving Medicare Post-Acute Care Transformation Act of 2014.  Retrieved from http://www.finance.senate.gov/imo/media/doc/IMPACT%20Summary.pdf

Pitts, P.W., Christy, D.S., and McCurdy, D.A. (2014). Analysis and Impact of the Improving Medicare Post-Acute Care Transformation Act of 2014.  Retrieved from http://www.reedsmith.com/files/Publication/a0c30fb6-81bd-4739-9be5-169e20aad8ae/Presentation/PublicationAttachment/1841b086-dd16-4a9c-a0fa-2cc2081dadb6/Analysis%20and%20Impact%20of%20the%20Improving%20Medicare%20Post-Acute%20Care%20Transformation%20Act%20of.pdf

  

Contributed by Dr. Michael Mileski, DC, MPH, MSHEd, LNFA, SJC Faculty