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IMPACT Act: Aligning Measures Across Post-Acute Care

Jane Pederson
Jane Pederson, MD, MS
Chief Medical Quality Officer,
Stratis Health

The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) is legislation designed to improve the Centers for Medicare & Medicaid Services (CMS) post-acute care (PAC) services. It contains requirements intended to further build the structural shift to patient-centered, value-based care instead of care fractured in setting silos.

Under the current Medicare system, patients can obtain PAC services from four different settings: a long-term care hospital, a hospital-based inpatient rehabilitation facility, a skilled nursing facility, or a home health agency. Each setting has its own set of multifaceted rules, procedures, and costs, managed within its own silo.

The goal of the IMPACT Act is to facilitate coordinated care to improve outcomes for Medicare consumers, and offer overall quality comparisons for use in improvement. Through the use of standardized quality measures and standardized data, the IMPACT Act aims to enable interoperability and access to information for providers.

To help achieve the goals of the IMPACT Act, a national CMS technical expert panel (TEP) will provide input on development of standardized cross-setting quality measures for use in PAC settings. It also will deliver feedback on various aspects of the measures, such as the proposed methodology for how to build, calculate, and report a measure.

Many aspects of these future measures focus on communication of specific person-centered information from setting to setting. In considering these measures, the TEP will need to address barriers to coordination, including electronic health record systems that don’t communicate with each other, providers with siloed roles, and lack of direct communication between settings.

I’m pleased to have been selected as a member of this expert panel. My input will be driven by my work as a geriatrician and a quality improvement proponent. When reviewing the measures, my touchstones will be: Will this improve patient care? Will this improve efficiency across the care delivery system?

The draft measures recognize that clinical data alone is insufficient to provide optimal care. I agree. The new measures should help providers share the types of information about patients valuable to other providers during transition stages. Transferring information such as care preferences from provider to provider delivers a blueprint for taking care of a person. The challenge is how to collect and transfer all of that information in a standard fashion that is clear and concise, and delivered at the time it is needed to care for the patient.

A challenge with transferring information across providers is balancing the amount of detail required with the reality of provider time constraints for data entry. For example, a measure could be created that accepted a patient’s functional status as “Ambulates with four-wheeled walker.” However, this is missing valuable information needed for the next setting to assume care, such as, how long they have been using the walker, distance they can ambulate, and if they have fallen.

The IMPACT Act also directs CMS to evaluate and recommend to Congress a PAC payment system that establishes payment rates according to characteristics of individual Medicare consumers instead of according to the PAC setting where they were treated. CMS must recommend to Congress a model for a PAC prospective payment system reimbursement method that could result in rebased payments for some services, and introduce aligned readmission policies that would hold PAC providers and hospitals jointly responsible for the care they furnish. That pushes care out of setting silos and fosters an even greater need to come together to support the patient.

As a physician, I admit to having concerns about how to strike the right balance for reasonable and effective measures. As a proponent of quality, I know quality improvement is an ongoing process. Where we start with these new quality measures is not where we’ll end up—we keep looking to improve.

We need to take the steps toward value set forth in the IMPACT Act as a way to help create a structure for effectively and consistently communicating information at the time of patient transitions. I, for one, am glad that the act recognizes the critical role PAC providers play in the quality of life for Medicare consumers.