The Improving Medicare Post-Acute Care Transformation Act, more commonly known as the IMPACT Act, was passed by Congress on September 18, 2014. It requires the reporting of standardized patient-assessment data from post-acute care providers including Long-Term Care Hospitals (LTCH), Skilled Nursing Facilities (SNF), Home Health Agencies (HHA) and Inpatient Rehabilitation Facilities (IRF).
The IMPACT Act identifies five Quality Measure domains, three of which will affect the provider’s payment beginning in 2018 : skin integrity, cognitive function and functional status, and occurrence of major falls. Beginning in October 2016, skilled nursing facilities, inpatient rehabilitation centers, and long-term care hospitals will start submitting this data. Data collection will begin in January 2017 for home health agencies. Starting in October 2018 for IRFs, LTCHs, and SNFS, and in January 2019 for HHAs, the results from this data will be used to determine payment. Beginning in 2019, post-acute providers that fail to collect and report data will have their market basket percentage updates reduced by two percentage points.
Why was the IMPACT Act legislated?
The IMPACT Act was legislated to address:
Noted substantial variations in quality and costs among post-acute providers
Lack of standardization of quality and cost metrics across the different post-acute providers
The IMPACT Act will:
Help ensure the patient is placed in the most appropriate post-acute care setting
Improve hospital and post-acute care discharge planning
Reform post-acute care payments and reimbursement
Promote interoperability across disparate technology platforms
What does the IMPACT Act say about skin integrity?
Regardless of setting or provider type, pressure injuries (ulcers) are recognized as a serious medical condition with many pressure ulcers identified as preventable. There is considerable evidence that associates pressure ulcers with pain, decreased quality of life, longer post-acute care stays, increased costs and increased mortality. Developed by the National Quality Forum (NQF), the skin integrity measure reports the percent of patients/short-stay residents with Stage 2-4 pressure ulcers that are new or worsened since admission.
For SNFs: The measure is restricted to the short-stay (100 or fewer days) patients and is calculated by examining all assessments during this time frame for reports of Stage 2-4 pressure ulcers that were not present or were at a lesser stage upon admission.
For LTCHs: This measure reports the percent of patient stays with reports of Stage 2-4 pressure ulcers that were not present or were at a lesser stage on admission for all patients in LTCHs.
For IRFs: This measure reports the percent of patient stays with reports of Stage 2-4 pressure ulcers that were not present or were at a lesser stage on admission for all Medicare Part A and Part C IRF patients.
For HHAs: This measure is calculated by examining all assessments during an episode of care for reports of Stage 2-4 pressure ulcers that were not present or were at a lesser stage since admission.
Post-Acute Provider Skin Integrity Measure Reporting Penalty
Timeline Timeline
Inpatient Rehabilitation % of Patients with Stage 2-4 October 1, October 1,
Facilities (IRF) Pressure Ulcers that are New 2016 2018
or Worsened (Short-Stay)
Long-Term Care % of Patients with Stage 2-4 October 1, October 1,
Hospitals (LTCH) Pressure Ulcers that are New 2016 2018
or Worsened (Short-Stay)
Skilled Nursing % of Patients with Stage 2-4 October 1, October 1,
Facilities (SNF) Pressure Ulcers that are New 2016 2018
or Worsened (Short-Stay)
Home Health % of Patients with Stage 2-4 January 1, January 1,
Agencies (HHA) Pressure Ulcers that are New 2017
or Worsened (Short-Stay) 2017 2019
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