Congressional approval of H.R. 4994, the IMPACT Act in October 2014, mandates the development and implementation of a standardized post-acute care assessment tool, and paves the way for effective payment reforms.

The IMPACT Act: What’s Ahead

Preventable Readmission Measures

CMS has contracted with RTI International and Abt Associates to develop potentially preventable readmission measures, in alignment with the IMPACT Act and the Protecting Access to Medicare Act of 2014 (known as PAMA).

The purpose of this project is to develop, maintain, re-evaluate, and implement outcome and process quality measures that are reflective of quality care for the PAC settings, to support CMS quality missions that include the Long-Term Care Hospital (LTCH) Quality Reporting Program (QRP), the Inpatient Rehabilitation Facility (IRF) QRP, the Nursing Home (NH)/Skilled Nursing Facility (SNF) QRP, the Home Health (HH) QRP, and SNF Value Based Purchasing. The cross-setting readmissions measures will be applicable to all post-acute care settings.

Project Objectives:

  • To develop an approach for defining potentially preventable readmissions (PPRs) for post- acute care (SNF, IRF, LTCH, HHA).
  • To develop potentially preventable readmissions measures for multiple settings (SNF, IRF, LTCH, HHA), including standardized items and specifications such as inclusion/exclusion criteria, and patient and facility characteristics – factors associated with outcome measures (risk adjusters).
  • To obtain setting-specific input on PPR quality measures’ application and implementation.

Medication Reconciliation Measure

CMS has contracted with Abt Associates and RTI International to develop a cross-setting PAC measure for the quality measure domain – medication reconciliation. In this measure, medication reconciliation and drug regimen review are defined as:

Medication Reconciliation – the process of comparing the medications a patient is taking (and should be taking) with newly ordered medications in order to identify and resolve discrepancies. (Reference: The Joint Commission, National Patient Safety Goals).

Drug Regimen Review – a review of all medications the patient is currently using in order to identify any potential adverse effects and drug reactions, including ineffective drug therapy, significant side effects, significant drug interactions, duplicate drug therapy, and noncompliance with drug therapy. (Reference: Home Health Conditions of Participation §484.55c).

Project Objectives:

  • Introduce drug regimen data elements for capturing data for a drug regimen measure in the medication reconciliation domain for PAC settings.
  • Refine measure specifications.
  • Identify setting-specific needs/concerns/barriers for capturing drug regimen review/medication reconciliation information using the data elements.
  • Gather feedback on importance, feasibility, usability and potential impact of adding drug regimen review data elements for quality measurement as new items to existing PAC assessment instruments in Home Health (HH), Inpatient Rehabilitation Facilities (IRF), Long Term Care Hospital (LTCH) and Skilled Nursing Facilities (SNF) settings.
  • Identify additional guidance required for the implementation in each setting of care.

Prototype PAC Payment System

Using data from a variety of sources, the Medicare Payment Advisory Commission (MedPAC) is required to submit to Congress by June 30, 2016, a technical prototype PAC payment system. The system will be required to establish payment rates according to the characteristics of individuals (such as cognitive ability, functional status and impairments), instead of the post-acute care setting where the Medicare beneficiary involved is treated. “The Commission believes that Medicare needs to move away from fee-for-service payment and toward integrated payment approaches that put providers at risk for all healthcare spending and outcomes during a longer period of time, such as episode-based payments. Therefore, a unified PAC PPS should not be considered the end point for payment reform but a good first step.”

“The IMPACT Act in October 2014 paves the way for effective payment reforms.”

So even with improved PPS, “companion policies” are needed to dampen FFS incentives, MedPAC staff noted, which should be considered when modifying a PAC PPS, such as value-based purchasing, readmission and transfer policies, and other reforms.

Revisions to the payment proposal will be generated by CMS with input from MedPAC no later than two years after the collection of standardized patient assessment data estimated: October 2018. A new payment system is likely by 2020.