Home Health Approaching IMPACT Act Reporting Requirements

Home health agencies will soon start preparing for their quality reporting responsibilities under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act. For more than 12,000 home health agencies, the first quality reporting measures begin January 1, 2017.

The main goal of the Act is to collect standardized data that is individualized by four post-acute care settings: long-term care hospitals, inpatient rehabilitation facilities, nursing homes and home health agencies. The legislation was passed with strong bipartisan support in 2014.

“It’s a movement away from a fragmented system of communication to an integrated system through standardized information,” Stella Mandl, RN, deputy director for CMS’s Division of Chronic and Post-Acute Care, said during a public national provider call on the legislation.

Beginning next year, home health agencies will be required to collect and report specific assessment data, including patient assessment data. The Act also requires that the assessment data is interoperable to support the ability to measure and compare.

A patient assessment instrument collects information about an individual through a series of questions, and providers gather specific information about patients, including their condition, health goals, preferences and activities of daily living, among other measures relevant to their health status. The assessment information presents a provider with data for care planning and clinical decision support for quality improvement purposes. CMS can use this data for quality compare purposes, improvement initiatives, reimbursement and survey requirements.

“The goal is to take a ‘sweet spot’ of uniformity and spread it across care settings where standardized data could be useful for informing long-term care services and when the individual transfers,” Mandl said.

The standardized data takes aim at eight specific domains:

  • Skin integrity and changes in skin integrity;
  • Functional status, cognitive function, and changes in function and cognitive function;
  • Medication reconciliation;
  • Incidence of major falls;
  • Transfer of health information and care preferences when an individual transitions;
  • Resource use measures, including total estimated Medicare spending per beneficiary;
  • Discharge to community; and
  • All-condition risk-adjusted potentially preventable hospital readmissions rates.

While the home health industry still has time to prepare for new quality reporting responsibilities in 2017 for these domains, industry groups have expressed their concerns about the upcoming implementation. Last month, the National Association for Home Care & Hospice (NAHC) and other provider groups sent letters to U.C. Congressional members expressing their concerns for the legislation’s implementation. The groups were mostly concerned about the timing of its implementation, stating that some aspects, particularly the spending per beneficiary measure, were “currently scheduled to be applied far earlier than is prudent.”

The groups also noted that a compressed timeframe for public comments didn’t allow for adequate review and advocated for a longer comment period.

“There is insufficient measure specification information available to permit a thoughtful review of the proposed measure, and little or no opportunity for CMS and its contracted measure developers to adequately review the submitted stakeholder feedback prior to the submission to the National Quality Forum (QF) for review,” the groups said. “This opaque process raises questions regarding the consideration given to providers and lack adequate opportunity for public input, likely leading to the development of flawed quality and resource use measures.”

The standardization of data and interoperability the IMPACT Act aims to achieve is a building block for other quality improvement efforts. The ultimate goal is to facilitate care coordination and the seamless hand-off from care settings as patients move along the care continuum. As the legislation continues to be implemented across these care settings, the process will take tremendous coordination and collaboration across the CMS components.

Written by Amy Baxter