Home Health & Hospice Week

IMPACT Act bones for MedPAC-endorsed PAC PPS in the works.

You have until June 26 to give CMS your two cents on new IMPACT Act data elements that will be used for cross-setting quality measures — and perhaps, eventually, a post-acute care payment system.

“The Centers for Medicare & Medicaid Services (CMS) seeks comments from stakeholders on data elements that meet the IMPACT Act domains of: cognitive function and mental status; medical conditions and co-morbidities; impairments; medication reconciliation; and care preferences,” CMS says on its website.

CMS and its contractor, Rand Corp., are “specifically interested” in the data elements’ potential

payment applications — “utility for describing case mix, which includes whether the data element could be used with different payment models, and whether it measures differences in patient severity levels related to resource needs,” CMS says. It also is interested in the elements’ “feasibility for use in PAC, which includes consideration of the data element’s potential to be standardized and made interoperable across settings; clinical appropriateness; and relevance to the work flow across settings;” and potential for improving quality and validity.

Last month, the Medicare Payment Advisory Commission agreed to recommend to Congress

in its June report that lawmakers implement a PAC payment system as quickly as possible. But the advisory body’s recommendations have numerous problems, says the National Association for Home Care & Hospice.

Among the many flaws in a PAC PPS are that home care has different, varying costs compared

to institutional care, such as travel time and caregiver support, NAHC argues. Also, a PAC PPS is likely to underfund therapy patients, and may not apply to patients without preceding inpatient stays, the trade group points out in its member newsletter.

Note: See more information and instructions on submitting comments on the IMPACT Act data elements at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/MMS/CallforPublicComment.html#RAND IMPAC. See MedPAC’s PAC payment system discussion points at http://medpac.gov/docs/default-source/default-document-library/pac-pps-april-2017-public.pdf.