Medicare Compliance & Reimbursement

Payment reform one step closer to becoming a reality.

Change is in the air for hospitals and post-acute care facilities, thanks to the new Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT), signed into law on Oct. 6, 2014. 

The law aims to develop more standardized post-acute patient assessments, improve hospital discharge planning, and create a better quality comparing system across post-acute facilities. Currently, PAC facilities and hospitals lack a consistent, systematic method of placing patients across settings, and major groups, including the American Health Care Association (AHCA) and Leading Age applaud the passage of this bill.

Grand finale: The end goal is a new and improved payment system for PAC settings — home health agencies, skilled nursing facilities, inpatient rehabilitation facilities, and long-term care hospitals.

Core Data Elements Drive Focus to Patient, not Setting

During the law’s 8-year phase-in you’ll see new, core data elements in your respective assessment tools (the IRF-PAI for IRFs, MDS for SNFs, OASIS for HHAs, and the CARE Tool for LTCHs, etc.).

The goal is to create consistencies that paint a better overall picture of the patient that can translate from setting to setting, rather than seeing the patient through the lens of a specific setting.

“We’ve needed the uniformity for some time now,” says Charles Crecelius, MD, PhD, CMD, private practice owner in St. Louis and chair of the Society for Post-Acute and Long-Term Care Medicine’s (AMDA) public policy committee. “Each prior assessment tool, such as the MDS, has its reasons, but they don’t transform from site of service to site of service well.” 

The legislation has suggested the following core data elements that should be on each setting’s assessment tool:

• Functional status, such as mobility, self-care, and history of major falls;
• Cognitive function, such as ability to express ideas and to understand, and mental status such as depression and dementia;
• Special services, treatments, and interventions, such as the need for ventilator use; dialysis, chemotherapy, central line placement, and total parenteral nutrition;
• Medical conditions and comorbidities, such as diabetes, congestive heart failure, and pressure ulcers; and
• Impairments, such as incontinence and impaired ability to hear, see, or swallow.

This information will eventually lead to the development of a prototype payment system and an assessment tool that could be used across all PAC settings. The intent is not to do away with each setting’s unique assessment tool, but to offer PAC facilities and hospitals a new tool that could aide in transfer of care or discharge planning.

A tool like this may eventually start from day one of the hospitalization, Crecelius surmises. “Right after you know the patient’s needs, you need to be thinking: ‘Where is this person’s continuum going to lie?’ And it’s been a disjointed effort,” he adds.

Experts believe that despite the birthing pains of huge changes, providers will save time in the long run. “Essentially, [the core data elements] improve the communication between tools so you’re not spending time trying to figure out what medication this person is on, what are his other diagnoses, etc.” says Alex Bardakh, MPP, PLC, director of public policy for AMDA. 

More Data for Providers = More Data for the Public

The IMPACT Act also calls for publically reporting new quality measures on PAC settings. 

Big change: The law requires that hospitals begin offering consumers this information to help them make a choice about where they are being discharged. 

“Currently, when a patient is discharged to a post-acute facility, the hospital is not allowed to steer a person one way or another,” says David Gifford, MD, MPH, senior VP of quality and regulatory affairs for the AHCA. “All they can do is provide a list, and the consumers can look up information on Nursing Home Compare or Home Health Compare on their own.” 

Furthermore, most of the current measures don’t even help the post-acute consumer make a choice. “Nursing Home Compare’s 5-star system is mostly geared toward long-stay individuals, not those coming directly from an acute hospital or coming for skilled rehab,” Crecelius says.

For example, current measures “don’t tell you how many people are discharged to go home — which is the goal of many people coming from the hospital to post-acute care,” Gifford says.

Don’t miss: Patients being discharged from one PAC facility to another can also use this public data to choose the best setting — and the facility is required to supply the data, Gifford adds.

Odds in your favor: Although more quality measures and public scrutiny may sound daunting, count it as an opportunity to discover your weaknesses and improve. “Historically when CMS puts measures on their public site, the providers focus on it,” Gifford says. “By implementing these important measures, we will focus more on issues that are important to consumers, and I think we’ll see improvement.”

For a summary of the IMPACT Act, see www.finance.senate.gov/imo/media/doc/IMPACT Summary.pdf.