Medicare Compliance & Reimbursement

IMPACT Act introduces new quality measures.

All eyes will be on your staffing turnover rates when the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 rolls out. In addition to standardizing patient assessments, this new legislation, signed into law on Oct. 6, 2014, aims to create a better quality comparing system across post-acute facilities. 

Affected settings include long term care hospitals (LTCHs), home health agencies (HHAs), inpatient rehab facilities (IRFs), and skilled nursing facilities (SNFs), and policymakers want to see your staffing stats as part of your facility’s profile when the new quality comparing methods hit the scene.

“We have long recognized that staffing in many ways is a key measure for quality,” Cheryl Phillips, MD, senior VP of public policy and advocacy for LeadingAge tells Eli. For example, “there is an abundance of literature that points out that non-profits typically have higher staffing ratios and also tend to have higher quality measures.”

Nursing Home Compare currently uses its 5-star scale with staffing turnover as a measure, but the data collection methodology is somewhat flawed.

“One issue with the 5 star that we have been frustrated with is that the staffing element is not only more heavily weighted when calculating the 5-star score, but it has been one of the easier ones to manipulate,” Phillips says. “Not only are staffing levels often self-reported, but nursing homes can ‘boost’ their staffing levels prior to the anticipated survey, only to go back to lower levels as soon as the survey is over.”

New way: The IMPACT Act requires payroll-based reporting which will up the ante in transparency and accuracy.

The challenge: “Many smaller nursing homes do not have automated payroll systems,” Phillips notes, so this reporting “will certainly require some investment in technology or software to accomplish whatever CMS rolls out.”

Unfortunately, nursing homes are known for being one of the slowest health care settings to transition to electronic health records and more tech-savvy bookkeeping. 

The investment, however, has its perks. In addition to helping you track staffing turnover more effectively, “it also allows homes to focus on ‘consistent assignment’ strategies whereby the nursing home works to minimize the number of different people who provide care to the resident,” Phillips says. “This is not only linked to better clinical outcomes and improved patient satisfaction but improved staff satisfaction as well. It is hard to implement and track, and having an automated tool to track staff will be a key boost.”

Hang tight: The IMPACT law leaves many details up to the Secretary of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services’ (CMS’) rulemaking process, so much is left to be seen. 

For example, “It is unclear in the IMPACT language what staffing levels will need to be tracked. Is this nursing? Direct care workers? Other staff, such as dietary and housekeeping? And how will outside agency staff be counted?” Phillips says. “Before this element of the IMPACT Act can be rolled out, CMS will need to define these, as well as define the rules for measuring staffing levels.”