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IMPACT Act of 2014 Data Standardization & Cross Setting Measures

Quality Initiatives: Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act)

The IMPACT Act: Background

On October 6, 2014, the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act) was signed into law. The Act requires the submission of standardized data by Long-Term Care Hospitals (LTCHs), Skilled Nursing Facilities (SNFs), Home Health Agencies (HHAs) and Inpatient Rehabilitation Facilities (IRFs). Standardized data are to be collected by the commonly used assessment instruments: The Long-Term Care Hospital CARE Data Set (LCDS) for LTCHs, the Minimum Data Set (MDS) for SNFs, the Outcome and Assessment Information Set (OASIS) for HHAs, and the Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF PAI) for IRFs.

The IMPACT Act requires the reporting of standardized patient assessment data with regard to quality measures and standardized patient assessment data elements (SPADEs). The Act also requires the submission of data pertaining to measure domains pertaining to resource use, and other domains. In addition, the IMPACT Act requires assessment data to be standardized and interoperable to allow for exchange of the data among post-acute providers and other providers. The Act  intends for standardized post-acute care data to improve Medicare beneficiary outcomes through shared-decision making, care coordination, and enhanced discharge planning.

Work to meet the intent of the IMPACT Act supports the CMS initiative “Meaningful Measures”. This new initiative identifies the high priorities for quality measurement and improvement. It demonstrates how improved outcomes for beneficiaries are being achieved through focusing on quality measures and core issues that are the most critical to providing high-quality care.

The Meaningful Measure priority areas are:

  • Promote effective communication and coordination of care
  • Promote effective prevention and treatment of chronic disease
  • Work with communities to promote best practices of healthy living
  • Make care affordable
  • Make care safer by reducing harm, cost in the delivery of care
  • Strengthen person and family engagement as partners in their care

For more information on Meaningful Measures, please refer to the CMS Meaningful Measures website.

The IMPACT Act Charge

The IMPACT Act requires the Secretary to implement specified clinical assessment domains and categories using standardized data required for submission by LTCH, IRF, SNF, and HHA providers. Standardized quality measures are to be developed and implemented from five quality measure domains. The Act also requires the development and reporting of measures pertaining to resource use, hospitalization, and discharge to the community.  Additionally, CMS is to develop, implement, and maintain standardized patient assessment data elements (SPADEs) for clinical categories. These domains and categories are listed below.

Quality Measure 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 and Other Measure Domains:

  • Resource use measures, including total estimated Medicare spending per beneficiary;
  • Discharge to community; and
  • All-condition risk-adjusted potentially preventable hospital readmissions rates. 

Assessment Categories:

  • Functional status
  • Cognitive function and mental status
  • Special services, treatments, and interventions
  • Medical conditions and co-morbidities
  • Impairments
  • Other categories required by the Secretary

IMPACT Act Measures:

IMPACT Act Domain IMPACT Act Measure PAC Setting Adopted
Skin Integrity and Changes in Skin Integrity Percent of Residents or Patients with Pressure Ulcers that are New or Worsened (Short Stay) replaced with Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury IRF, LTCH, SNF, HH
Functional Status, Cognitive Function, and Changes in Function and Cognitive Function
  • Application of Percent of LTCH Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function
  • Percent of LTCH Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function
  • Change in Self-Care Score for Medical Rehabilitation Patients
  • Change in Mobility Score for Medical Rehabilitation Patients
  • Change in Discharge Self-Care Score for Medical Rehabilitation Patients
  • Change in Discharge Mobility Score for Medical Rehabilitation Patients
  • IRF, LTCH, SNF, HH
  • LTCH
  • IRF, SNF
  • IRF, SNF
  • IRF, SNF
  • IRF, SNF
Medication Reconciliation Drug Regimen Review IRF, LTCH, SNF, HH
Incidence of Major Falls Application of the Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay) IRF, LTCH, SNF, HH
Transfer of Health Information and Care Preferences when an Individual Transitions Under Development IRF, LTCH, SNF, HH
Resource Use Measures, including Total Estimated Medicare Spending Per Beneficiary Medicare Spending Per Beneficiary IRF, LTCH, SNF, HH
Discharge to Community Discharge to Community IRF, LTCH, SNF, HH
All-Condition Risk-Adjusted Potentially Preventable Hospital Readmissions Rates Potentially Preventable 30-Day Post-Discharge Readmission IRF, LTCH, SNF, HH

IMPACT Act: Service Providers/Settings 

The IMPACT Act mandates the collection and reporting of standardized data in the following post-acute care settings: Long-Term Care Hospitals (LTCHs), Skilled Nursing Facilities (SNFs), Home Health Agencies (HHAs) and Inpatient Rehabilitation Facilities (IRFs).

Specific information about each setting and reporting tools can be found at:

Long Term Care Hospitals (LTCHs)

Skilled Nursing Facilities (SNFs)

Inpatient Rehabilitation Facilities (IRFs)

Home Health Agencies (HHAs)

The Data Element Library (DEL)

The CMS Data Element Library (DEL) is the centralized resource for CMS assessment instrument data elements (e.g. questions and responses) and their associated health information technology (IT) standards. The goals of the DEL are to:

  • Serve as a centralized resource for CMS assessment data elements (questions and response options);
  • Promote the sharing of electronic CMS assessment data sets and health information technology standards; and
  • Influence and support industry efforts to promote Electronic Health Record (EHR) and other health IT interoperability.
  • For more information on the DEL, please see: https://del.cms.gov/DELWeb/pubHome  

Please submit questions and comments to: PACQualityInitiative@cms.hhs.gov 

The IMPACT Act of 2014 can be found at: 

You can find additional information about the IMPACT Act by visiting the Post Acute Care Quality Initiatives web page at: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Post-Acute-Care-Quality-Initiatives/PAC-Quality-Initiatives.html

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