Exploring the IMPACT Act

On September 18, 2014, Congress passed the Improving Medicare Post-Acute Care Transformation Act of 2014, better known as the IMPACT Act.  By October 6, 2014 this act was signed into law.  It is an unusual piece of legislation in that it took only 40 days from its introduction until it became a public law.  This act not only requires the submission of standardized data by Home Health Agencies (HHAs), but also by Long-Term Care Hospitals (LTCHs), Skilled Nursing Facilities (SNFs), and Inpatient Rehabilitation Facilities (IRFs).  The IMPACT Act requires providers in all four post- acute settings to collect and report three types of data – patient assessment data, quality measures and resource use measures.

Patient Assessment Data

A major issue with the post-acute care setting is that each setting uses its own patient assessment tool and with it comes an array of quality metrics.  Furthermore, these tools are administered at different times, making it difficult to assess a patient’s condition and outcome across various settings.  With the IMPACT Act, a more standardized measurement and reporting system will be deployed.  It also supports the inter-operable exchange of assessment data across post-acute care settings and other providers to facilitate coordinated care and improved Medicare beneficiary outcomes.  One of its ultimate goals is to provide one payment system across all of these settings.

Quality Measures

The IMPACT Act requires all four post-acute settings to report on the following five sets of quality data:

  • Physical and cognitive function and changes in function
  • Skin integrity (for example the onset and worsening of pressure ulcers)
  • Medication reconciliation
  • Incidence of major falls
  • Discharge planning, particularly the timely transfer of health information regarding patient preferences, to the next care setting when a patient is discharged from an acute care setting or transferred from one post-acute setting to another, including the patient’s home.

In addition, the act allows CMS (Centers for Medicare and Medicaid Services) to require post-acute providers to report additional quality-related data that it categorizes as important.

Resource Use Measures

The IMPACT Act also requires post-acute providers to report patient resource use using three main measures:

  • Total Medicare spending per beneficiary
  • Whether the patient was discharged to the community
  • All-cause risk-adjusted preventable hospital readmission rates

The first stage of the IMPACT Act was just implemented on October 1 and the timeline below illustrates the stages moving forward:

  • October 1, 2016
  • FY 2017 Standardized resource use measure and some quality reporting begins.
  • October 1, 2017
  • FY 2018 Confidential feedback provided on previous year’s reports.
  • October 1, 2018
  • FY 2019 Standardized assessment data required. Public quality data available. Penalties take effect for those not reporting.
  • October 1, 2021
  • FY 2022 CMS and MedPAC reports on PAC prospective payment. Study on hospital assessment data.

Support for the IMPACT Act

There has been spotty industry support for the IMPACT Act.  However, the National Association for Home Care & Hospice (NAHC) has voiced its concerns about it recently.  The NAHC is apprehensive about potential duplication and/or overlap with current OASIS assessment items and the implications associated with replacing or altering these items.  OASIS is key to home health agencies’ payments, quality measures, Star Ratings and home health value based purchasing.  In addition, NAHC is concerned that more items will be added to the OASIS, which already has a lengthy data set of its own.

The IMPACT Act could affect post-acute care for the next several years.  To implement the IMPACT Act’s various provisions $130 million from the Medicare Trust Fund has been set aside.  We question the necessity of the IMPACT Act and how it will affect the overall patient experience with HHAs in particular.  With all of the additional reporting requirements put into effect recently will the IMPACT Act just burden home health agencies even further and not result in any substantial improvements?  Only time will provide the answer to this question and others regarding the IMPACT Act.

Stay tuned. . .


  • American Healthcare Association website
  • DeJong, G., (2016) Health Policy Perspectives – “Coming to Terms with the IMPACT Act of 2014’, American Journal of Occupational Therapy
Southern Web SupportExploring the IMPACT Act
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