How CMS’s Proposed IMPACT Act Impacts Healthcare Providers
By - Every patient who steps foot into a hospital – from the college quarterback with a broken collarbone to the octogenarian diagnosed with numerous comorbidities – may soon require a discharge plan, according to a new proposed rule from the Centers for Medicare & Medicaid Services (CMS).
For the first time in over a decade, CMS plans to update the Federal Conditions of Participation (CoPs) for Discharge Planning and revise the discharge planning requirements hospitals must meet to participate in Medicare and Medicaid.
The types of hospitals affected by the proposed rule include inpatient rehabilitation facilities (IRFs), critical access hospitals (CAHs), skilled nursing facilities (SNFs), and home health agencies.
CMS’s proposed rule – CMS-3317-P – will also implement discharge planning requirements under the Improving Medicare Post-Acute Care Transformation Act of 2014.
A date for this massive regulatory overhaul will likely be confirmed in coming weeks, following close of a public commentary period.
“We believe the provisions … to take into account quality measures and resource use measures to assist patients and their families during the discharge planning process will encourage patients and their families to become active participants in the planning of their transition to the PAC setting (or between PAC settings),” CMS’s proposed rule explains.
“This requirement will allow patients and their families' access to information that will help them to make informed decisions about their post-acute care, while addressing their goals of care and treatment preferences. Patients and their families that are well informed of their choices of high-quality PAC providers, including providers of community services and supports, may reduce their chances of being re-hospitalized.”
Tom Ferry, Curaspan's President and CEO (pictured above), recently chatted with RevCycleIntelligence.com to discuss what the healthcare industry needs to know about CMS’s proposed Improving Medicare Post-Acute Care Transformation Act of 2014 – aka the IMPACT Act.
RevCycleIntelligence.com: What does the Federal CoPs / the IMPACT Act mean for healthcare providers? Who will be most affected financially at the hospital level?
Tom Ferry: Like every government regulation, it's certainly aspirational to want to challenge an industry to standardize its processes and drive better outcomes. That's the intention of the IMPACT Act – trying to get more standardized information out of a post-acute community.
The challenge with these initiatives is in the absence of really supporting technology, you're putting more burden on providers to collect information, document performance, and justify they're following standardized practices.
Most case management departments are spending millions of dollars on people spending a significant portion of their time doing documentation, gathering and faxing paperwork, and running spreadsheets and reports to give to either regulatory bodies or to their CFO to justify the department’s performance.
RevCycleIntelligence.com: How will the proposed rule affect Medicare and Medicaid participation?
TF: Medicare and Medicaid is such a large portion of the patients providers treat. If people aren't able to perform and meet expectations, they're not going to be able to participate in these programs.
They'll probably lose their major revenue source and go out of business. Or there will be a relaxation of the rules if you don't have enough capacity to support the needs of that population.
You're going to see under these programs a narrowing of networks. If you're striving for just cost, you're not going to get quality. If you're striving for just quality, you're not going to get cost. How much choice can a patient have if you're really driving towards cost and quality?
RevCycleIntelligence.com: How can providers best operationalize their approach to meet regulation needs?
TF: A lot of organizations we're talking with are obviously expressing their concerns, saying, "How do I incorporate technology into my organization's workflow so I can eliminate all the unnecessary, redundant administrative tasks we've been asked to do, which will free up my highly-paid, intelligent people to take the data we deliver to them and make a good decision?"
Based on the plans and the operational approach we've put in place, how do we deliver data when they need to make the best critical decision around a particular episode or around that particular patient's care?
There’s a marriage of data that's available or tools they've used to analyze all this information they have access to. And workflow technology where they can start to insert some of this critical information at the point that someone needs it so they can follow that operational plan, deliver the information, and make the right decision at every point of a care transition or an exchange of information among a disparate group of providers within the system.
RevCycleIntelligence.com: How might overall revenue and reimbursement be affected?
TF: There’s a push to move patients from the most-costly setting to a less-costly setting. Everything from outpatient treatment to lower skilled nursing stays, lower rehab stays, more homecare treatment obviously lowers the overall cost of care for any particular episode.
If you're thinking of it strictly from a fee-for-service perspective, you're going to have a lower length of stay. That in the short term potentially lower revenues because of those shorter hospital stays.
When you think of it from a value-based perspective and potentially getting reimbursed on the total episode of care, whether it happened within an acute care setting or not, the profitability of that care will start to play into account. It’s a lot less about total revenues and a lot more about margin.
It's got to be an uncomfortable time when you go from how you've traditionally operated to a more uncertain model. If you think about directionally and aspirationally that value-based care is the right approach in driving both cost and quality, organizations have to adapt. Those that incrementally drive towards best practices will ultimately be most successful long-term.
