Dig Deeper into the IMPACT Act: Is Your PAC Facility Prepared?

CMS Discharge Planning Standards

Hospitals may aim for a smooth and coordinate patient discharge process, but they’re not reaching that goal often enough according to Medicare. This year, under the Hospital Readmissions Reduction Program (HRRP), Medicare is penalizing around more than 2,500 hospitals for readmissions considered unnecessary, according to analysts at Advisory Board. Although this number is down from 2017, the amount of payment withheld has increased – from $528 million to $564 million.

This is part of a larger trend, according to regulatory compliance expert Sue Dill Calloway. In a live webinar with ProfEdOnDemand, she addresses the increased federal focus on hospital discharge planning. She outlines the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 as well as the Centers for Medicare and Medicaid Services (CMS) proposed changes to the discharge planning standards. In order to continue to receive Medicare payments, hospitals must implement both—or face penalties.

From 4 Ways to Ask a Question to Just One

The IMPACT Act, signed into law by President Obama in October 2014, has a few main goals regarding improving patient quality of care and efficiency of hospital services. These goals include:

  • Requiring providers to submit standardized patient assessment data
  • Making assessment data interoperable, e.g. used and shared easily across PAC settings
  • Increasing transparency in data reporting
  • Improving care transitions and coordinated care
  • Focusing on patient-centered and goals-driven care and discharge planning.


Prior to the passage of the IMPACT Act, a key issue was the lack of comparable information across different post-acute care (PAC) settings where discharged patients frequently end up. These PAC facilities are:

  • Skilled Nursing Facilities (SNF)
  • Home Health Agencies (HHA)
  • Inpatient Rehabilitation Facilities (IRF), and
  • Long Term Care Hospitals (LTCH).


Not only has each PAC setting historically had a different payment system, but each also has possessed a separate assessment tool. Each tool often asks patients the same question but in a different way, making data collection and analysis difficult and confusing.

“In essence, the [IMPACT] Act seeks to standardize data elements used through various patient and resident assessment instruments by aligning certain data elements across instruments, to support our ability to measure and compare quality across the providers and settings of care,” stated Patrick Conway, MD, currently Director of the Center for Medicare and Medicaid Innovation (CMMI) at CMS, in a 2016 YouTube video by The Medicare Learning Network (MLN). With the streamlined information sharing mandated by the IMPACT ACT, Medicare will now be able to compare quality across PAC settings while also improving discharge planning and creating higher quality care for patients and their caregivers.

Timelines to Hold You Accountable

Dovetailing with the IMPACT Act’s emphasis on improving discharge processes, CMS’s Discharge Planning Proposed Rule mandates a stricter discharge timeline. According to this timeline, hospitals must:

  • Develop a discharge plan within 24 hours of administration or registration (for patients staying less than 24 hours, hospitals are to create a plan as quickly as possible so as not to delay discharge or transfer). This plan must be made in accordance with the patient’s goals and wishes.
  • Provide discharge instructions to patients at time of discharge, in addition to medication information—including all potential side effects, as well as material on warning signs and symptoms that indicate a patient needs immediate care
  • Ensure the patient’s primary care physician receives the discharge summary and all other relevant information within 48 hours of discharge. Additionally, all tests must be made available to the primary physician within 24 hours.


These changes will mean more work for hospitals, at least initially, but the underlying goal is to avoid preventable patient readmission. How? By ensuring that the patient is an active participant in their care post-discharge—and that both patient and caregiver(s) properly understand what to expect next and what PAC options (at what cost) are available.

New Data Elements Focus on Patient Preferences

To promote patient-focused case, the IMPACT Act requires that PACs use 5 quality measure domains when creating standardized assessments for discharge, according to CMS. These domains include:

  • Functional status, cognitive function, and changes in function
  • Skin integrity and any changes in skin integrity
  • Medication reconciliation
  • Incidence of major falls
  • Communicating and providing for the transfer of health information and care preferences of the patient


Based on the quality measures listed above, the IMPACT Act requires that PACs now include the following 5 data elements on all their discharge forms:

  • Cognitive status
  • Mental status
  • Medical conditions
  • Impairments
  • Other clinical topics (such as a patient’s care preferences)

Is Your Facility Compliant?

A patient’s individual goals and preferences are now required to be documented not only in their medical record, but in the discharge plan and forms as well. Your facility has the responsibility of ensuring continued compliance. In order to avoid any Medicare penalties, you should be sure you have identified all compliance gaps, implemented process changes, established written guidance and educated your staff.

Ideal for discharge planning staff, transitional nurses, chief medical officers and physicians, Calloway’s presentation will help you ensure full compliance with the IMPACT Act and CMS’s discharge planning standards by getting you up to speed quickly and answering any questions you may have on how these two issues will affect your facility.

To join the conference or see a replay, order a DVD or transcript, or read more

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