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MedPAC Issues Final IMPACT Act Report

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The Medicare Payment Advisory Commission (MedPAC) has issued a report on a unified post-acute care payment system, as mandated by the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).  

The IMPACT Act implemented wide-ranging changes to standardize patient assessment and quality measures across the four post-acute care settings; long-term care hospitals (LTCHs), inpatient rehabilitation facilities (IRFs), skilled-nursing facilities (SNFs), and home health agencies (HHAs). It also required that hospitals incorporate patient outcome and quality data into their discharge planning process. An additional goal of the IMPACT Act was to model and evaluate the potential for a unified post-acute care prospective payment system (PAC PPS).    

In the final report, which is available in Chapter 10, MedPAC provides a description of a prototype PAC PPS model and related considerations. MedPAC concludes that designing a PAC PPS is feasible and could establish accurate payments, though modifications would be necessary to make it more consistent with the intent of a unified payment system. The commission also notes that CMS would be challenged to implement companion policies to address current structural benefit and payment rules and setting-specific regulations, a process that could take several years. Moreover, recent changes to PPS for HHAs, SNFs and LTCHs have, in MedPAC’s view, reduced the impetus for the development of a unified payment system. MedPAC recommends that the Centers for Medicare & Medicaid Services consider smaller-scale site-neutral policies and implement standing recommendations to reduce payment rates for HHAs, SNFs, and IRFs.