VNAA Submits Comments on Common Assessment Tool

On Friday, May 9, VNAA submitted comments to the Chair and Ranking members of the Senate Finance and House Ways and Means Committees on the discussion draft , Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT). IMPACT proposes to phase-in a "Common Assessment Tool" to for use across all post-acute settings including home health agencies, (HHAs), skill nursing facilities (SNF), inpatient rehabilitation facilities (IRF) and long term care hospitals (LTCH).

VNAA recommends IMPACT should:

· Integrate that the Outcome and Assessment Information Set (OASIS) and the common assessment tool with no duplication of items or effort.

· Provide for a phase-in period and funding for providers including funding for health information technology.

· Ensure safeguards are in place so that the tool is used for assessment and not patient placement.

· Require quality measures to be carefully risk-adjusted to account for settings as well as patient acuity and characteristics.

· Require socioeconomic status (SES) and other sociodemographic factors to: 1) be collected as part of the common assessment tool and 2) utilized for both quality and resource measurement.

· Direct the HHS Secretary to provide to Congress a report that a) examines incentives to provide care in higher cost setting, b) patient preference, c) risk adjustment for unique characteristics of home care setting and d) placement of a patient in the most appropriate low-cost setting.

VNAA was one of a few groups selected to provide input on this discussion draft. It is anticipate that IMPACT will be formally introduced as a bill this year. Once introduced, the Senate and House would have to approve the measure. The bill would need to be signed by the President before the Centers for Medicare and Medicaid Services (CMS) could issue regulations.

VNAA's letter can be found here.


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