It all begins with the IMPACT Act of 2014…
The IMPACT Act requires the development of standardized patient assessment data that will enable:
- Quality care and improved outcomes
- Data Element uniformity
- Comparison of quality and data across PAC settings
- Improved discharge planning
- Exchangeability of data
- Coordinated care
And, this standardized data will be used to inform payment models.
The IMPACT Act mandates the collection and reporting of standardized data in the following PAC settings: SNF, HH, IRF, and LTCH.
One of the data category requirements in the IMPACT Act is Functional Status, and CMS has chosen Section GG as the standardized data set for all PAC settings. Section GG has been incorporated into the MDS, the IRF PAI, and LTCH CARE data set (LCDS) and, beginning 1/1/2019, the OASIS. The specific items and scoring are the same in every setting.
Payment models are shifting away from their own unique ways of measuring function (i.e., Section G for SNF, the FIM for IRF) and beginning to not only collect this uniform data but also to incorporate it into payment systems. In the SNF, PDPM uses Section GG as the basis of the functional score for PT/OT and nursing. The FY2019 IRF PPS Final Rule clarified that the FIM would no longer be used in the IRF setting and that data from Section GG would be used to calculate the case mix groups beginning in FY 2020. CMS will no doubt move away from functional info in Section M of the OASIS to Section GG once there has been sufficient Section GG data collected from providers.
The entire PAC industry is moving toward a Unified Post-Acute Care PPS – no doubt standardized information related to function as captured in Section GG will play a significant part in that system.
In addition to these new payment models using Section GG, the information/data recorded in Section GG on the various PAC assessment tools is also used to inform Function-related Quality Measures. In the SNF Quality Reporting Program (QRP), four new measures were implemented 10/1/2018 – change in mobility score, change in self-care score, discharge mobility score, and discharge self-care score. These measures are true “outcome” measures as they compare actual functional change and status at discharge to “expected” change. SNF providers are not yet paid based on their outcome (they are only required to submit the data at this point), but providers can be sure they will be in the not too distant future.
For therapy providers in every PAC venue, using Section GG as the “standard” outcomes measure for PT and OT ensures that all providers are speaking the same language. It allows for data comparison between facilities, regions, etc. Measurement scales, definitions and descriptions of the activities, and the instructions on how to score items are the same. Data is collected at admission and discharge and improvement (or lack thereof) will mean the same thing to everyone.