May 2, 2018
RE: Quality Measures to Satisfy the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) domain of: Transfer of Health Information and Care Preferences When an Individual Transitions – Medication Profile Transferred to Provider / Medication Profile Transferred to Patient
The American Hospital Association's comments on the Centers for Medicare & Medicaid Services’ (CMS) and its contractors’ draft specifications for the two transfer of health information measures under development. The measures are being developed to meet CMS’s statutory obligations under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act. The sharing of relevant patient information with other providers and patients/caregivers is paramount to maintaining a strong and integrated continuum of care, and the AHA appreciates that CMS is thoughtfully working to meet the statutory requirements of the IMPACT Act. This letter includes feedback on the evolution of these measures as well as questions and recommendations for the developers as they continue to refine the specifications.