CMS Holds Second Open Door Forum on Proposed Home Health Star Rating System
February 10, 2015 10:26 AM
The Centers for Medicare & Medicaid Services (CMS) held its second Open Door Forum (ODF) call for the proposed five star rating system for home health agencies. The presenters reviewed the star rating system, the comments received from the previous an ODF call, the revised methodology for calculation, and the next steps in developing the star rating system.
CMS reviewed their initial plans to implement a five-star rating system for home health agencies (HHAs), similar to the system used for skilled nursing facilities. The plan was officially announced on an ODF call held back in December. During that call, CMS presented ten selected measures and a preliminary methodology to be used for the five-star rating system.
Many of the comments CMS received from the initial ODF call were related to the selected measures, the methodology for calculating the star rating, and concerns regarding consumer interpretation of the rating system. Several comments addressed the robustness of risk adjustment and the request for CMS to issue changes through the rule making process.
The ten measures originally selected will be used. CMS rejected several requests for the inclusion of stabilization measures and measures from the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS). According to CMS, the stabilization measures do not meet the criteria for selection. None of these measures are reported on Home Health Compare nor do any have NQF endorsement. Additionally, the scores for these measures do not have enough variation.
CMS revealed plans to apply a separate star rating for the HHCAHPS measures and eventually incorporate these scores into the outcome measure rating system. However, CMS did not have any concrete plans for this initiative.
During the most recent ODF call, CMS also presented a revised methodology for the rating system. Rather than place agencies in quintiles with ratings from 1-5 stars, agencies would be sectioned into deciles and be rated in half star increments between 1 and 5 stars.
By distributing agencies among deciles the ratings distribution are “flattened”, allowing for less clustering around 3 stars. However, CMS plans to apply the same approach with the calculation as in the previous method. The score for each measure will be adjusted towards a rating of 3 if the score for that measure is not significantly different from the median across all agencies.
CMS plans to begin publishing the star ratings on Home Health Compare (HHC) in mid-July 2015. The ratings will be based on Outcome and Information Assessment Set (OASIS) data from January through December 2014 and claims data from October 2013 through September 2014. These are the same data that will be published on HHC in April 2015 under the usual schedule. The star ratings will be updated quarterly.
Agencies will be able to review their reports in March and will have several weeks to review and provide feedback on any data errors identified that affect the final star rating.
CMS is accepting another round of comments that are due Friday, February 13, 2015. CMS will also be drafting and testing consumer language, and plans to continue to solicit additional input on the rating system through informal stakeholder group.
The National Association for Care & Hospice (NAHC) has the same concerns with this proposal as it did with CMS’ initial proposal. NAHC has a general concern with using a star rating system framework to communicate to consumers the difference in quality of care among HHAs.
NAHC also maintains that measures other than those selected should be used. Additionally, the revised methodology continues to divide agencies in sections - now ten rather than five - even when performance variation between providers may be slight. This is compounded by ranking agencies on a “curve” that moves agencies towards a 3 star rating. Lastly, CMS will not likely be able to develop language that will effectively communicate to consumers how this star rating system differs from other consumer star rating systems.
The approach CMS has taken to inform stakeholders of their intent to apply a star rating system for HHAs is also of concern. NAHC has requested that CMS use the formal rulemaking process for public notice and comment to communicate this initiative to stakeholders.
A separate web page has been set up for the home health five sat rating system on the Home Health Quality Initiative page. On this page, agencies will find the handouts for the ODF call and the revised methodology for the rating system along with other information on the star rating system.