CMS Proposes to Incorporate Social Risk Factors in Home Health Quality Reporting Program
August 15, 2017 03:38 PM
Please note: This is the first article in a series on the CMS Proposals for the HHQRP
The Centers for Medicare & Medicaid Services (CMS) published in the Federal Register on July 28, 2017 The Calendar Year (CY) 2018 Home Health Prospective Payment System Rate Update proposed rule.
A significant portion of the proposed rule is dedicated to proposals that update the Home Health Quality Reporting Program (HH QRP).The changes are many with the majority focused on cross setting quality measures and standardized assessment items that CMS is required to develop in accord with the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). (see NAHC Report article)
CMS begins the HH QRP section with a request for comments on their proposal to incorporate socio-economic and socio-demographic status as a risk adjuster for quality measures. Risk factors would includeincome, education, race and ethnicity, employment, disability, community resources, and social support.
The National Quality Forum has undertaken a 2-year trial period in which measures from the for Re-hospitalization During the First 30 Days of Home Health and Emergency Department Use without Hospital Readmission During the First 30 Days of Home Health are being risk adjusted for social risk factors. At the conclusion of the trial, NQF will issue recommendations on the future inclusion of social risk factors in risk adjustment for quality measures.
CMS continues to express its concern related to health disparities if providers are held to a different standard for outcomes if quality measures are risk adjusted for social risk factors.
CMS is requesting public comment on whether we should account for social risk factors in measures in the HH QRP, and if so, what method or combination of methods would be most appropriate for accounting for social risk factors. Examples of methods include :confidential reporting to providers of measure rates stratified by social risk factors, public reporting of stratified measure rates, and potential risk adjustment of a particular measure as appropriate based on data and evidence.
In addition, CMS is seeking public comment on which social risk factors might be most appropriate for reporting stratified measure scores and potential risk adjustment of a particular measure. Examples of social risk factors include, but are not limited to, dual eligibility/low-income subsidy, race and ethnicity, and geographic area of residence.
Comments are due September 25, 2017