Home Health & Hospice Week

Open Door Forum participants express concern about normal distribution model.

It may already be too late to affect your initial five-star rating calculation much, but you can urge CMS to present the information in a more favorable light.

Background: Last month the Centers for Medicare & Medicaid Services proposed a fivestar rating system for home health agencies based on 10 current Home Health Compare measures (see Eli’s HCW, Vol. XXIII, No. 44-45).

How the calculation works, step 1: First, CMS will cull out home health agencies that have been reporting data for fewer than six months or that do not have enough data reported to meet the minimum threshold of 20 quality episodes for at least six of the 10 star-calculating measures.

That’s a surprising number of agencies, revealed David Hittle with CMS contractor University of Colorado in a Dec. 17 Special Open Door Forum about the proposal. In analysis of 2013 data, about 23 percent of agencies would not receive a star rating because they don’t meet the data threshold.

Step 2: For agencies that do meet the minimum data threshold, for each of the 10 measures, CMS will calculate home health agencies’ scores as it normally would for Home Health Compare, explained Sara Galantowictz with CMS contractor Abt Associates in the forum.

Step 3: Then it will divide up the scores of qualifying agencies into five equal parts, or quintiles, Galantowictz said. Each quintile will receive the corresponding star number (one star for the lowest quintile, two stars for the second-lowest quintile, etc.).

Step 4: For each measure score, CMS then will determine whether the difference between your score and the national average is statistically significant. If it is, your star score for that measure will stay the same. If not, CMS will adjust your star score by moving it up one star if the score is a 1 or 2, and down one star if the score is a 4 or 5. Individual measure star scores of 3 will stay the same regardless of statistical significance.

Step 5: CMS will average the adjusted star rating for each measure into one overall star rating. Look at it as a summary of the 10 measures, suggested physician Alan Levitt with CMS. CMS will round up starting at 0.5.

More details about the calculations are in the forum’s slides at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/Wednesday-December-17-2014-–-Home-Health-Compare-Star-Ratings-Special-Open-Door-Forum.pdf.

No Way To Know

While the five-star rating system will be based on your current Home Health Compare data, there’s no way to know how it will translate to a star rating without knowing the five quintile figures, Hittle noted in the call. Unless CMS releases that data early, you’ll have to wait for your preview report to see your star calculation. In a related question-and-answer document, CMS says you may get your report only a few weeks before the information is published on Home Health Compare.

Timeline: CMS has mentioned that it may start publishing star scores on Home Health Com-pare as early as this summer — but don’t count on it. The process may take longer depending on the volume of stakeholder feedback, resulting work required, etc., said CMS’s Mary Pratt in the forum

Almost 60% Of HHAs Would Get 3 Stars

Multiple callers expressed concern about the five-star rating system to CMS in the forum. In its 2013 data analysis, a whopping 58 percent of agencies would have fallen into the three-star category, CMS revealed in the forum. Twenty-two percent of agencies would have scored four stars and only 2 percent of agencies would have achieved five stars. On the lower end, 17 percent of agencies would have scored two stars and 1 percent would have scored one star.

“There are relatively few agencies that are consistently achieving higher or lower results across all the measures included in the star ratings calculation,” Galantowictz observed.

The problem: Today’s consumers don’t e-quate three stars with doing a good job, multiple HHA reps feared. They would think four stars would be a minimum for quality care.

For example, consumers looking for a hotel don’t want three stars, one provider said. “I am aiming for a four or a five.”

“A rating of three stars does not represent low quality,” Galantowictz said in the forum. “Most agencies perform quite well on the measures currently reported on Home Health Compare.” The clustering in the three-star category “shows most agencies are providing on average a similar level of quality to their peers,” she said.

But consumers are unlikely to understand that, agencies worried. They urged CMS to include clarifying language that would explain that, without requiring HH Compare users to click on extra links or read obscure footnotes.

CMS will post language explaining that the star rating is only one factor to consider in choosing an agency, Pratt explained. You can look at Medicare’s Nursing Home and Physician Compare sites to see examples of the language that Home Health Compare will include, she suggested.

Comment Deadline Almost Here

Levitt urged agencies to submit this concern and other feedback to CMS via email address hhc_ star_rating_helpdesk@cms.hhs.gov for consideration. However, agencies need to give their two cents to CMS by Jan. 16.

In the forum, Mary Carr with the National Association for Home Care & Hospice urged CMS to give agencies more time to submit comments, especially in light of the holidays. But extending the initial comment deadline would mean less time for agency input at later stages, Levitt responded. There will be “an ongoing dialog,” he promised. 

Note: More information is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQISpotlight.html — scroll down to the “Downloads” section for links to the slides and FAQs.