Home Health & Hospice Week

Your quality data from the COVID era will hit screens in January.

If you’ve skipped over Medicare’s latest hospice proposed rule because you operate only home health, you’d better take a minute to circle back to the newly released regulation.

Why? The Centers for Medicare & Medicaid Services has included a provision about home health quality data reporting in the rule published in the Aug. 14 Federal Register. “We include this Home Health proposal in this rule because we plan to resume public reporting for the HH [Quality Reporting Program] with the January 2022 refresh of Care Compare,” CMS says in the rule. “In order to finalize this proposal in time … we need the rule containing this proposal to finalize by October 2021.” In contrast, CMS often releases the annual HH final rule in early November.

“We are proposing to modify our public display schedule to display fewer quarters of data than what we previously finalized for certain HH QRP measures for the January 2022 refreshes,” CMS explains. CMS decided to freeze public reporting of quality data in 2021, due to the COVID-19 public health emergency’s impact on data collected in Quarter 1 and Quarter 2 of 2020.

“Given the timing of the PHE onset, we determined that we would not use HH QRP OASIS, claims, or HHCAHPS data from Q1 and Q2 of 2020 for public reporting,” CMS relates. Then, “because October 2020 refresh data will become increasingly out-of-date and thus less useful for the public, we analyzed whether it would be possible to use fewer quarters of data for one or more refreshes and thus reduce the number of refreshes that continue to display October 2020 data.”

After running some involved analyses and data testing, CMS settled on this tactic: “We are proposing to use the [COVID-19 Affected Reporting] scenario for the last of the refreshes affecting OASIS-based measures, which will occur in January 2022. We are also proposing to use the CAR scenario for refreshes from January 2022 through July 2024 for some claims-based measures.”

The CAR scenario will use OASIS data from Q3 2020, Q4 2020, and Q1 2021. At three quarters, that’s down from the usual four quarters’ worth of data.

Claims-based data is more varied, but will exclude Q1 and Q2 of 2020 by skipping over them to the next-most-recent quarters, according to the rule. “For both claims and OASIS-based measures, the quarters used in our analysis were the most recently available data that exclude the same quarters (Q1 and Q2) as that are relevant from the PHE exception, and thus take seasonality into consideration,” CMS explains.

“Updating the data in January 2022 by more than a year relative to the October 2020 freeze data can assist the public by providing more relevant quality data and allow CMS to display more recent HHA performance,” CMS says. “Similarly, using fewer than standard numbers of quarters for claims-based measures that typically use eight or twelve months of data for reporting between January 2022 and July 2024 will allow us to begin providing more relevant data sooner,” according to the rule.

See an example of quarters used for refreshes broken down by claims-based measure in Table 33 of the proposed rule. But “actual quarters will be provided subregulatory,” CMS informs providers in the rule.

As with OASIS-based measures, CMS will use three quarters of data for CAHPS measures — Q3 2020, Q4 2020, and Q1 2021. That excludes Q1 and Q2 data and reduces the number of quarters’ data used from four to three.

Note: The rule is at www.govinfo.gov/content/pkg/FR-2021-04-14/pdf/2021-07344.pdf.