Home Health & Hospice Week

Conditions of Participation, CAHPS also discussed in Open Door Forum.

A Home Health Compare change initially thought to be quick has finally been scheduled, about a year after its first proposal.

Reminder: Back in January 2017, the Centers for Medicare & Medicaid Services explained in a special Open Door Forum that it was considering axing the flu vaccination component of the patient quality of care star rating calculation for home health agencies, and adding an Emergency Department use factor (see Eli's HCW, Vol. XXVI, No. 6). At the time, CMS said it planned to move quickly on the change and HHAs could see the revision take effect as soon as in their April 2017 preview reports. But in its March 2017 Home Health Open Door Forum, CMS pulled back on that schedule, saying the agency was still reviewing the comments HHAs sent in.

CMS announced in October it was going to move ahead with the flu measure removal, and held a forum on the topic in December. The change will take effect with the April Home Health Compare refresh, a CMS official said in the agency's Jan. 17 Home Health Open Door Forum.

CMS will distribute Home Health Compare preview reports reflecting this change by early February. The reports will cover data from July 1, 2016, to June 30, 2017, the CMS source said in the forum.

Still important: The flu measure won't disappear altogether, however. It still will be reported as an individual measure on Home Health Compare going forward. And the measure "will be monitored to determine whether removal from the star rating calculation impacts vaccination rates," the CMS official indicated.

As for the claims-based ED measure, the "majority" of comments CMS received on the change opposed adding the new component to the star rating calculation, CMS said in the December forum. Thus in October, CMS pulled back that proposal.

Why? HHAs were concerned "that although the measure did provide important information, that there were attribution issues ... because patients, for example, could voluntarily go to the emergency room, or families could take them irrespective of the medical issues that were involved," noted Alan Leavitt, Medical Officer for the Division of Chronic and Post-Acute Care at CMS, in the December forum. "Physicians may just tell a patient to go without consulting the agency."

Shelving the ED measure proposal is a good example of how CMS "really work(s) with you in terms of trying to develop star ratings that are best terms of the performance for the agencies," Leavitt added. "We really do take your public comments seriously in terms of how to move forward."

Resources: See more about the star rating changes, as well as links to the December forum and related materials, at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIHomeHealthStarRatings.html.

Other home health agency issues addressed in the forum include:

• CoPs. You'd better make sure you're putting 100 percent effort into your compliance with the new Home Health Conditions of Participation now, because the wait for the final Interpretive Guidelines may go on for a while.

In the forum, a CMS official said in response to a question that the IGs for the CoPs are in the final clearance process, but there is no release date set for them. The new CoPs took effect Jan. 13, without the IGs being released.

Agencies that called into the forum looking for clarification on the CoPs were largely disappointed, since no staff in charge of the IGs were present. Listeners did get some illuminating information on the requirements for furnishing records to patients free of charge, however (see box, p. 35).

• CAHPS. Check out new CAHPS data posted for the Jan. 24 Home Health Compare refresh, a CMS official noted. The following information is also available on the HHCAHPS website, CMS notes in a Jan. 24 notice: HHA-level data, state and national averages, star ratings cut points, and patient mix adjustment coefficients for the linearized data used to construct the star ratings.

Resource: To view the new information, go to https://homehealthcahps.org, then click on the "Archived Publicly Reported Data" link under the "General Information" pull down menu.