With home health agencies set to receive a “preview” of their first-ever star ratings from the government starting this week, the Centers for Medicare & Medicaid Services (CMS) is taking steps to educate providers about how to understand and appeal the forthcoming reports.
Nursing homes, physicians and other Medicare-certified providers already receive star ratings, which are based on certain quality measures and are intended to give consumers an idea of how these providers stack up against one another. Starting in July, home health agencies (HHAs) also will have their star ratings posted on the CMS Home Health Compare—and the agency now is beginning to circulate preview reports informing providers of their initial star rating.
Home health agencies will in fact receive two reports, CMS officials explained during a webinar last Thursday. One will be the quality measure preview report, which up until now has been delivery annually and will be delivered quarterly going forward. It will include two new measures that are being added to Home Health Compare as of July: rehospitalization during the first 30 days of home health, and emergency department use without readmission during the first 30 days.
The second report will be the star rating preview. Both will be delivered to CASPER mailboxes, as has been done with the quality measure reports in the past.
The star rating report will include a scorecard that lists the nine quality measures used, including timely initiation of care, improved breathing and received current season flu shot. Originally, CMS planned to include pneumococcal vaccination as a measure, but dropped that in response to provider feedback. HHAs also protested the flu shot measure. Their arguments included that the star rating is re-calculated quarterly, but flu shots are not administered every quarter.
Providers also have expressed concern over the measures gauging patient improvement, noting that the Jimmo vs. Sebelius ruling established that Medicare is required to reimburse providers for helping patients maintain their condition, not just to improve. Some have argued that the rating system undermines this ruling by putting so much value on improvement, specifically in breathing, bathing, walking, and getting in and out of bed.
The scorecard lists the cut-points for star ratings for each quality measure, as well as the individual HHA’s score and corresponding number of stars. For example, the scorecard might indicate that scores between 62.8 and 65.5 would earn a provider 3.5 stars for the “improved walking or moving around” measure, show that the provider’s score was 64, and therefore list the HHA’s initial decile rating as 3.5.
The cut-points will vary from quarter to quarter, CMS officials stressed, because they are based on the performance of all agencies for that time period. This is in keeping with the overall methodology of the star ratings, which are distributed on a bell-shaped curve. Therefore, a 3-star rating would indicate that the provider offers care that is about as good as most other HHAs in the country—it does not mean that the provider has met a predetermined and fixed level of quality.
The scorecard will include a variety of other information, including whether an initial star rating for a given measure has been adjusted due to statistical considerations.
Agencies will have until April 17 to request a review of the star rating they received on the preview report, CMS officials stated. Review requests are to be submitted via email, to HHC_Star_Ratings_Review_Request@cms.hhs.gov.
To appeal, providers must be able to furnish evidence showing that missing or inaccurate data affected their quality measure scores, and that the volume of missing data was substantial enough to affect the final, overall star rating.
CMS detailed several specific items that need to be included in a request for review, including the contact information for a point person at the HHA, measure(s) affected by the inaccurate or missing data, and a plan and timeline for submitted corrected information. No identifiable patient information should be transmitted via email
CMS officials in the past have said they do not anticipate particular issues that would spur review requests but are putting a system in place to cover the contingency.
If a review determines that corrections do have to be made, an agency’s star rating could be suppressed for one quarter, according to CMS.
Written by Tim Mullaney