CMS held a Special Open Door Forum on December 17 to solicit stakeholder feedback on the proposed five star rating system for home health agencies scheduled to start in 2015. CMS announced the quality measures it will use along with the proposed methodology for obtaining the five star rating. Comments regarding the five star rating system were due on January 16. NAHC submitted comments which addressed three main areas of concern with the CMS proposed star rating system, including the selected measures, the calculation methodology, and the next steps.
NAHC is especially concerned with CMS’ decision to include five measures that show improvement in functional status or clinical condition. For many patients admitted to home health care, the expected outcome is to stabilize or prevent decline of a condition or functional limitation. The recent settlement in the Jimmo v. Sebelius case further confirms that the improvement standard does not apply to all Medicare home health patients. Additionally, an agency’s ability to affect a patient’s improvement in any measure depends on the services provided and the length of time the patient spends on service with the agency. The quality measures in home health agencies include data from four unique payment sources. However, each patient population and the applicable payers have varying utilization patterns.
NAHC recommends CMS include outcome measures reflecting care to patients who cannot and will not improve in any ADL or IADL function and add measures from the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) survey. NAHC also expresses concerns with the star rating model and believes it is misleading and could have significant consequences for patients and home health agencies.
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