On December 11, 2014, CMS issued a fact sheet detailing its proposal for assigning an overall star rating for each home health agency (HHA) on the Home Health Compare website starting in 2015. An HHA’s star rating would be based on its performance on a subset of ten quality measures (out of 27 measures currently posted on Home Health Compare), including four process of care measures, such as “Influenza Immunization Received for Current Flu Season,” and six outcome measures, such as “Improvement in Ambulation.”

In particular, CMS has proposed to include the following measures for its calculation of an HHA’s star rating:

Process Measures

1. Timely Initiation of Care
2. Drug Education on all Medications Provided to Patient/Caregiver
3. Influenza Immunization Received for Current Flu Season
4. Pneumococcal Vaccine Ever Received

Outcome Measures

1. Improvement in Ambulation
2. Improvement in Bed Transferring
3. Improvement in Bathing
4. Improvement in Pain Interfering With Activity
5. Improvement in Dyspnea
6. Acute Care Hospitalization

Only HHAs that have reported data for six of the ten measures used in the calculation would receive a star rating.

CMS stated that it applied the following four criteria in choosing the ten measures for inclusion in the star rating: (1) applicability to a substantial proportion of home health patients, and reported for a majority of HHAs; (2) a reasonable amount of variation among HHAs, and potential for improvement in performance; (3) face validity (which is generally understood as the extent to which a test is subjectively viewed as covering the concept it purports to measure) and clinical relevance; and (4) stability over time. Eight of the thirteen process measures, for example, were eliminated from the star rating because there was very little difference in score between the top performing HHAs and the worst performing HHAs. A more detailed explanation of the four criteria CMS applied in choosing its proposed measures can be found in CMS’s fact sheet.

CMS explained that an “HHA’s quality measure values are compared to national averages, and their rating is adjusted to reflect the differences relative to other agencies’ quality measure values.” These adjusted ratings are then “combined into one overall star quality measure star rating that summarizes each of the 10 individual measures.” CMS applied its proposed methodology to 2013 data and found that about 2 percent of HHAs would have earned 5 stars, about 1 percent would have earned 1 star, and a majority (i.e., 52 percent ) would have earned 3 stars.

CMS stated that it “plans to solicit stakeholder feedback on the proposed star rating methodology, including the measures proposed for inclusion” and that this “may include future Open Door Forums.” The star ratings methodology will then “be finalized based on feedback received and additional technical analysis.” CMS’s proposal is part of CMS’s plan to adopt star ratings across all Medicare.gov Compare websites.

Reporter, Daniel J. Hettich, Washington D.C., +1 202 340 4771, dhettich@kslaw.com.