VNAA recently submitted comments to CMS on the proposed five-star performance-rating system for home health agencies. CMS intends to create a consistent rating system in all sectors of the healthcare market to assist beneficiaries in making informed choices about where to obtain care. The star ratings will be in addition to the Home Health Compare measures currently available. Patients and their caregivers can use the star rating to search providers by performance criteria that matter most to them.
VNAA generally agrees with CMS' overall approach to the home health star ratings but submitted several comments, questions, and recommended changes. VNAA agrees with CMS' approach of using a subset of existing process and outcome measures from the Home Health Compare measure set. This ensures that the ratings are based on validated measures and prevents the unnecessary burden on providers of additional reporting. VNAA also fully supports CMS' approach to engaging home health agencies multiple times over the process of development. It is particularly important that home health agencies have the opportunity to review their star rating in advance of it being made public. VNAA's major concern relates to the high proportion of home health agencies that are anticipated to receive 3-star rankings and whether that accurately reflects the quality of care provided by home health agencies. VNAA also provided comments on measures selected, the review process for the consumer-facing language on the website, and the risk adjustment methodologies for outcome measures.