These were Cindy Krafft’s comments to Star Rating on HH Compare after she participated in a live phone discussion with CMS:

Thank you for taking my call as a participant in the discussion held on February 5. At that time you asked me to submit my thoughts in writing via this website and I am doing so now. If I can provide any additional information or be of any assistance, please let me know.

I appreciate the efforts of CMS to ensure that home health agencies are focused on the quality of care being delivered. Consumers deserve to have access to tools that assist with selecting a provider of home based services based on measurable information. Many times the publicly accessible information can be confusing for the consumer to navigate so refinements to the format and focus should be expected as the process evolves.

Many concerns about the use of a “star” symbol have been raised and I agree that consumer confusion regarding what a “star” means in this specific situation as compared to other uses should be considered. As the intent is to compare agencies to each other and not to serve as a report card, consideration of another symbol (maybe a little house) should be made.

My larger concern is the data used to calculate the rating – Home Health Compare.This model has become an integral part of home health agency culture since its inception. The majority of items publicly reported on focus on “improvement” leaving both “stabilization” and “decline” rates off the public report. There is confusion at both the provider and consumer level regarding the implications of only one set of data being reported.

As an example – can you see the difference between these two agencies?

  • Agency A: Ambulation Outcome – 54% improvement, 46% decline
  • Agency B: Ambulation Outcome – 54% improvement, 40% stabilization, 6% decline

Without clarification, many assume the TOTAL non-reported percentage represents DECLINE.

This has become an even more important issue in light of the Jimmo vs Sebelius settlement in 2013 which confirmed that IMPROVEMENT is not the sole measure of skilled care and that MAINTAINING / STABILIZING a patient that requires skilled services IS a covered part of the Medicare benefit. Although regulations have been clarified, Home Health Compare inadvertently continues to emphasize ONLY improvement. The end result is a devaluing of stabilization in the minds of many. By adding another layer of emphasis in the form of “stars” based on improvement alone, there is concern that the vital importance of including stabilization as a viable focus of care will be negatively impacted.

On the Open Door Forum call, it was indicated that adding stabilization rates to the proposed calculations could be considered in future evolutions of this model and this would be GREATLY appreciated.

In the short term, I STRONGLY urge consideration of publicly reporting the rates of improvement, stabilization AND decline as part of Home Health Compare effective AS SOON AS POSSIBLE. This information is currently in the hands of CMS and would not require a large amount of work to add to the report. This apparently simple task would reinforce that CMS is in full support of the Jimmo settlement and actively educating both the consumer and the provider about the value of skilled care to prevent or slow decline.

Thank you for your time.