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CMS clears up some questions on new measures in the final rule.

CMS has adopted two new quality measures as proposed, batting down industry comments and criticism on a number of the measures’ aspects.

Background: In its 2014 Home Health Pro-spective Payment System proposed rule, the Cen-ters for Medicare & Medicaid Services proposed adding "Rehospitalization during the first 30 days of HH" and "Emergency Department Use without Hospital Readmission during the first 30 days of HH" (see Eli’s HCW, Vol. XXII, No. 24). CMS proposed to apply the measures to patients who had an acute inpatient hospitalization in the five days before the start of a home health stay, it said in the July 3 rule. CMS wanted to base both measures on claims, not self-reported data.

In the final rule published in the Dec. 2 Federal Register, CMS adopts the measures without changes. "After consideration of the comments received, we are finalizing the adoption of the two claims-based measures," it says. "We will provide feedback to HHAs on their measure rates in CY 2014." CMS plans to add the measures to Home Health Compare in 2015.

CMS makes the move in spite of numerous protests about the measures (see Eli’s HCW, Vol. XXII, No. 37).

For example: Commenters on the proposed rule criticized adoption of the measures without Na-tional Quality Forum endorsement. CMS is seeking NQF endorsement of the two measures, the agency says in the final rule. "However … we may adopt measures for the [Home Health Quality Reporting Program] that are not NQF-endorsed," CMS says. "If NQF does not endorse the proposed quality measures, CMS will consider NQF’s rationale for not endorsing the measures and decide how to proceed."

Another example: Commenters complained that the proposed rehospitalization measures were too similar to already existing ones. "The two quality measures we proposed are different from the existing NQF-endorsed Acute Care Hospitalization and ED Use without Hospitalization measures," CMS maintains in the final rule. "The proposed quality measures specifically target the previously hospitalized home health population, whereas the existing, NQF-endorsed Acute Care Hospitalization and Emergency Department Use without Hospitalization measures evaluate home health agencies on their care for all of their Medicare patients."

HHAs Can’t Deny Their Responsibility, CMS Suggests In Rule

CMS doesn’t buy commenters’ arguments that they shouldn’t be judged on rehospitalizations when so many factors are out of their control. While some readmissions are unavoidable, "we believe that HHAs can provide the highest quality care and coordination of care for their patients so that the rate of preventable readmissions is reduced," the agency maintains. Even when other factors such as the ordering physician’s preference influence readmissions, "the care that a patient receives from a HHA can reduce the need for that patient to be readmitted to the hospital," it says later in the rule.

CMS does clear up some questions from the proposed rule. "‘Risk-standardized’ … is interchangeable with ‘risk-adjusted,’" the agency says. Also, it has listed the risk adjustment factors on its HHQI website, it adds.

Plus: As proposed, the rule reduces the number of home health quality measures currently reported to HHAs through their certification and survey provider enhanced reports (CASPER) reports.

Note: See the final rule at — the section on the measures starts on p. 72297 (p. 43 of the PDF file).