CMS announced on their Medicare Learning Network (MLN) national call a proposed change to the Quality of Patient Care (QoPC) Star Ratings starting next year. CMS has proposed to eliminate the “Drug Education on all Medications Provided to Patient/Caregiver” measure and add the “Improvement in Management of Oral Medications” measure to the QoPC algorithm.
This comes on the heels of their very first algorithm change since the July 2015 inception of the home health star ratings. As of the Home Health Compare (HHC) April 2018 refresh, CMS eliminated Flu Vaccinations from the list of reported measures used in the star ratings.
The elimination of the Drug Education measure sure makes sense. These scores were “topped out” with the median score (50th percentile) at 98.7%. There just was not enough variability in the scores nor much room for improvement across all providers to be meaningful.
With this proposed change CMS noted that the average rating of 3.7 would not change, and the distribution of star ratings would change very little based on episodes ending 7/1/2016 through 6/30/2017 (see graph).
What seems to be overlooked with these subtle changes is how often Star Ratings by provider change each quarter. During this MLN call CMS pointed out that about 35% of all providers see their QoPC Star Ratings change up or down by a half star each quarter. With their proposal the impact would be about the same - 35 percent! That was larger than I had expected.
In fact, looking at the change when the Flu vaccination was removed in April, agencies with a star rating in both the HHC Jan 2018 and April 2018 refresh, 42% of all providers saw a QoPC star rating change.
Keep in mind this is due in part to the star rating methodology that uses decile rankings for each QoPC measure. By using statistical significance calculations, the formula pushes provider scores toward the middle in forming this more traditional bell curve as can be seen by the graph. As providers improve in their scores and new providers are added/deleted, the decile cut points change to reflect the new distribution in these scores.
As an example, in looking at the cuts point changes for Ambulation you needed only a score of 74.4% for a 5 Star rating in July 2015 where today you now need a score of 85.3%, a 10.9 percentage point increase to keep your 5 star rating.
In looking at HHC refresh scores for Ambulation between the Jan 2018 and April 2018, 5,274 or 61.1% of the providers showed improvements in their scores, but only 21.8% saw an increase in their Ambulation decile rankings. In fact, there were 176 providers that had an improvement in their scores but their Ambulation ranking actually went down!
With provider scores improving each quarter, no provider can stand still. CMS will continue to make changes to their quality reporting programs, so keeping track of these changes and closely monitoring and improving your scores will be critical to your success.