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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations In addition to the Preview Report, we will also include claims-based measure scores in the Hospice Agency-Level QM
Report in CASPER. This report is intended to support quality improvement for hospices. Measure scores will be updated annually in the QM Report as they will in the Preview Report and on Care Compare and the Provider Data Catalogue.
Comment: We received several comments with a request for CMS to consider quarterly as opposed to annual reporting of claims-based measures to best support continuous quality improvement activities.

Response: Our proposal to update annually reflects our understanding that claims measures reflect business practices that are slow to change. For example, for HCI, as we discussed in the proposed rule, we compared index scores calculated for the same hospice using annual claims from Federal FY
2017 and 2019. The analysis found that 83% of hospices had HCI scores that were 01 percentage points different in FY2019 relative to their FY2017 scores.
These results indicate that a hospices HCI scores would not normally fluctuate a great deal from one year to the next, and that they will fluctuate even less from quarter to quarter. Thus, quarterly
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updates would not necessarily provide meaningful support to hospices seeking to improve their quality of care. Instead, progress on HCI will occur over longer time frames, and annual updates are sufficient to support hospices efforts to improve.
Other PAC settings show similar findings regarding the stability of claims measures compared to assessment scores, which we update quarterly. In the home health setting, for example, national median scores for OASIS-based measures tend to increase, while the acute care hospitalization measure remains steady Figure 3.

Figure 3. National median values over time 100

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At the same time, reporting claimsbased measures does require additional labor. Given the findings about stability in claims measure scores, and the cost of updating more frequently, all PAC
settings update claims-based measures annually. Hospital claims-based measures are also updated annually.
The HQRP seeks to align with the other settings.
Given the findings and considerations, we believe that our proposal to provide annual updates is appropriate. However, we will remain open to reconsidering the frequency of reporting claims across all PAC settings in the future, should data after implementation indicate that such change is warranted.
Comment: One commenter expressed concern that CMS would obtain the data from cost reports, which would not allow them time to understand or preview the measures before they were publicly reported.
Response: We will not pull claims data for calculating the measures from cost reports. Instead, it will come from
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our research database that contains Medicare files including fee-for-service claims data. As stated, data source and timing will allow time for hospices to preview their measure scores before they are publicly reported.
Comment: We received comments in support of the proposal to use two years of data for publicly reporting HVLDL
and HCI. One of these commenters expressed support for making the reporting more inclusive of smaller hospices, to encourage them to also improve the quality of care they provide. Other commenters suggested using a 1-year time frame, so as to make the measure score more reflective of current operations and performance, and thus more understandable and useful for providers and consumers.
Some commenters recommended adding a disclaimer that the data are two years old and do not reflect the current status of hospice performance.
Response: We agree that there are benefits to reporting just one year of data. However, we also believe that we must strike a balance between the
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benefits of reporting fewer years of more timely data with the need to be more inclusive of smaller hospices, which MedPAC has found have higher live discharge rates than larger hospices.50 In other settings, some claims-based measures also use two or even three years of data for reporting. For example, as part of the Home Health Quality Reporting Program, the Potentially Preventable 30-Day Post-Discharge Readmission measure is reported using three years of data, while Medicare Spending Per Beneficiary and Discharge to Community measures are reported using two years of data. We also considered using three years of data for HVLDL and HCI, and determined that three years did not yield the same benefit that is, inclusion of hospices relative to cost that is, lag in reporting, and thus proposed using two years of data. With two years of data, 50 percent 50 MedPAC. 2020. Report to the Congress:
Medicare Payment Policy March 2020. http
medpac.gov/docs/default-source/reports/mar20_
medpac_ch12_sec.pdf?sfvrsn=0. Accessed June 13, 2021.

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