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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations
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2020 hereafter excepted data. The testing helped us develop a plan for displaying HH QRP data that are as upto-date as possible and that also meet scientifically-acceptable standards for publicly displaying those data. We believe that the plan allows us to provide consumers with helpful information on the quality of home health care, while also making the necessary adjustments to accommodate the exception granted to HHAs. The following sections provide the results of our testing for OASIS and claims and explain how we used the results to inform a proposal for accommodating excepted data in public reporting. HH
CAHPS discussion is further in section III.G.4.
4. Update on Use of Q4 2019 HH QRP
Data and Data Freeze for Refreshes in 2021
In the March 27, 2020 Guidance Memorandum, we stated that we should not include any PAC quality data that are greatly impacted by the exception granted in the quality reporting programs. Given the timing of the COVID19 PHE onset, we determined that we would not use HH QRP OASIS, claims, or HH CAHPS data from Q1 and Q2 of 2020 for public reporting, and that we would assess the impact of the COVID19 PHE on HH QRP data from Q4 2019. In the original schedule Table 20, the October 2020 refresh included Q4 2019 measure based on OASIS and HH CAHPS data and is the last refresh before Q1 2020 data are included.
Before proceeding with the October 2020 refresh, we conducted testing to ensure that publicly displaying Q4 2019
data would still meet our standards despite granting an exception to HH
QRP reporting requirements for Q4
2019. Specifically, we compared submission rates in Q4 2019 to average rates in other quarters to assess the extent to which HHAs had taken advantage of the exception, and thus the extent to which data and measure scores might be affected. We observed that the quality data submission rate for Q4 2019
was in fact 0.4 percent higher than the previous calendar year Q4 2018. We note that Q4 2019 ended before the onset of the COVID19 pandemic in the U.S. Thus, we proceeded with including Q4 2019 data in measure calculations for the October 2020 refresh.
Because we excepted HHAs from the HH QRP reporting requirements for Q1
and Q2 2020, we did not use OASIS, claims, or HH CAHPS data from these quarters. All refreshes, during which we decided to hold this data constant, included more than 2 quarters of data that were affected by the CMS-issued
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COVID reporting exceptions, thus we did not have an adequate amount of data to reliably calculate and publicly display provider measures scores.
Consequently, we determined to freeze the data displayed, that is, holding data constant after the October 2020 refresh without subsequently updating the data through October 2021. We communicated this in a Public Reporting Tip Sheet, which is located at: https www.cms.gov/files/
document/hhqrp-pr-tipsheet081320final-cx-508.pdf.
5. Application of the COVID19 PHE
Affected Reporting CAR Scenario To Publicly Display Certain HH QRP
Measures Beginning in January 2022
Through July 2024
We also proposed to use the CAR
scenario for refreshes for January 2022
for OASIS and for refreshes from January 2022 through July 2024 for some claims-based measures. There are several forthcoming HH QRP refreshes for which the original public reporting schedule included other quarters from the quality data submission exception.
These refreshes for claims-based measures, OASIS-based measures, and for HH CAHPS Survey measures are outlined in Table 20.
Because October 2020 refresh data will become increasingly out-of-date and thus less useful for the public, we analyzed whether it would be possible to use fewer quarters of data for one or more refreshes and thus reduce the number of refreshes that continue to display October 2020 data. Using fewer quarters of more up-to-date data requires that: 1 A sufficient percentage of HHAs would still likely have enough OASIS data to report quality measures reportability; and 2 using fewer quarters of data to calculate measures would likely produce similar measure scores for HHAs, and thus not unfairly represent the quality of care HHAs provided during the period reported in a given refresh reliability.
To assess these criteria, we conducted reportability and reliability analysis excluding the COVID19 affected quarters of data in a refresh instead of the standard number of quarters of data for reporting for each HH QRP measure to model the impact of not using Q1 or Q2 2020 Specifically, we used historical data to calculate HH quality measures under two scenarios:
Standard Public Reporting SPR
Scenario: We used HH QRP data from CY 2017 through 2019 to build the standard reported measures, to represent as a proxy CY 2020 public reporting in the absence of the temporary exemptions from the
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submission of OASIS quality data, as the basis for comparing simulated alternatives. This entails using 4
quarters of CY 2019 HH QRP data to model the OASIS based measures that are normally calculated using 4 quarters of data. This also entailed using 4
quarters of HH QRP data from CY 2019
for the all-cause hospitalization and emergency department use claims-based measures, 8 quarters of HH QRP data from CY2018 and CY2019 for Medicare spending per beneficiary MSPB and discharge to community DTC claimsbased measures; and or 12 quarters from January 2017 to December 2019 for the potentially preventable readmission claims-based measure.
COVID19 Affected Reporting CAR Scenario: We calculated OASISbased measures using 3 quarters of HH
QRP CY 2019 data to simulate using only Q3 2020, Q4 2020, and Q1 2021
data for public reporting. We calculated claims-based measures using HH QRP
CY 2017 to 2019 data, to simulate using the most recent data while excluding the same quarters Q1 and Q2 that are relevant from the COVID19 PHE
exception. We used 3 quarters of HH
QRP data from CY 2019 for the all-cause hospitalization and emergency department use claims-based measures and 6 quarters of data from HH QRP CY
2018 and CY 2019 were used for both the Medicare spending per beneficiary and discharge to community claimsbased measures. We used 10 quarters of HH QRP data from CY 2017 to 2019 to calculate the CAR scenario for the potentially preventable readmissions claims-based measure. For both claims and OASIS-based measures, the quarters used in our analysis were the most recently available data that exclude the same quarters Q1 and Q2 as that are relevant from the COVID19 PHE
exception, and thus take seasonality into consideration.
The OASIS-based measures are based on the start of care and calculated using admission dates. Therefore, under the CAR scenario we excluded data for OASIS-based measures for HHA patient stays with admission dates in Q1 and Q2 2019. To assess performance in these scenarios, we calculated the reportability as the percent of HHAs meeting the 20-case minimum for public reporting the public reporting threshold, or PRT. We evaluated measure reliability using the Pearson and Spearman correlation coefficients, which assess the alignment of HHs measure scores between scenarios. To calculate the reliability results, we restricted the HHAs included in the SPR
Scenario to those included in the CAR
Scenario.

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