From: RevCycle Intelligence
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According to its August letter addressed to CMS contractors, CRE states CMS has a legal obligation to develop the star ratings in compliance with such regulations as well as requirements of the Medicare Act and the Administrative Procedure Act. CRE references a letter from the Department of Health and Human Services (HHS) sent in response to a Request for Correction under the DQA filed by CRE additionally informs the World Health Organization (WHO) “the process lacked a high degree of transparency, and the data and analytic results contained within the Report were not subject to formal, independent, external peer review, among other criteria.”
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CRE recommends the Yale-New Haven Health Services Corporation / Center for Outcomes Research and Evaluation and the Lantana Consulting Group address the following steps:
- Ensure that the collection of data used in developing the ratings was collected in accordance with the PRA and has an OMB Control Number.
- Ensure that all of the work you perform is reproducible by qualified third parties and publicly disclose for comment the data sets and documentation necessary for third-parties to conduct such verification.
- Work with CMS to develop a peer review plan for the analytical components of the program, designating the program as “highly influential” (HISA), and in sponsoring an independent, expert, external peer review in accordance with the OMB/OIRA peer review requirements.