I want to express my concerns about an area on the Home Health Compare section of the Medicare.gov Web site. In the section "ER and EMERGENT care," the subsection "What It Means" has created false public impressions because agencies are judged negatively or positively by this information to consumers, families, other health professionals, and regulatory and accrediting bodies.

My agency serves patients well above the national and state average in age (90s to 101 years old). We actually pride ourselves on successfully managing these near-centurions and have become quite specialized in caring for this special patient group. The many direct needs, coordination of services and caregivers, and overall case management for this age group are much beyond the concept of geriatric care. We capture data on patients with chronic health problems and orthopedic high-risk patients. Our patients from their first visit are fragile, brittle, and are well above high risks for falls and disease exacerbations, which pushes them to ERs door. Our reported numbers indicate an above-average rate for hospitalizations and after-hour emergent care events, yet I can give you many reasons why.

We enhance many lives in the "assisted living" environment, yet we are at the mercy of each facility's different policies concerning falls and other emergent care problems. In most instances, they follow their protocol that is written: "Send to ER." The next day, we learn about the emergent care from a family member or directly from the facility. The decisions have been made, the action taken. We had no opportunity to assess the situation and suggest an intervention. Many times our decision would have been the same. It's not an education issue with the assisted living facilities; it's their own policy that ultimately affects our scores.

The hospitalization and emergent care statement to the public of "less is better" may not be the best statement to capture all home care agencies across the United States. Perhaps including some age data regarding the population the agency serves and allowing the agency to make a two-line comment under a posted score that appears adverse could be included on the Health Care Compare site. The report may allow for an improved, fair, and more accurate report to the public. The statement of "less is better" is an irresponsible statement when it comes to my agency. Often, quality care IS going to the hospital and ER.

Home Health Compare scores can be a useful tool for Pay for Performance if modified.

I no longer will feel the pang of guilt or frustration with my staff. Good nurses and physicians recognize the importance of fast medical attention by way of ER and hospitalizations when the specialized services needed can be provided only in that setting. I have made my comments to our QIO and to CMS. I'm asking my colleagues to consider their agency's "more or less" score to determine what is unique about their patient population and service area that is typical for the patients served. If many of us actively communicate about this subject, the Health Care Compare reports will not mislead the public and can become a better tool to use as pay for performance looms in our future.