In a letter to the Centers for Medicare & Medicaid Services' Center for Clinical Standards and Quality, Dialysis Patient Citizens expressed concern about the implementation of Dialysis Facility Compare's new five-star rating system.

"We applaud CMS’ well-intentioned efforts to try to simplify Dialysis Facility Compare (DFC) for consumers, the executive director and director of government affairs for the patient organization said in a letter. "However, we are not convinced that the proposed five-star methodology will accomplish our shared goal of improving transparency for beneficiaries. It seems to us that the agency is moving very quickly to adopt a novel scoring methodology that exposes patients to two conflicting quality rating systems for facilities, and is doing so at a time when consensus has formed in the health policy community that outcome measures need to be adjusted for socio-economic status."

Dialysis Patient Citizens is particularly concerned about the bell curve scoring methodology: "As Tracey Miller and William Sage have noted, disclosures about health care providers must strike the proper balance 'between educating patients and alarming them.' Given the connotations commonly associated with one- and two-star ratings in the minds of consumers, we are concerned that these ratings may inappropriately stigmatize facilities for outcomes that are beyond their control. We hope the patient would not interpret these reviews as one ordinarily interprets a movie review, and decide to stay home. We further note that for beneficiaries who regularly use the consumer review website Yelp, one- and two-star facilities may be judged particularly harshly—Yelp issues those ratings to just the lowest twenty percent of businesses."


Related: What’s wrong with the 5-star rating system for the renal community


The letter also expressed concern about the rating methodology's alignment with the ESRD Quality Incentive program. Under the QIP, all dialysis facilities that meet quality goals are given good ratings. But the five-star rating system will grade dialysis facilities on a curve. "We believe this is the first time that patients have faced the same payer issuing more than one rating to the same health care provider."

The patient organization said it is also concerned about making nationwide comparisons. "From the beginning of its quality reporting and pay-for-performance efforts, CMS has taken the position that quality should be judged as part of a nationwide competition among providers. This approach assumes that providers serving the most disadvantaged areas in our very diverse nation can, or at least should, be capable of producing as favorable patient outcomes as their counterparts in wealthier regions."

Download a copy of the letter.