The Centers for Medicare & Medicaid Services has agreed to delay implementation of its five-star rating system for dialysis facilities until January, according to a memo received by dialysis advocacy groups this morning.
The renal community has been critical of the system, saying it had little say in the methodology used in its development and that some of the performance measures used in the ratings haven't been properly vetted by the National Quality Forum or CMS itself. The agency said it will use 11 quality measures that are part of its Dialysis Facility Compare program to set the star ratings, but dialysis providers and patient groups have questioned the use of three of those measures dealing with hospitalizations, mortality, and blood transfusion rates because they are not part of the ESRD Quality Incentive Program, which dialysis providers must participate in as part of receiving Medicare eligibility for reimbursement. Those three measures skew the rating system, giving some dialysis facilities who did well on their QIP performance score a poor, 1–2 star rating from the DFC-based system.
CMS had planned to launch the rating system in October after dialysis facilities were given a month to review and/or contest their rating, but kidney groups, along with the Medicare Payment Advisory Commission, had urged CMS to delay the launch.
"In response to the feedback, CMS has decided to implement the Star Rating System for dialysis facilities in January 2015 to allow more time for consumer education about appropriate use of the ratings for making decisions about treatment," CMS said in the memo release Sept. 10. "Implementing the Star Rating system for dialysis facilities in January will also give dialysis facilities extra time to review their ratings and fine tune verification and correction processes for data submission to DFC."
CMS says the star ratings on DFC is part of its plan to feature star ratings on all of Compare websites in an effort to help consumers compare and select health care providers. Originally launched in 2001 and mandated by the Balanced Budget Act of 1997, DFC lists approximately 6,000 Medicare-certified dialysis facilities on its site.
Prior to launching the DFC Star Rating System for dialysis facilities, CMS said it will provide a variety of consumer educational activities, including:
- An Open Door Forum that will provide background on the Compare website star rating initiative, the development of star ratings for DFC, the difference between star ratings and QIP, and the strengths and limitations of star ratings in making treatment decisions.
- Consumer group informational sessions that will provide ready-to-use information on how to use the stars to inform treatment decisions, including the strengths and limitations of stars.
- Direct consumer outreach to put information in the hands of consumers through the many ways they receive health care information, including newspapers, the internet, and other sources.
"CMS is committed to working with stakeholders in implementing the star ratings for Dialysis Facility Compare. We will continue to partner with the ESRD community to ensure that consumers have information they can easily understand and use to make important health care decisions," the agency said.
The announcement of the delay drew a harsh response from Kidney Care Partners, which represents dialysis providers, manufacturers and supplies, pharmaceutical companies, and patient groups. "There is no indication that CMS plans to correct flaws in the program, despite the serious concerns raised collectively and individually by patient advocates, physician and nursing organizations, dialysis providers, as well as policy makers, including the Medicare Payment Advisory Commission (MedPAC)," said KCP chairman Edward Jones. "Kidney Care Partners believes that no amount of patient education will fix what's broken in the Dialysis Five-Star Program and by changing the implementation date, CMS has done little more than kick the can down the road. Instead of simply changing the implementation date, CMS should start over and develop a rating system that is based on accurate data and an evidence-based methodology.
"As MedPAC noted, the Medicare ESRD program already has an existing, fully transparent quality program mandated by Congress, called the Quality Improvement Program (QIP)," said Jones. "This program provides publicly available quality information at the facility level. We urge CMS leaders to work closely with the kidney care community to find an alternative to the current forced 'bell curve' methodology. We also urge the Agency to work with us to ensure that the quality measures included in the program lead to public information about dialysis that is accurate, evidence-based, useful and understandable for patients and the general public.
"This Five-Star program simply should not move forward given its numerous flaws."