On Feb. 13, the Kidney Care Partners sent recommendations for the ESRD Five Star Technical Expert Panel in a letter to Centers for Medicare & Medicaid Services administrator Marilyn Tavenner.
“Kidney Care Partners would like to work with your team and the TEP to identify ways to improve ESRD Five Star so that patients, facilities, and consumers find it a meaningful and accurate tool for evaluating dialysis care,” the organization said in the letter.
Kidney Care Partnerssaid they have been working to develop the recommendationssince the end of 2014. The organization said it also plans to provide more specific recommendations for methodology by March 6.
In the letter, Kidney Care Partners said they have been told by CMS staff that the agency may not review or seriously consider recommendations provided to them after
“While we have been in regular communication with the staff working on Five Star since November, we were given only eight days notice of the hard February 13 deadline,” Kidney Care Partners said in the letter. “The community is extremely disappointed that public notice of comment deadlines was not provided and that our request for a few additional weeks was denied. We ask that you directthe staff to take a more open approach than that which has unfolded to date.”
Kidney Care Partners said it used own group of kidney care experts to develop the recommendations.
- Align the standardized ratio measures methodology with that used for other
- Medicare programs and providers, such as Medicare Advantage (MA) plans and hospitals, by using the CMS claims data available for the hierarchical conditions categories (CMS-HCC);
- Establish the methodology for standardizing comorbidity adjustment for the standardized ratio measures by using a generally accepted methodology, such as the CMS-HCC grouping of diagnosis codes;
- Consider adding the year-over-year difference between normalized (deaths per 100 patient years) for mortality and hospitalization rates currently available from Dialysis Facility Reports data for one to two years until they can be replaced by a standardized mortality rate and a standardized hospitalization rate; and
- Provide raw transfusion, hospitalization, readmissions, and mortality data directly to facilities on a quarterly basis by using Dialysis Facility Report calculations and the six-month lagged data file.
- Provide a clear definition of quality and performance criteria while continuing to provide patients and consumers with information to allow them to distinguish in a meaningful way among and between facilities;
- Address the statistical uncertainty CMS has identified in the standardized ratio measures, as well as when defining the cut points for stars; and
- Preserve the actual performance distribution without amplifying the differencesin a way that misleads patients and consumers.
More details about the recommendations are available in the letter.