UPDATE: April 1, 2019: America's Essential Hospitals submitted its comments on the star ratings program Friday, urging CMS "to suspend publication of the ratings and consider the following comments before moving forward, to avoid confusion among patients and disproportionate effects on essential hospitals." A CMS spokesperson told Healthcare Dive the agency appreciates the feedback it has received so far and will publicly post a summary of the comments "once we've had time to thoughtfully review all comments."
- The American Hospital Association supports just three of the 14 changes CMS has proposed to the hospital star ratings system and requested the agency remove the existing ratings from the Hospital Compare website. The group remains concerned the program "is being compromised by a methodology that can lead to inaccurate, misleading comparisons of quality performance."
- In a Wednesday letter to the agency, AHA said it approved of empirical criteria for measure groups, peer grouping star ratings among similar hospitals and using an explicit scoring approach but found the other proposals did not address "important shortcomings" in the program or did not include enough information to be judged.
- AHA also gave additional suggestions not included in the CMS proposal, including consulting experts about the approach to calculating latent variable models, examining how to mitigate the impact of outliers on readmission rate calculations and an alternative approach that did not include an overall rating of individual hospitals.
AHA and CMS have tussled over the star ratings program for years, with the hospital group frequently arguing that the underpinnings of the ratings are fundamentally flawed. CMS says patients need a convenient and easy-to-understand way to assess a hospital's quality record — a goal AHA says it shares.
Heeding the hospitals' concerns, CMS delayed an update to the star ratings for more than a year, but rolled out a new set of rankings a month ago, along with a proposal to alter how the stars are calculated.
In its latest letter, AHA said it understands the desire for updated information, but wants the current rankings taken down. "We appreciate the desire for the ratings to reflect the most current quality data. Yet CMS's public comment underscores the many problems with the current methodology. Unless and until the ratings methodology is improved, it will be difficult for hospitals and the public to have confidence that star ratings portray hospital performance accurately," wrote Ashely Thompson, the group's senior vice president for public policy.
CMS did not immediately respond to a request for comment on the letter, which is addressed to its chief medical officer, Kate Goodrich.
AHA wrote that while CMS pushes the ratings system as a tool intended primarily for patients, hospitals will still want to benchmark their performance against others and incorporate the scores in quality improvement goals. Also, commercial payers "are increasingly expressing interest in using star ratings for contracting purposes."
The group measured the proposed changes from CMS against six metrics: usefulness to consumers, accuracy, stability, line of sight to underlying measures, balance of assessment and accounting for potential bias. The three changes AHA cautiously endorsed either fully or partially met the criteria for at least three of the six concerns.
Least palatable was the proposal to use individual component Patient Safety Indicator measures. AHA said that because PSIs rely on claims data, they do not provide a full and accurate picture of a hospital's safety record. It called on CMS to transition the measure out of all of its reporting programs.