Coalition Wants CMS to Make Changes To Dialysis Facilities’ Star Ratings

February 18, 2015

Published by Bloomberg BNA
Michael D. Williamson
Feb. 18, 2015

A coalition of dialysis providers, patient advocates and drug companies recently urged the CMS to change the rating system used on the agency’s Dialysis Facility Compare website.

The coalition, known as Kidney Care Partners, provided recommendations in its Feb. 13 letter for the agency’s end­-stage renal disease (ESRD) technical expert panel (TEP) to consider. In January, when the Centers for Medicare & Medicaid Services added ratings (of one to five stars) to the dialysis facility website, it said the TEP would make recommendations to the agency for future modifications of the star ratings system as necessary (15 HCDR, 1/23/15).

The Kidney Care Partners letter encouraged the agency to allow the TEP “to conduct an open and transparent review of the current Five Star methodology and to have a meaningful discussion with us” about current and future recommendations from the coalition. Edward Jones, the KCP’s chairman, signed the letter.

The KCP letter expressed concerns about use of a bell curve methodology for rating the dialysis providers, which puts a relatively small number of facilities in the top ranking, and noted that such a methodology for some nursing home ratings has been eliminated.

TEP Nominations

The nomination period for the ESRD star ratings expert panel opened Feb. 2 and continues until March 4, according to a CMS website.

The website also includes information on nomination periods for other Medicare­related expert panels.

The coalition’s letter to the CMS said the ESRD star ratings TEP process “must be an open and transparent process that takes into account not only theoretical and academic issues, but also acknowledges practical and operational realities.”

Furthermore, the agency should provide a timeline that clearly describes each step in the TEP process and when it will occur, the KCP said.

The coalition recommended the agency “improve the membership of the TEP panels to ensure that it is reflective of all constituencies within the community,” the coalition said, adding that the CMS should also “create an open and transparent process” and establish clear evaluation criteria for TEP members to apply to the evaluation of measure and structural proposals.

The members of KCP include drugmakers such as AbbVie and Sanofi, organizations such as the Kidney Care Council and National Kidney Foundation, and providers such as DaVita Healthcare and Fresenius Medical Care North America.

Problems With the Bell Curve
In addition to its TEP recommendations, the KCP called on the agency to change the methodology used to determine ratings on the compare website. According to the KCP’s letter, the CMS decided to use a fixed bell curve methodology for dialysis centers. The organization pointed that similar rating methodologies have been successfully fought by other providers.

The methodology means that quality measures shown on the Dialysis Facility Compare (DFC) website “fall into a normal distribution and then sets cut points based on the percentage of facilities in each category,” the letter said. “We understand that CMS originally used bell curves for some of the categories of the nursing home star ratings,” the KCP added.

Nursing homes “also raised concerns about this methodology because it also meant that no matter how good a nursing home’s performance was, only 10 percent of nursing homes could receive five stars and 23.3 percent could receive four stars,” the group said, adding, “After nursing homes raised concerns, CMS changed the methodology in a way that resulted in 53 percent of nursing homes receiving four and five stars.”

Ultimately, the CMS should “eliminate the fixed bell curve methodology for dialysis facilities,” the KCP’s letter said.

The KCP said it has never asked the agency “to cease the ESRD Five Star program.” Instead, the group added, “we have focused our discussions and recommendations on ways to improve the program.”