If Implemented, Program Risks Confusing, Misleading Patients and Public

WASHINGTON, DC – Kidney Care Partners (KCP), concerned that the Centers for Medicare and Medicaid Services’ (CMS) planned End-Stage Renal Disease (ESRD) Five-Star Program will confuse and mislead patients, called on the Agency to delay implementation and work with the community to provide useful, meaningful, and accurate ratings of dialysis providers. KCP is a broad-based coalition of patient advocates, clinicians, care professionals, dialysis providers, researchers and manufacturers working together to improve quality of care for individuals with chronic kidney disease (CKD) and ESRD.

In an August 8 letter to CMS signed by every member of the organization, KCP raises serious concerns about implementation of the flawed ESRD Five-Star Program. Specifically, KCP identified three major reasons the program should not move forward as currently configured:

• The use of a bell curve distorts quality information by forcing a predetermined number of facilities into 1 or 2 stars, even if the facility’s performance on the actual quality measures indicates that they are not low performers;

• Some measures included are misleading because they describe whether facilities are within the normal range of performance and cannot be used to rank facilities; and

• Some aspects of care being measured in the program are not – and cannot — be controlled by dialysis facilities, such as deaths unrelated to kidney failure.

“KCP supports efforts to increase transparency through the public reporting of quality data that provide meaningful information to empower patients,” said Dr. Edward Jones, Chair of KCP and a practicing nephrologist. “However, as designed, the ESRD Five-Star Program will lead to substantial confusion among patients and their loved ones, because it provides misleading and inaccurate information, which does not reflect the actual quality of care being provided and because the ratings are inconsistent with other quality scores being publicly reported by CMS.”

Use of the bell curve may be the single greatest flaw in the program, added Dr. Jones. “Using a bell curve rating system forces a predetermined number of facilities into each performance category, despite the facility’s actual quality performance.” As a result, at least 30 percent of facilities under the flawed program could be inaccurately labeled as having poor quality, which would be confusing to patients and their loved ones for whom this unreliable information is meant to help. “That means that even if a facility meets quality benchmarks established by CMS for Medicare’s Quality Incentive Payment Program, that facility could be rated with a single star, simply because the Five-Star Program forces a certain percentage of facilities to receive a single star,” said Dr. Jones.
“We believe these problems can be overcome, if CMS will work with the community to address key issues before the rollout of the program,” said Dr. Jones. “We strongly urge Agency officials to consult with patients, clinical experts and others in the kidney community before launching this program.”

KCP has a long, successful history of working constructively with CMS to improve quality and patient outcomes through the QIP, the first true value-based purchasing program in Medicare. These activities include harmonizing measures developed through the Kidney Care Quality Alliance (KQCA) with measures developed by CMS.

“If CMS believes an October launch is necessary, we urge the Agency to base its star ratings program upon measures that can be used to compare facilities with one another and use benchmarks that accurately describe facility performance. Once a reliable framework is established, we welcome the opportunity to work with CMS to determine how future iterations should be designed,” Dr. Jones added.