VHCA & AHCA Comment on Proposed Five Star Nursing Home Quality Rating System

VHCA (7/25/2008)

Both VHCA and AHCA have submitted comments on the recently announced Five Star Nursing Home Quality Rating System to the Centers for Medicare & Medicaid Services (CMS).

In its comments VHCA indicated support for the need to develop a process to increase the usefulness of the Nursing Home Compare website to assist consumers in selecting a nursing facility based on informed choice and the best facility to meet the needs of their loved one.  However, we voiced strong reservations that the proposed Five-Star process is not adequately developed and currently lacks a foundation of accurate and consistent data.  Until additional refinements are made to enhance MDS and QI/QM accuracy and improvements are made related to survey consistency in application of deficient practices, the projected time frame for implementation of this project is premature.  National implementation of a Five-Star Rating System should be delayed until the MDS 3.0 and the QIS survey process are implemented.

VHCA comments included a recommendation that CMS consider partnering with organizations that already use validated tools for customer satisfaction surveys for inclusion in the rating system.  Additionally, we strongly encouraged CMS to provide another opportunity for comment once the formula and criteria have been determined prior to publicly reporting a Five-Star rating system for nursing facilities across the U.S."

In its comments AHCA said, "as currently proposed and designed by the Centers for Medicare & Medicaid Services (CMS) the rating system is seriously flawed and AHCA does not support this system in its current form.  There must be an agreed upon definition of ‘quality.’  Professionals in nursing homes, CMS staff, professional organizations, direct care staff, researchers, state surveyors, nursing home residents, and family members struggle with how to define, measure, and analyze ‘quality.’  An agreed upon definition is essential to the framework of a quality rating system.” 

CMS has announced that it intends to implement the Five Star Nursing Home quality Rating System by January 2009.