Well we knew it was going to happen. CMS has posted a revised 5-Star User’s guide that details the promised changes to the Quality Measure cut point thresholds. In a recent regulatory reminder we indicated that CMS had given us a heads up about these changes in memo issued last month which detailed the planned changes in a 2019 memo QSO-19-08-NH. In our last reminder we reiterated how this will work.
How will this work?
- Every six months, QM thresholds will increase by 50% of the average rate of improvement in QM scores. For example, if there is an average rate of improvement of 2%, the QM threshold would increase by 1%. Note that for the April update, CMS did not change any of the point thresholds for individual QMs.
- The purpose of this is to incentivize continuous quality improvement. Additionally, it will reduce the need to have larger adjustments to the thresholds in the future.
- In QSO-19-08-NH CMS also noted that threshold and methodology changes will cause many nursing homes to decline in QM rating. Consequently, this could further lead to a reduction in overall rating.
- A decline in a Five Star rating, absent any new inspection information, does not necessarily represent a decline in quality. In other words, if a rating changes, it may not have been due to any change in operations or level of care. In these cases, the change in rating would represent a change in the methodology for calculating certain measures. Conversely they also indicated that some nursing homes will see an increase in rating, rather than a decrease.
Cut Points
Below are the actual cut point tables for comparison. Note that the last time these cut point ranges updated was October 2019. If you did the calculations you would see that the changes that will affect the April 2022 Care Compare, and your QM 5-star rating update amount to about a 2% increase in the cut point levels which means that it will be that much harder to achieve each ascending QM star rating.
For example, the overall QM rating cut point range for 4 stars in October 2019 was between 1,299 and 1,474 points. Starting in April 2022 update it will be between 1,331 and 1,509 points. That’s a difference of 32 points on the low end and 35 points on the high end. Again, this represents about a 2% increase in the cut point range. This means a 4% average improvement in the quality measures used to calculate these ranges. For the April 2022 refresh, the average improvement is determined from the period of April 2019 – January 2022.
Comparison
The important point to remember is that this swing in point values will be enough to affect many star ratings. If your rating changes, spend some time understanding why. Your changes may very well be related to these QM cut point revisions. Most of the MDS based QM point values will be based on the 4 quarter average from Q1 – Q4 of 2021.
Lastly, CASPER, the 5-Star public reporting preview and the 5-star preview overview reports have not yet posted. Please be on the lookout for these in the coming days as they will give you guidance as to the changes you can expect to your star rating when Care Compare does refresh later this month.
