In the letter, CHA urges the agency to take a fresh look at the way patients and providers use Hospital Compare and whether proposed changes to ratings methodologies actually meet those needs.
CHA believes that three of the proposals outlined in the request for comment warrant additional consideration in the short term. These include new clinical and empirical criteria for measure groups, revision of weights applied to measures used in the latent variable model, and continued exploration of peer grouping for star ratings to address potential biases. CHA also urges CMS to remove patient safety indicator measures from its measurement programs.
Most importantly, CHA urges CMS to consider additional stakeholder input from experts and put additional thought into its approach before any action is taken.