An Open Letter to Andy Slavitt, CMS Acting Administrator

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Dear Acting Administrator Slavitt:

At MPIRICA, our goal is to promote the ability for patients to make informed decisions based on doctor and hospital quality, and we have been pushing the industry as a whole to empower consumers with unambiguous quality measures based on clinical outcomes.

We saw the Centers for Medicare & Medicaid Services’ (CMS) plan to consolidate 60+ disparate quality metrics, into a single 5 star ratings system on the Hospital Compare website as a generally positive step for patients and the industry as a whole. So when CMS announced in late April that they will delay the release of the updated star ratings, in response to letters from 60 senators (April 11) and 225 congressional leaders (April 18th), we were disappointed. The lawmakers offered no recommendations for CMS to achieve its laudable goal of a greatly simplified medical quality measure.

What’s wrong with the proposed CMS star rating system?

Dear CMSThe concern raised by members of congress and senate is that the new system may be “misleading” for consumers due to “flaws in the measures that underpin the ratings.” They are uncertain that the methodology properly accounts for the differences in patient profiles at different hospitals. They fear that hospitals that take sicker patient populations are being punished for having more inherent complications. Another major issue they raised is the possibility that the rating is too heavily weighted in the subjective dimension of patient satisfaction.

While not explicitly called out by the two letters, we also heard concerns that the star ratings are blended scores of a hospital’s overall performance, and does not reflect the wide variation of outcomes from department to department. For example, a hospital that specializes in cardiac procedures may not perform well in orthopedics, and an “all up” score will not reflect that difference.

Rick Pollack, President and CEO of the American Hospital Association (AHA) summarized their concerns: “Health care consumers need reliable, factual information to make critical care decisions.” Star ratings on the Hospital Compare website are meant to inform consumers’ health decisions, “so we need to make sure that they are reflective of an institution’s true quality.”

Addressing the issues without reinventing the wheel

Upon reflection, we actually agree with the lawmakers’ concerns, but we also believe in the CMS goal of creating a single measure of medical performance that can be easily understood by consumers. Moreover, we are convinced that the latest technologies and methods can properly address requirements on both sides of the issue. Specifically:

  • Risk adjustment addresses the concern over differences in patient profiles. It is a well established method for “leveling the playing field” between providers, and it ensures that hospitals and doctors are not punished for taking care of sicker patients.
  • To tackle the subjectivity of the rating system, we suggest CMS remove patient satisfaction as a factor in its scoring, so the outcomes are completely objective. There’s a lot of data showing a priority placed on patient satisfaction does not achieve the best outcomes, and does not serve patients very well as a guide to better quality.
  • The issue that blended ratings hide true performance can be solved by scoring at the procedure and surgeon level, so good and bad performance do not get lost in a combined average. The resulting scoring system will give the granularity necessary to make good healthcare choices possible.

We know it’s not easy

MPIRICA has implemented all of these key methodological approaches noted above in our own surgery rating system called the MPIRICA Quality Score, which includes sophisticated statistical modeling and weighting for scoring dimensions. But it wasn’t easy, or fast.

Although we are a startup, our methodology was not developed overnight. It’s based on decades of experience from a team of clinicians’ and statisticians’ work in medical quality analytics. With that backbone in place, we’ve spent the last two years creating a consumer-friendly approach to outcomes-based surgery quality.

So, Mr. Slavitt, I wanted to send you a letter of both encouragement and support. Please keep up the effort to empower patients with medical transparency information. And, in your diligence on ways to respond to congress, please consider risk adjusted, outcomes based methodologies.

It isn’t easy, but it’s a valiant battle for us all to fight.


Shakil Haroon
Founder/CEO, MPIRICA Health, Inc.