As part of the federal government’s new risk-based survey model, nursing homes will be marked as “high-performing” using a little gold trophy icon on Care Compare. While the icon could be a powerful marketing tool, sector leaders warn that its use could be problematic on many fronts.
First, the gold trophy’s presence could create the false perception that it alone should be used to assess a nursing home’s quality or suitability, when in fact facilities without the icon may still be the best option for a resident in need of a particular service. Moreover, updates related to the icon may be unreliable or delayed if operators are waiting for CMS to provide state survey agencies with updated lists of who qualifies.
All in all, as the icon plan is rolled out, there needs to be consumer education, explaining its limitations, providers said.
The sector is aware of how difficult it will be to get into this bracket for surveys, with just 12% meeting all the criteria currently. But the rewards are great – high-performing facilities that qualify will undergo surveys that take half the time and require fewer surveyors. CMS said it will provide state survey agencies with a list of risk-based qualified facilities at the end of each quarter.
Facilities are eligible for the risk-based survey for six months after the state agency receives the list of qualifying facilities from CMS. The agency has plans to implement the icon on the back-end by Sept. 8 and have it publicly displayed on Sept. 30.
Michelle Stuercke, chief clinical officer for Transitional Care Management, sees the icon as a stop sign of sorts for the public.
“I think that’s going to mean a lot,” said Stuercke told Skilled Nursing News. “They used to talk about the good housekeeping seal of approval that would make people buy that product, right? I think for buildings that have [the gold trophy], and from a consumer standpoint, I think it’s going to be a really strong marketing feature.”
Brian Ellsworth, vice president of strategy and policy at Health Dimensions Group, told SNN that the icon is a “welcome next step along the journey of rewarding performance instead of just focusing on penalties.”
Measuring quality isn’t an exact science, and we need as many tools in the toolbox as possible, he added.
Robin Mitchell, chief nursing officer for Diversicare, agreed that the icon is good on the surface.
“I think the icon at first glance will signify an excellent center for referrals, patients and families,” Mitchell told SNN. “I do think there are excellent operators though that may not have the icon for one reason or another, and those operators are going to have to continually justify why they do not have the icon.”
The icon misses nuance
Just one month of decreased staffing can affect overall star ratings, Mitchell said, and in turn the risk-based survey list. The risk-based survey eligibility test requires nursing homes have no less than a Five-star overall rating and no less than a Three-star staffing rating. These criteria are two of 11 stringent requirements that range from star ratings to schizophrenia diagnoses.
“There are many variables that may impact [the risk-based survey list], but it doesn’t mean [a facility without the icon] is a bad place to go and get rehab or care,” said Mitchell.
The icon will be a strong indicator for families too, Stuercke said, and drive family decision-making – operator approval of the icon will likely come down to whether an operator has the icon.
Stuercke urges families to use a fair bit of discernment here, especially since a facility with the high-performing icon may not have the services a family member might need.
“Maybe the facility in your town that has the icon doesn’t provide dementia care or doesn’t provide some high acuity care that your family member needs. I think there does need to be some consumer education on that,” said Stuercke.
And as for nursing homes that don’t have the icon – which will be most buildings in the country – marketing focused on such services will be key. Stuercke expects a certain narrative to pop up, something along the lines of ‘yes, we might not have a Care Compare icon, but we provide so many specialized services that can only be found here.’
Nursing homes with three or four stars will need to market their outcomes, as well as the services provided.
“Surveyors, social workers and discharge planners are going to encourage people to go where that icon is. Your marketing team should be talking now about how you’re going to talk about the care that your facility delivers and the quality that you produce … you want to have that story,” said Stuercke. “Even if you don’t have that emblem, I suspect those buildings are going to be full pretty quickly.”
Physical tours of a facility will matter even more as well, she said, with the patient meeting the care team and getting a feel for the facility.
Family members are also at the mercy of their loved one’s health insurance. Nursing homes bearing the gold trophy icon may not take their insurance, a reality that will need to be discussed between the hospital, discharge planner and family.
Putting the high-performing icon to use
Stuercke said we may see hospitals and social workers seeing only the icon as a gold standard, much like the Five-star rating system, encouraging people to go to the facility with the icon without considering all of these other angles.
It’s important to remember that the Five-star system was never meant to be used in all the ways it is now – the sector and agencies should be careful that the icon doesn’t cause the same issues.
“It was never meant for all these uses that we’ve given it,” Stuercke said of the Five-star rating system. “Managed care companies already have rules around stars. I do think that if you are a building that has not been contracted with a managed care company, and you would like to be contracted, and you are lucky enough to have the emblem, I think they are 100% going to be much more willing to contract with you than somebody who doesn’t.”
As for staff recruitment and retention, nursing homes with the icon will likely already have decent staffing ratios to achieve that high-performing status. These facilities will have an easier time recruiting and retaining staff, but it’s unclear if this will widen the gap between facilities at the top of their game and those that are at the bottom.
Reliability issues
One more factor when discussing the high-performance icon, leaders said, is a likely difference between state lists of risk-based survey facilities and those that have the icon.
Data transmission and posting processing will create differences between facilities identified on the lists sent to states and those with the icon in Care Compare, CMS said. It’s a potential communications headache between providers and the public, if an operator wants to market a facility with the icon when the state is getting lagged data from CMS.
“The difference in timing will have more impact on the public, I believe,” said Mitchell. “States should use the CMS data listing, although we know that the CMS timing is sometimes lagging, as evidenced by updates on the Special Focus Facility (SFF) listings after a good survey.”
The agency urged states to conduct risk-based surveys based on the lists sent to them and not based on what is displayed on Care Compare.
Stuercke compared the lag to what happens with star ratings not updating in a timely manner following a survey, or due to a lack of timely surveys.
Companies featured in this article:
Centers for Medicare & Medicaid Services, Diversicare, Health Dimensions Group, Transitional Care Management

