Comparing Facility QM Rates Against Peer Facilities on Nursing Home Compare
A facility's QM rating depends on peer performance, not just its own results.

Comparing facility QM rates on Care Compare, the successor to Nursing Home Compare, requires more than checking whether a rate improved. CMS scores key measures against national decile distributions, so a facility’s standing depends on peer performance as well as its own. Proactive rating management therefore combines public peer comparisons with accurate coding and continuous review of the clinical documentation nurses already produce.
How CMS actually scores QM ratings — and why the bar keeps moving
CMS’s Five-Star Quality Rating System assigns ratings of 1–5 stars across three separate domains, which are health inspections, staffing, and quality measures. The QM rating comes from a subset of MDS-based and Medicare claims-based measures. For key measures, CMS groups facilities into deciles based on the national distribution of performance across participating nursing homes. These include long-stay ADL worsening, antipsychotic use, mobility decline, and claims-based measures for both long-stay and short-stay residents. A decile identifies a facility’s place within that distribution.
The distinction is between clinical performance and relative standing. A facility’s rate describes its measured results, while its decile shows how those results compare with the national cohort. The scoring system does not treat an unchanged rate as a guarantee of an unchanged rating. If peers improve while a facility’s performance holds steady, its relative position can deteriorate. A useful comparison therefore needs both the facility’s trend and the distribution against which CMS awards points.
What happens when CMS raises the point thresholds at a refresh
The July 2026 refresh made that distinction concrete. CMS raised the total-point thresholds required to earn 2, 3, 4, or 5 QM stars substantially above the January 2025 standards. The Five-Star Technical Users’ Guide, September 2026, says thresholds rise at each refresh by half the average gain in QM scores since the prior period. QSO 19-08-NH codifies that approach. The July change therefore increased the points facilities needed without requiring any deterioration in their own care.
A facility dropping from 5 QM stars to 4 loses eligibility for the one-star upward adjustment to its overall rating. A facility dropping from 2 QM stars to 1 receives a one-star downward penalty on its overall rating. For administrators reviewing the July 2026 results, the relevant question is how the revised thresholds changed the facility’s distance from those consequential boundaries.
Recent measure changes that shift where a facility sits in the national distribution
Threshold increases are not the only source of movement. CMS also respecified measures during 2025–2026, changing what enters the comparison before points are assigned. CMS’s Quality Measures page describes the January 2026 replacement of the MDS-only long-stay antipsychotic measure with a version incorporating Medicare and Medicaid claims and Medicare Advantage encounter data. That change captures antipsychotic use previously absent from MDS reporting. Consequently, the national percentage counted as receiving antipsychotics rises, scoring cut points reset to new deciles, and facilities’ relative positions are recalculated.
In July 2025, CMS added Section GG functional ability variables from the MDS to risk-adjustment models for four claims-based measures and revised thresholds to preserve the distribution while changing individual facility standings. The MDS 3.0 QM User’s Manual v18.0, effective January 1, 2026, also updated applicable risk-adjustment coefficients based on specification changes. The QM page provides the associated errata and files. The definition and adjustment method behind the rate also need to be understood.
Where to find your facility's QM rates and your peers' on Care Compare
The CMS Provider Data Catalog points to Care Compare on medicare.gov as the place where the public can see each nursing home’s QM scores and offers data to download and analyze in bulk. For a practical peer review, the lookup begins with a geographic search, followed by selection of comparable facilities for side-by-side comparison. The review then moves measure by measure. Collection windows must match across the comparison. The catalog lists the current period for every measure, and short-stay and long-stay measures use different windows.
Interpretation requires restraint as well as access. CMS states that QMs are not benchmarks, thresholds, guidelines, or standards of care and are not appropriate for use in a lawsuit. They describe average performance across residents. The guide also identifies a trophy icon for facilities meeting the full risk-based survey qualification criteria, covering approximately 12% of facilities nationwide. First displayed on October 8, 2026, after a one-week delay from September 30, the icon adds a public distinction beside the stars. It requires a separate reading because its eligibility conditions extend beyond QM performance.
What the new risk-based survey designation on Care Compare signals about peer standing
CMS assesses four qualification criteria quarterly, including an overall 5-star rating, accurate and timely data submission, no citations for harm or substandard quality of care in the most recent health inspection, and no recent ownership changes. Meeting the star requirement alone is insufficient. A single harm citation disqualifies a facility, making the designation a more demanding condition to maintain than a current 5-star rating by itself.
The designation also changes how survey resources are allocated. Facilities that qualify have state inspections less often, so staff spend less time on inspections and survey preparation. That is a lighter inspection schedule under continued oversight, with the designation attesting only to the stated qualification criteria. Its public visibility nevertheless changes the comparison for facilities near the overall 5-star boundary. A neighboring facility may have the same star tier plus a designation that reflects its inspection record, how accurately it reports, and whether its ownership has stayed the same. Competitive standing therefore depends on more than the QM points that contribute to the overall rating.
Which QMs carry the most weight when peer gaps are visible
The guide identifies long-stay ADL worsening, antipsychotic use, mobility decline, and claims-based measures for both resident populations among the decile-scored measures with the heaviest influence on QM point totals. These provide the first lens for prioritizing visible gaps. ADL worsening and mobility decline deserve attention because their scoring influence makes differences in functional outcomes consequential for the rating. The national average for long-stay antipsychotic use is approximately 14%, and rates at 5-star facilities are usually well below that level. Ongoing CMS audit activity on schizophrenia coding makes an antipsychotic gap a compliance concern as well as a scoring concern.
CMS citations from early 2026 showed infection prevention lapses in a substantial share of surveys, making infection control the most prevalent deficiency category. That survey pattern gives infection-related performance a place in the review without making a deficiency citation interchangeable with a QM rate. Short-stay rehospitalization and emergency department use need a different response because they are claims-based. Those outcomes require care transitions management and post-acute coordination, so the work arising from a peer gap must fit the measure’s underlying events.
Why a peer rate gap on Care Compare is often a documentation problem before it is a care problem
A published gap does not identify its own cause. OIG found that nursing homes failed to report a large share of falls involving major injury and hospitalization on required assessments. A peer’s low reported fall rate may come from undercoding even when outcomes are no better, which can mislead managers and external reviewers who compare rates. The antipsychotic respecification exposes a related problem by bringing medication use into view that MDS-only reporting missed. In both cases, the reported rate can differ from the clinical activity it is intended to describe.
Check accuracy before redesigning care. For an identified gap, the facility should reconcile MDS coding with the medical record, confirm that assessments and care plans agree with delivered care, and audit the relevant high-risk clinical area. This separates a documentation inconsistency from a true difference in care. The Third Circuit’s July 2026 affirmation of convictions and approximately $15.35 million in restitution against two Pennsylvania nursing-home operators involved falsified staffing records submitted during DOH surveys and illustrates the enforcement stakes of falsified documentation. Accuracy checks are therefore part of compliance work. Their purpose is a faithful record, whether correction improves or worsens the reported rate.
How continuous internal monitoring closes the gap between refreshes
Care Compare reports on care from prior quarters. The catalog shows that some measures use 12-month collection periods and others use shorter MDS-based windows, so a published score alone cannot show what care is like now. Internal monitoring closes that time gap by reviewing resident-level evidence before it reaches a later public refresh. This includes checking past survey findings and plans of correction, auditing residents as well as checking policies, and reviewing high-risk areas such as transfer and discharge documentation.
The necessary signals often already exist in nursing notes. Falls, antipsychotic use, ADL decline, wound progression, and weight loss can be visible in clinical documentation before they enter MDS submissions. AI-enhanced EHR analysis can help find documentation risk and missed coding in real time, including gaps in level of care and authorization readiness. Where nurses already document thoroughly, staff often still need to pull out that information and act on it between submission cycles. Continuous monitoring thus provides an earlier view of local trends, while Care Compare remains the source for the published peer comparison.
A practical workflow for acting on peer QM comparisons without adding nurse documentation burden
For a nursing manager or administrator, the review cycle begins with a quarterly download of facility and peer QM rates from the catalog for the relevant geographic market. Each measure’s collection window should be recorded before rates are compared. For decile-scored measures, a full decile-tier difference needs to be checked, while smaller gaps may be within normal variation. This focuses the review on differences that could have a consequential scoring effect.
Each selected gap then needs a resident-level accuracy audit. MDS coding should be compared with the medical record for the relevant population before the team commits resources to a clinical intervention. Once the cause is clearer, the gap can be mapped to signals already recorded in routine notes, including falls, antipsychotic prescriptions, ADL changes, wound progression, and weight loss. Continuous review of those notes can surface a trend before the next QM refresh. The resulting work should address the identified cause rather than treating every unfavorable rate as evidence of the same problem.
Progress should then be tracked against both the published point thresholds and the raw rate. The guide’s refresh-specific thresholds show how many points separate the facility from the next star tier and support prioritizing measures with the largest potential point gain. For facilities pursuing the risk-based survey designation, the dashboard also needs the full qualification criteria, including reporting accuracy and timeliness, harm citations, overall 5-star status, and recent ownership changes. This extends monitoring across all three rating domains.
The process must use the documentation nurses already write. New assessment forms or parallel documentation systems split staff attention and undermine the compliance discipline the review is meant to support.


