December 15, 2025

The 2026 CMS Five Star Rating Rule: How the CMS Five Star Rating Can Create Long-Term Risk for Hospitals 

Beginning in 2026, updates to the CMS Five Star Rating methodology introduce a far more punitive and long-term consequence for hospitals with lower safety performance. Any hospital that falls into the bottom quartile for safety will be blocked from achieving a 5-Star rating and may be automatically downgraded to 1-Star in future cycles—even if clinical quality improves later. 

 

This shift transforms what once felt like an annual performance challenge into a multi-year financial and reputational constraint. 

 

Several components of the CMS Five Star Rating are influenced by safety-related measures, including patient safety indicators, which play a role in how hospitals are evaluated across reporting periods. 


How the CMS Five Star Rating Methodology Changes Under the 2026 Rule 

Under the revised CMS Five Star Rating model, safety performance becomes a gating mechanism for a hospital’s overall rating. Falling into the bottom quartile no longer affects only the current reporting year. Instead, the designation limits upward movement in subsequent cycles, making it more difficult for hospitals to recover once they fall behind. 

 

Even with strong clinical care, the star rating may not immediately reflect improvements due to historical weighting and lookback periods used in CMS calculations. This lag increases the risk that lower ratings will persist long after care delivery has improved. 

 

How Documentation Issues Affect CMS Medicare Star Ratings

Safety quartile placement under the CMS Five Star Rating program is influenced not only by clinical outcomes but also by how accurate events are captured in documentation. Inconsistencies in cataloging clinical data, present-on-admission (POA) designations, or coding detail can inadvertently elevate safety event counts. 

 

Even small inaccuracies may create a misleading representation of patient safety performance—pushing hospitals into the bottom quartile and triggering the long-term downgrade risk outlined in the 2026 rule. Proactive alignment between documentation and clinical activity is now one of the most controllable ways to avoid unintended rating impact for your Stars rating. 


The Long-Term Implications of Low Hospital Star

Ratings CMS Reports 

A 1-Star designation affects far more than year-end quality reporting. Because the revised CMS Five Star Rating model limits upward mobility over multiple cycles, the consequences can compound year after year. 

 

Hospitals may experience: 

  • Contracting & Revenue Limitations: Reduced leverage in payer negotiations and limited inclusion in preferred networks. 
  • Volume & Market Share Declines: Employers, consumers, and digital navigation tools increasingly direct patients toward higher-rated hospitals. 
  • Margin Pressure: A weaker payer mix, higher underpayments, and diminished leverage in billing disputes. 
  • Growth & Valuation Challenges: Lower ratings influence partnerships, employer agreements, affiliations, and investment confidence. 
  • Workforce Strain: Physicians and APPs often avoid joining hospitals with persistent 1-Star ratings, increasing recruitment and retention costs. 

 

Financial impact may occur immediately, but recovery within CMS reporting is gradual—resulting in long-term consequences even after performance improves. 


How the Star Rating Program Creates Long-Term Performance Challenges

Once a hospital falls into the bottom safety quartile, the pathway back to a higher standing within the star rating program becomes slow and difficult. Because CMS blends historical data with current performance, real-time improvements rarely translate into immediate rating changes. This lag can extend reputational and financial challenges for years beyond the initial downgrade—long after underlying issues have been resolved. 

 

To prepare for the 2026 rule, hospitals should complete a focused assessment to understand where safety event inflation or documentation inconsistencies may be influencing their performance within the star rating program. An effective readiness assessment should: 

 

  • Quantify potential downgrade exposure in financial terms 
  • Pinpoint documentation patterns that may be affecting safety event reporting 
  • Identify opportunities to reduce downstream financial risk 
  • Establish a roadmap aligned to the 2026 CMS rating methodology 

 

Taking these steps now can help hospitals strengthen their safety profile and prevent prolonged rating challenges under the evolving star rating program framework. 


The Bottom Line 

The 2026 CMS Five Star Rating rule fundamentally changes how long hospitals may feel the effects of a single year of poor performance. Even hospitals with high clinical quality may be at risk if documentation doesn’t accurately reflect patient care. 

 

Now is the time to reinforce documentation accuracy, verify how safety events are captured, and address any preventable factors that could affect safety quartile placement—before a downgrade shapes financial and operational outcomes for years to come. 




Linda Wiseman, BSN, RN, CCDS, Director, CDI Services at UASI

 Linda Wiseman, BSN, RN, CCDS 

Director, CDI Services at UASI


References & Additional CMS Resources

Centers for Medicare & Medicaid Services. (2024). Overall hospital quality star ratings methodology. Available at: https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/hospital-quality-initiatives/overall-hospital-quality-star-rating 

 

Centers for Medicare & Medicaid Services. (2024). Technical notes for the overall hospital quality star rating. Available at: 
https://www.cms.gov/files/document/overall-star-rating-methodology.pdf
 

 

Centers for Medicare & Medicaid Services. (2024). Medicare program; hospital inpatient prospective payment systems for acute care hospitals and the long-term care hospital prospective payment system and policy changesFederal Register. Available at: 
https://www.federalregister.gov
 

 

for Medicare & Medicaid Services. (2024). Present on admission (POA) indicator reporting. Available at: 
https://www.cms.gov/medicare/medicare-fee-service-payment/hospitalacqcond/poa
 

MRI brain scans illustrating symptoms of PRES with title text overlay.
December 9, 2025
Learn the symptoms of PRES, key treatment considerations, ICD-10-CM code I67.83, and documentation tips for CDI and accurate DRG assignment.
Microscopic immune cells interacting in cellular environment, illustrating immune effector activity
By Katie Curry December 1, 2025
Understand ICANS documentation and ICD-10 coding with guidance on the ICANS grading system, ICE score, clinical indicators, and CAR T-cell neurotoxicity.
Fingerstick blood glucose test being performed, illustrating screening and monitoring practices for gestational diabetes.
By Katie Curry November 3, 2025
Gestational Diabetes
Clinician pointing to anatomical kidney model illustrating acute kidney injury.
By Katie Curry October 20, 2025
Learn how to identify, document, and code acute kidney injury (AKI), including diagnostic criteria, staging, ICD-10-CM guidance, and CDI query considerations.
Blurred hospital scene symbolizing CDI review of firearm injury intent reporting.
By Katie Curry September 30, 2025
Learn how firearm injury intent is documented and reported in ICD-10-CM, including intent categories, external cause codes, and documentation considerations.
Title image for the ventricular standstill clinical documentation and coding overview
By Katie Curry September 22, 2025
Learn how ventricular standstill is documented and coded, including clinical indicators, ICD-10-CM guidance, and common documentation considerations.
Title image for neurostorming (PSH) documentation and coding
By Katie Curry September 7, 2025
Learn how neurostorming, also known as paroxysmal sympathetic hyperactivity (PSH), is documented and coded using ICD-10-CM guidance.
By Katie Curry August 7, 2025
Background: With the 2026 IPPS Proposed Final Rule comes a new diabetes code, E11.A, Type II diabetes mellitus without complications in remission. This is a non-CC/MCC and is assigned to MDC 10. ICD-10-CM Official Guidelines for Coding and Reporting 2026: Section I.C.4.a.1.(b) - “Code E11.A, Type 2 diabetes mellitus without complications in remission, is assigned based on provider documentation that the diabetes mellitus is in remission. If the documentation is unclear as to whether the Type 2 diabetes mellitus has achieved remission, the provider should be queried. For example, the term “resolved” is not synonymous with remission.” Clinical criteria for diabetes in remission: Note* - Remission does not mean cure. Ongoing monitoring is essential as relapse is possible. 1. Prior Diagnosis of Diabetes Mellitus Documented history of type 2 diabetes mellitus, diagnosed using standard criteria: HbA1c ≥ 6.5% Fasting plasma glucose ≥ 126 mg/dL 2-hour plasma glucose ≥ 200 mg/dL during an OGTT Random plasma glucose ≥ 200 mg/dL with classic symptoms 2. Normal or Controlled Glucose Levels Without Medications The patient is not taking any antidiabetic medications (oral agents, insulin, or non-insulin injectables). Glycemic control is sustained through lifestyle modifications, such as diet and exercise. HbA1c < 6.5%, and sometimes < 6.0%, on two occasions at least 6 months apart without pharmacologic therapy. 3. Duration of Remission Partial remission: HbA1c < 6.5% and fasting glucose 100–125 mg/dL for at least 1 year without medications. Complete remission: HbA1c in the normal range (<5.7%) and fasting glucose <100 mg/dL for at least 1 year. Prolonged remission: Complete remission lasting ≥5 years. 4. Documentation Must Include Clear statement that diabetes is in remission or resolution. No current use of diabetes medications. Current HbA1c values. Lifestyle interventions being used. Absence of ongoing diabetic complications (or if present, they are noted as sequelae) 5. What about Type I diabetes? Is remission associated? “Honeymoon Phase” vs. Remission Some individuals newly diagnosed with type 1 diabetes may experience a "honeymoon phase": This is a temporary period (weeks to months) where insulin needs to decrease and blood glucose levels may normalize. However, this is not true remission, as the autoimmune process continues and insulin dependence eventually returns. Clinical Scenario Dr. Doctor, Documentation in your visit note indicates the patient has a documented history of type 2 diabetes mellitus, but current labs show: HbA1c: 5.6% No diabetes medications (e.g., insulin, metformin) currently prescribed Patient reports lifestyle changes (e.g., diet and weight loss) No hyperglycemia documented during this admission or recent visits Query Based on the clinical picture, can you please clarify the patient’s current diabetic status? ☐ Type 2 diabetes mellitus – continue to document and treat as active ☐ History of type 2 diabetes mellitus, currently in remission (no medications, normal glucose values) ☐ Other: ________________
By Katie Curry July 9, 2025
Definition: Neonatal encephalopathy (NE) is a clinically defined syndrome of disturbed neurologic function in the earliest days of life in a term or late preterm infant, manifested by difficulty with initiating and maintaining respiration, depression of tone and reflexes, subnormal level of consciousness, and often seizures. Clinical presentation: Low APGAR scores and/or weak/absent cry in the delivery room. Hyperalert, irritable, lethargic, obtunded. Decreased spontaneous movements, poor tone, blunted or absent primitive reflexes, seizure activity. Breathing and/or feeding difficulties. Documentation Tips: The CDS should review to identify the underlying etiology . (e.g., hypoxic-ischemic event, infection, metabolic disorder). Review clinical indicators that may indicate associated conditions , such as seizures, abnormal imaging, acidosis, or multi-organ dysfunction. Review the documentation for the timing of onset (e.g., at birth, delayed). Common clinical indicators include low APGAR scores, need for resuscitation, abnormal tone, or altered level of consciousness.  ICD-10-CM Coding: P91.811, Neonatal encephalopathy in diseases classified elsewhere P91.819, Neonatal encephalopathy, unspecified Use when the type or etiology of NE is not documented Query Example: To the Attending Neonatologist: Documentation in the medical record indicates the newborn infant delivered from mother with placental abruption demonstrates seizures, abnormal muscle tone, low APGAR scores, and required resuscitation at birth. Imaging showed evidence of cerebral edema. The diagnosis of “neonatal encephalopathy” was documented in the assessment. Query: Based on the clinical indicators, can you clarify the type and cause of the encephalopathy in this newborn? Please select the most appropriate option below or specify another diagnosis: Neonatal encephalopathy due to Hypoxic-ischemic encephalopathy (HIE) Neonatal encephalopathy due to other etiology (please specify) Other (please specify): __________
By Katie Curry May 12, 2025
Definition: Tumor lysis syndrome (TLS) is an oncologic emergency caused by massive tumor cell lysis and the release of large amounts of potassium, phosphate, and uric acid into the systemic circulation. Deposition of uric acid and/or calcium phosphate crystals in the renal tubules can result in acute kidney injury.
Show More