The answer is yes, but not in the way that you might think. QIS provides a critical benchmark against which all nursing homes should be compared. This benchmark is the continuous quality improvement process that QIS dictates.

A benchmark is a standard, or yardstick, against which one can compare oneself, and so it can be a process. And the benchmark in this case is the process of continuously improving quality based on the full range of Quality of Care and Life Indicators (QCLIs) in QIS.

Because QIS is a process, the benchmark that it sets is a process benchmark. That process is for nursing centers to continuously conduct quality assessments using rigorous methods and to improve their performance. This process requires attention to the wide array of QIS measures, from interviews with residents, families, and staff to observations and record reviews.

Some may contend that the QIS thresholds are the numerical QIS benchmarks that one should strive to achieve. It is true that these QCLIs represent the translation of the legal language in the regulations of the Omnibus Budget Reconciliation Act of 1987 into measurable constructs and questions: They provide the most comprehensive numerically defined set of quality metrics available.

But while the threshold rates offer an absolute standard—not a relative standard based on a group of peers—they only represent the minimum standards necessary to be in compliance with the regulations.
Not a resounding benchmark! It is hard to argue that one should strive for only minimum compliance with the regulations. But there is no higher benchmark in the QIS process or elsewhere to indicate what providers should strive to achieve, and no benchmarks for the “acceptable” percentage of negative responses for the individual questions and QCLIs. There is not a value for each indicator that one can claim represents “good enough quality.”

The other extreme, of course, is zero tolerance. And that is not reasonable to expect to achieve in every situation, such as pain management, choices, and certain infections. For example, some residents may choose to experience some pain in order to avoid sedation from heavy doses of pain meds.

So what do you compare your performance to in order to determine where you are relative to a benchmark?

The answer is relatively easy: Your benchmark is to continuously improve on your current performance. At no point will you reach an acceptable rate of resident quality concerns—there is always room for improvement. And when you improve your current rate of performance on a QCLI or question, then your benchmark should be the next measurable level for that QCLI or the questions underlying it.


This is the QIS benchmark.