Hospital star ratings in ads: using the CMS Overall Star Rating and quality scores accurately

A five star rating from Medicare is one of the strongest lines a hospital can put in an ad, and one of the easiest to get wrong. The rating has a name, a publisher, a year and a method. It measures some things and not others, and the method itself changes for 2026 and again for 2027. This guide explains how CMS builds the Overall Hospital Quality Star Rating, how the other scores on Care Compare differ from it, and how to word an ad, a billboard or a web page so the claim says exactly what the source says.

Two related topics have their own guides and are not repeated here. Private awards, paid badges, rankings from publishers and review stars are covered in our guide to top doctor awards, paid badges and star ratings. The wider set of hospital marketing rules, from tracking technologies to physician ownership disclosures, is in our hospital marketing compliance guide. This guide covers government quality ratings and scores. For accreditation, payer programs and state designations, see our guide to center of excellence and designation claims. Patient satisfaction figures from your own surveys are covered in our guide to patient satisfaction survey results in ads.

What the Overall Star Rating is

The federal rule that sets up the rating, 42 CFR 412.190, describes it as a summary of certain publicly reported hospital measure data for the benefit of patients, consumers and hospitals. It is published on Care Compare on Medicare.gov and gives a hospital between one and five stars. CMS first published it in July 2016 on the old Hospital Compare website, according to the CMS public reporting page, and codified the method in the CY 2021 outpatient payment rule.

The measures come from five CMS hospital quality programs named in 412.190(b)(1): the Hospital Inpatient Quality Reporting Program, the Hospital-Acquired Condition Reduction Program, the Hospital Value-Based Purchasing Program, the Hospital Readmissions Reduction Program and the Hospital Outpatient Quality Reporting Program. Hospitals paid under the Medicare inpatient prospective payment system, called subsection (d) hospitals, are included when they are subject to those programs and their data is publicly reported on a CMS website. Critical access hospitals are included only if they choose to submit and publicly report the measures, and the CMS page says Veterans Health Administration hospitals became eligible for ratings in 2023.

Three facts about timing matter for advertising. Under 412.190(c), the rating is published once a year, using data publicly reported on Care Compare from a quarter within the previous 12 months. Under 412.190(e), hospitals get at least 30 days to preview their rating before it is published. And under 412.190(f), a critical access hospital may ask CMS to withhold its rating from publication if it asks during the preview period. A rating is tied to one publication, and the next publication replaces it.

How CMS turns measures into stars

The method in 412.190(d) runs in steps. CMS starts with the measures reported on Care Compare and drops some of them, such as measures that 100 hospitals or fewer report and measures where it is unclear whether a higher or lower score is better. Each remaining measure is converted to a standard score so that a higher score means better performance for every measure, and the measures are sorted into five groups: Mortality, Safety of Care, Readmission, Patient Experience, and Timely and Effective Care.

Each group gets a score from a simple average of its measures. The group scores are then weighted and added together into a hospital summary score. Mortality, Safety of Care, Readmission and Patient Experience carry equal weight, and Timely and Effective Care carries a smaller weight. When a hospital has too few cases to report enough measures in a group, CMS may spread that group’s weight across the groups it does report.

To get a rating at all, a hospital must report at least three measures in at least three groups, and one of those groups must be Mortality or Safety of Care. Hospitals are then sorted into three peer groups by the number of measure groups in which they report three or more measures: three, four or five. Within each peer group, a clustering method assigns one to five stars. In plain terms, the stars place a hospital among hospitals that reported a similar number of measure groups, using the measures each one had.

That last point is worth reading twice before writing copy. Commenters on the CY 2026 rule raised concerns that hospitals may be evaluated on different subsets of measures, and that ratings for large and small hospitals may not compare cleanly. CMS kept the peer group approach. For an advertiser, the safe reading is that a star rating describes how a hospital did on the measures in the rating, compared with its peer group, in one publication year. It is not a ranking of every hospital in a city.

The Safety of Care change for 2026 and 2027

The CY 2026 outpatient payment final rule, published November 25, 2025, changed the method to give the Safety of Care group more influence. CMS wrote that patient safety is a cornerstone of healthcare delivery. The stated aim, now in 412.190(a)(2), is to address hospitals receiving a high star rating despite performance in the lowest quartile of the Safety of Care group. The rule was finalized without modification and is now in 412.190(d)(9).

It works in two stages, and both apply only to hospitals with at least three Safety of Care measures. For the 2026 rating, a hospital that the clustering step would place at five stars, but whose Safety of Care score is in the lowest quartile, is capped at four stars. For the 2027 rating and later years, any hospital in the lowest Safety of Care quartile loses one star from whatever the clustering step assigned, so two becomes one, three becomes two, four becomes three and five becomes four.

For marketing, this means a rating from before 2026, a 2026 rating and a 2027 rating are produced under different rules. An ad that says a hospital “has been a five star hospital for three years” joins ratings built under different methods, and it should say which years and which ratings it means. When the 2027 rating publishes, every ad, page and listing that quotes the 2026 rating needs a check against the new one.

HCAHPS stars and the other scores on Care Compare

The Overall Star Rating is not the only star on a hospital’s Care Compare profile. The CMS public reporting page says CMS added HCAHPS Star Ratings in 2015. HCAHPS is the Hospital Consumer Assessment of Healthcare Providers and Systems survey, which the same page describes as a standardized instrument and data collection method for measuring patients’ perspectives on hospital care. An HCAHPS star rating reports on patient experience. An ad that calls it a quality rating, or puts it next to the words “five star hospital” without naming it, mixes up two different ratings.

Care Compare also reports individual measures. The CMS page says CMS reports over 150 hospital quality measures on Care Compare and the Provider Data Catalog, and it describes a Birthing-Friendly icon shown when a hospital meets CMS criteria for that designation. A single measure result, such as an infection rate or a readmission rate, is a measure, not a rating. If an ad quotes one, it should name the measure as CMS names it, give the reporting period shown on Care Compare and avoid turning it into a broader claim about the hospital.

Illustration: a hospital’s Care Compare profile shows a [number] star Overall Star Rating, a [number] star HCAHPS star rating and a measure result for [measure name] for the period [period]. Each of those is a separate claim with its own label and period. An ad can quote one of them accurately. It cannot fold them into one line that says the hospital is rated [number] stars for quality and patient experience.

Star claims are objective claims under the FTC Act

The FTC Act makes deceptive acts or practices in commerce unlawful (15 U.S.C. 45) and bars false advertisements likely to induce the purchase of services (15 U.S.C. 52). The FTC Policy Statement on Deception looks at whether a representation or omission is likely to mislead a consumer acting reasonably, and it judges the net impression of the ad rather than one line in isolation. A star rating quoted without its name and year can leave a net impression the source does not support.

The FTC Policy Statement Regarding Advertising Substantiation says that when an ad expressly or impliedly refers to a level of support, the advertiser is expected to have at least the advertised level of substantiation. A line such as “rated five stars by Medicare” tells the reader the claim comes from a government rating. The hospital needs the matching rating, from the publication the ad refers to, on file before the ad runs.

Comparisons need the same care. “The highest rated hospital in [area]” is a claim about every hospital in that area, not only about the advertiser. To support it, the hospital needs the ratings of every hospital in the stated area from the same publication, a clear definition of the area, and a plan for what happens when a competitor’s rating changes. If several hospitals share the top rating, “highest rated” on its own leaves a different net impression than “one of [number] hospitals in [area] rated [number] stars”.

Do not suggest CMS endorses the hospital

Quoting a CMS rating is not the same as being approved by CMS. Under 42 U.S.C. 1320b-10, no person may use words such as “Medicare” or “Centers for Medicare & Medicaid Services”, the letters “CMS” or “HHS”, or a CMS or HHS symbol or emblem in an advertisement in a manner that conveys, or reasonably could be read as conveying, the false impression that the item is approved, endorsed or authorized by CMS or HHS, or that the advertiser has a connection with them. The statute adds that this is judged without regard to any disclaimer of affiliation with the government.

Practical wording follows from that. “Medicare-approved hospital”, “CMS certified five star” and a badge that copies the look of a government seal all go beyond what a rating says. A plain attribution, such as “[number] stars in the [year] Overall Hospital Quality Star Rating on Care Compare on Medicare.gov”, names the source without implying a relationship. Our guide to marketing to Medicare patients covers the name and symbol rule in more detail.

Star ratings in Google Ads

The Google Ads Misrepresentation policy does not allow inaccurate claims, or claims that entice the user with an improbable result as the likely outcome a user can expect. A star claim in an ad that is out of date, mislabels which rating it is, or stretches a hospital level rating into a promise about one surgeon or one service fails the first part of that test.

The landing page is where a reader checks the claim. It should show the same rating the ad quotes, the year of the publication, the name of the rating as CMS uses it, and a link to the hospital’s Care Compare profile so the reader can see the source. When the ad and the page disagree, the ad is the claim that has to be fixed or paused.

Transplant programs have their own outcome reports and approval rules. Our guide to transplant center marketing covers SRTR survival figures, wait-time claims and living donor recruitment.

What a star rating does not tell patients

The Overall Star Rating summarizes certain measures for a hospital. It is not a rating of a hospital’s individual departments, physicians, outpatient clinics or affiliated practices. The rule does not rate those, and an ad should not imply that it does.

Illustration: a physician practice owned by a health system wants to advertise that it is “part of a five star hospital”. The rating belongs to the hospital, under its own CMS certification, for one publication year. The practice can state the relationship and quote the hospital’s rating with its name and year. It should not say or show that the practice itself, or its physicians, are rated five stars.

Ratings also leave patients without some answers they need. A star rating does not say whether a hospital offers a particular service, accepts a particular plan, or has wait times that suit them. Ads that use a rating to answer those questions are making claims the rating does not cover.

Wording that matches the source

Here is how we approach the line itself, before any design work.

• Name the rating as CMS names it: the Overall Hospital Quality Star Rating, or the HCAHPS star rating, not a generic “quality rating”.
• Give the publication year and the publisher: Care Compare on Medicare.gov.
• Link to the hospital’s Care Compare profile on the landing page and on any web page that quotes the rating.
• Keep the rating at the hospital level. Do not attach it to a department, a doctor or an affiliated practice as if it were theirs.
• Do not use CMS or HHS logos or designs that look like a government seal.
• Back every comparative claim with the same publication’s ratings for every hospital in the stated area.
• Set a date to check every ad, page, listing and printed piece when the next rating publishes.

Illustration: two ways to advertise a star rating

Illustration: a hospital receives a [number] star Overall Star Rating in the [year] publication. Version one runs a search ad that says “Medicare’s top rated hospital” with a gold seal, links to a home page that does not mention the rating, and keeps running after the next publication. The ad implies a CMS endorsement, claims a ranking the rating does not make, and has no date or source a reader can check.

Illustration: version two runs “Rated [number] stars in the [year] Overall Hospital Quality Star Rating on Medicare.gov” and links to a page that repeats the rating, explains in one sentence what it measures, links to the Care Compare profile and shows the date the page was last checked. A calendar reminder tied to the annual publication triggers a review of the ad, the page and the hospital’s listings. The claim says no more than the source.

Checklist

• Which rating is quoted: Overall Star Rating, HCAHPS star rating or a single measure result?
• Is the publication year in the ad, and does it match the current Care Compare profile?
• Does the landing page repeat the rating, name it and link to Care Compare?
• Does any wording or image suggest CMS or HHS approval, endorsement or a connection?
• Is the rating kept at the hospital level, with no transfer to departments, doctors or affiliated practices?
• Is every comparison backed by the same publication’s ratings for every hospital in the stated area?
• Is there a review date for the next annual publication, including the 2027 Safety of Care change?

How we help

We build websites, local search, Google Ads and AI front desk tools for independent practices and health businesses. For quality ratings, that means a website with a ratings page that names each rating, its year and its source, ads whose wording matches that page, listings that are checked when a new rating publishes, and intake flows that do not lean on ratings to promise outcomes. We do not decide what your rating means legally; your counsel does. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it. We are not a healthcare provider and we do not give legal or medical advice. We do not sell lead lists and we do not pay for referrals. For the wider rules, see our healthcare marketing rules hub.

Sources

• 42 CFR 412.190: Overall Hospital Quality Star Rating
• CMS CY 2026 OPPS/ASC final rule, 90 FR 53448 (November 25, 2025), section XVIII on the Overall Hospital Quality Star Rating (PDF)
• CMS: Hospital Quality Initiative Public Reporting
• 15 U.S.C. 45: Unfair methods of competition and unfair or deceptive acts or practices
• 15 U.S.C. 52: Dissemination of false advertisements
• 42 U.S.C. 1320b-10: Prohibition of misuse of symbols, emblems, or names
• FTC Policy Statement on Deception
• FTC Policy Statement Regarding Advertising Substantiation
• Google Ads policy: Misrepresentation

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