With the much anticipated Advance Notice now in hand, we have our first glimpse into the Centers for Medicare & Medicaid Services (CMS) proposed changes to the 2019 and 2020 Star Ratings. Though CMS hasn’t yet proposed any noteworthy changes (or removed any measures) as part of its “Meaningful Measures” or “Patients Over Paperwork” initiatives, there are plenty of proposals to be carefully considered. Here’s a quick summary of CMS’ proposals impacting the 2019 Star Ratings:
- Measures proposed for addition include: Statin Use in Persons with Diabetes (SUPD; Part D) and Statin Therapy for Patients with Cardiovascular Disease (Part C).
- Measures proposed for removal include: Beneficiary Access and Performance Problems (BAPP) and Reducing the Risk of Falling
- Although CMS confirmed its proposal addressing Star Ratings and Quality Bonus Payments (QBPs) for surviving plans when two or more contracts are consolidated will be addressed in pending rulemaking for Contract Year 2019, CMS reminds plans, for two or more plans combining into a single contract at the start of a contract year, the rating used to determine QBP status for the first year following the consolidation will be the enrollment weighted average of what would have been the QBP ratings of the surviving and consumed contracts using the contract enrollment in November of the year the Star Ratings were released.
Other proposals and program changes include:
- Implementation of a scaled reduction policy for the Part C and Part D Appeals measures when incomplete data or data integrity issues are identified
- Increase in the maximum possible Categorical Adjustment Index (CAI) from 0.09 to 0.14
- Healthcare Effectiveness Data and Information Set (HEDIS®), Consumer Assessment of Healthcare Providers and Systems (CAHPS®), and Health Outcomes Survey (HOS) relief for contracts with more than 25% of its members affected by 2017’s natural disasters
- Removal of contracts with more than 60% of members in areas affected by 2017’s natural disasters from the clustering algorithm used to determine measure cut points
- Careful evaluation of the impact of Value-Based Insurance Design (VBID) to ensure Star Ratings are appropriately assigned to both participating and non-participating plans
Perhaps just as important, or more important, than the technical changes proposed by CMS is the impact CMS’ proposed changes to Health Related Supplemental Benefits could have on a plan’s Star Ratings. In a huge win for beneficiaries and plans, CMS proposes a far broader interpretation of the term “supplemental benefits,” which increases plans’ flexibility to include far more services that increase health, enhance beneficiaries’ quality of life, and improve health outcomes. This flexibility would allow plans to customize supplemental benefit offerings to support their members’ unique combination of social determinants of health. Though CMS has previously not allowed items supporting “daily maintenance” to be offered to members, CMS recognizes the growing body of evidence connecting certain such items with reduced illness, injury, and utilization. Examples provided by CMS (in the Advance Notice and supplemental documents) of benefits plans could consider include such things as non-skilled in-home supports, fall prevention devices, portable wheelchair ramps, other assistive devices, etc.
Although we are only one month into the measurement period that will drive the 2020 Star Ratings, CMS has indicated the following 2020 Star Ratings program changes are under consideration:
- New hypertension treatment guidelines lowering the criteria used to define high blood pressure are being evaluated by the National Committee for Quality Assurance (NCQA) for application in HEDIS® 2019 to the Controlling Blood Pressure measure. NCQA is also using this opportunity to explore additional measure adjustments. Because this change will expand the denominator, preparations should be made for the possibility Controlling Blood Pressure may be temporarily retired to the Display Page for the 2020 Ratings.
- NCQA is evaluating enhanced measure exclusions for persons with certain advanced illness, recognizing certain HEDIS® measures may not be clinically appropriate for all members, which could be incorporated into HEDIS® 2019. This could support more robust person-centered care efforts.
- Pharmacy Quality Alliance (PQA) has indicated it will recommend all three Medication Adherence measures be risk adjusted for various sociodemographic characteristics beginning with the 2018 calculations; once complete (expected in early 2019), CMS will determine how to implement within the Star Ratings program.
- CMS’ previous plans to adjust the Medicare Plan Finder (MPF) Price Accuracy measure will be implemented through the Display Page for the 2020 and 2021 ratings, and CMS seeks feedback on leaving the current MPF Price Accuracy measure “as is” until the new modified measure takes effect in the 2022 ratings.
CMS has also presented a broad array of new measures under consideration for potential addition in 2021 and beyond. After the 2019 Call Letter is finalized, CMS plans to establish a Technical Expert Panel (TEP) comprised of representatives across stakeholder groups to obtain feedback on the Star Ratings framework, topic areas, methodology, and operational measures. Since no significant changes were proposed to remove “topped out” measures or to support Administrator Verma’s “Patients Over Paperwork” or “Meaningful Measures” vision, careful attention should be paid to the work of this TEP as it will likely serve as CMS’ sounding board for such program changes.
For more information regarding the impact of these potential program changes on your organization, contact me today at firstname.lastname@example.org.
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