Backpedaling from Better Quality Measurement?

Few would argue Star Ratings is overdue for evolution. With almost 50 Star Ratings measures, many having been in the program for years, and Secretary Price and Administrator Verma both positioned to make their mark on Medicare, change is imminent. But change is also difficult, a fact acknowledged by the Centers for Medicare & Medicaid Services (CMS) when it reversed course in the 2018 Call Letter on several proposals included in the Advance Notice.

CMS backed off on proposals to more heavily weight Care Coordination and Post-Discharge Medication Reconciliation measures beginning in the 2019 ratings and also reversed course on proposed changes to the Beneficiary Access and Performance Problems measure and addition of a new Non-recommended PSA-based Screening in Older Men measure.

Though many plans undoubtedly breathed a sigh of relief when CMS backpedaled from some of these proposals, the question remains: Where do we go from here? And what can be done while we await technical updates in August? Here are a few suggestions:

  • Analyze, analyze, analyze! Math matters in Star Ratings. With limited budgets and 50 measures in the program, meaningful investments must be made where it matters most, accounting for potential program changes. As Secretary Price works to reduce regulatory burden and improve physicians’ experience with Medicare, we must analyze and predict the impact of potential changes we may see in his pursuit of this vision. Evaluating the impact of potential changes on Star Ratings and planning investments in response to these changes will require lots of number crunching!
  • Predict and Prepare.  With the numerous measure additions and removals on the horizon during 2018 and 2019, combined with CMS’ signal “topped out” measures may be removed as new measures are added, “Star Ratings math” has never been more important. Predict performance under multiple Star Ratings scenarios to manage C-Suite expectations and secure needed resources, and prepare for the operational changes needed for success in new areas not only to earn quality bonuses but also to achieve the broader return on investment (ROI) of strong Star Ratings.
  • Educate leaders and staff regarding the dynamic and fluid Star Ratings environment. The C-Suite has always expected a Star Ratings dashboard that precisely predicts whether the plan will hit 4 stars. With the limited changes in recent years, this has not been as challenging as it used to be. And for the few perpetually high- and low-performing plans, the current fluidity may not impact dashboarding and predictions. But for most plans, the scope of proposed changes will influence Star Ratings. Educate leaders and managers on the need for, and nature of, preemptive evolution, and manage leadership expectations by evaluating multiple Star Ratings scenarios to best avoid Star Ratings surprises after CMS finalizes program changes.
  • Embrace display and other measures under consideration by CMS without waiting on CMS to decide whether they will be Star Ratings measures. How prevalent are the conditions impacted by potential new measures among your membership? Does your performance on these measures indicate unmet health needs or challenging issues in your service area? Even if not adopted as Star Ratings measures, improving under-performing measures can create ROI by improving medical trend, making care more efficient and effective, and better serving your members’ health needs. Embrace these measures and begin developing and implementing strategies to improve performance, as success in new areas generally requires at least 18 to 24 months to realize.
  • Support your providers. Know the measures your providers have chosen to focus on in Medicare Fee-for-Service under the Quality Payment Program (QPP)/Medicare Access and CHIP Reauthorization Act (MACRA), and help your Provider Relations team tailor your Star Ratings approach in a way that is efficient and seamless for your providers. Share your expertise in population health management, proactive patient identification for interventions, and patient engagement to help them succeed in the QPP and align your efforts with theirs wherever possible. Star Ratings success without provider engagement is costly and challenging, and some of your Star Ratings “asks” in the coming months will be difficult, so supporting providers for shared success will endear you to your provider network and set you up for success.

And by all means – remember, CMS can retrospectively change the Star Ratings program, even adding or removing measures, without socializing such changes in advance.

Whether you need Star Ratings-centric analytics to support your Star Ratings program, expert review of your Star Ratings work plan to identify strategies and tactics to succeed through Star Ratings evolution, or additional expert bandwidth to help execute your work plan, we can help. For questions or additional information about how Gorman Health Group can support your Star Ratings program, please contact me directly at msmith@gormanhealthgroup.com.

 

Resources:

Gorman Health Group’s Summary and Analysis of the Final Rate Announcement and 2018 Call Letter for Medicare Advantage and Part D is now available. Download now >> 

Melissa Smith
Melissa Smith

Melissa Smith is Senior Vice President of Stars & Strategy at Gorman Health Group, LLC (GHG). Melissa’s team helps clients improve performance within quality ratings systems such as Star Ratings, improve health outcomes and the member experience, evaluate market dynamics and opportunities, optimize distribution channels, and supports our clients’ strategic planning needs.

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