GHG Responds to Common Questions About CMS’ Proposed Star Ratings Changes

Since COVID-19 surfaced, GHG has been working to answer any and all questions that come our way, in an attempt to provide guidance in a time of great uncertainty. Information is changing every day with new announcements from the Centers for Medicare & Medicaid Services (CMS) and Trump Administration, and Medicare Star Ratings are no exception.

In fact, on March 30, 2020, CMS announced a variety of temporary regulatory waivers and new rules to help the entire U.S. healthcare system continue operating through President Trump’s COVID-19 emergency declaration. A summary of the changes relevant to Stars can be found in our recent blog post.

With this new information, our experts answered many of the frequently asked questions we’ve received over the last few weeks. Read more below.

Does GHG expect CMS to make any more changes to Medicare Advantage Star Ratings to address the COVID-19 crisis?

CMS is allowing a 60-day comment period (through June 1) regarding the proposed adjustments. We expect many plans who invested heavily in their 2019 activities and programs to protest the announced changes and request some additional changes and relief. 

Will the HEDIS® submission in 2020 for services rendered in measurement year 2019 be affected?

Yes. CMS will no longer require Medicare Advantage (MA) plans to submit HEDIS® measure data for measurement year 2019. CMS will use plans’ 2020 measure-level ratings for all HEDIS® measures in the 2021 ratings.

Will CMS or NCQA make any changes to HEDIS® measures for the 2020 measurement year?

No changes to HEDIS® measures have been announced by either CMS or NCQA relative to measurement year 2020. However, CMS has delayed application of the previously-announced cutpoint guardrails to allow 2022 cutpoints to decrease by >5% in the event that national trends on specific measures decrease dramatically due to the crisis.

Has CMS or NCQA provided any insights into the CAHPS surveys currently in the field or the HOS surveys scheduled for this spring?

Yes. CMS will no longer require MA plans to submit CAHPS survey data for measurement year 2019 (which is being collected in spring 2020). CMS will use plans’ 2020 measure-level ratings for all CAHPS measures in the 2021 ratings.

CMS is delaying the survey administration period for the 2020 HOS from spring to late summer. In the event the public health emergency prevents the surveys from being performed later this year, CMS will use plans’ 2021 ratings for HOS measures as their 2022 measure-level ratings.

Is CMS applying the current Major Disaster policy as it has applied in previous years?

No. CMS has acknowledged that this public health emergency transcends the scale for which the current policy was intended.

Normally during this period of the year, my organization focuses mostly on closing preventive screening measure gaps by scheduling appointments for members. This year, we’re forced to tell members to cancel all non-essential appointments and stay home to stay safe. How will this impact Star Ratings? Since we obviously are going to struggle to do any traditional gap closure work for the time being, where should we focus our efforts?

Almost every plan is experiencing these same challenges, and many/most providers are cancelling all non-essential appointments (even for needed chronic care) as directed by CMS. It is vital to acknowledge that most of these types of efforts are focused towards 1x-weighted process measures—and all plans will be struggling to maintain past performance levels on these measures. To account for the challenges all plans will have on certain measures, CMS has delayed implementation of the cutpoint guardrails to MY2021/SY2023 to allow cutpoints to decrease by >5% if needed due to challenges such as this. We strongly suggest plans deprioritize certain process measures (at least somewhat) to focus on CAHPS, outcomes, and other measures with higher weights during the remainder of 2020. 

Are the changes to Star Ratings minimal or substantial?

The changes to 2021 and 2022 Star Ratings are very substantial. Stars staff should immediately escalate the impact to plan leaders.

My Stars team is comfortable operating in a “status quo” environment where measures are long-known, and best practices and tactics are fairly similar across plans. How do I help them succeed in this environment of uncertainty and crisis?

This sentiment quite common, particularly since we’ve had so few new or adjusted measures in recent years. Now is a great time to help augment capacity with Stars experts who have had exposure to other operating circumstances—and ideally who were part of the early years of Star Ratings where the entire industry faced similar unknowns. (Yes, GHG can help with this—it’s what we love doing most!)

My plan started operations in 2019, and CMS’ current Major Disaster policy does not appear to offer me any relief. Am I misreading the technical guidance?

The changes announced by CMS allow new plans to retain their “new plan designation” for one additional year to get through this crisis.

Will NCQA allow in-home diabetic monitoring test results as numerator events for measurement year 2020?

At present, no such change has been announced by NCQA to allow this. NCQA will publish the HEDIS® measure technical specifications in July, which we will need to watch closely for any such change. Because the new specifications for Controlling Blood Pressure do consider certain results captured through in-home monitoring as numerator events, and in response to the aggressive push in 2020 by CMS and providers to avoid in-person clinical care wherever possible (including appointments for treatment of chronic conditions), it is possible that NCQA may consider such a change, which would not represent a substantive measure change for Star Ratings purposes. We encourage health plans to expand their efforts to capture in-home A1c test results using the same measurement criteria/approach already allowed for the Controlling Blood Pressure measure.

Many plans have been achieving strong ratings on the Osteoporosis Management in Women with a Fracture measure by obtaining an order from a physician and then coordinating an in-home service to perform a bone density screening. Both elements of this best practice are difficult to perform under the current clinical and social environment created by COVID-19. Will CMS make any changes to account for this?

Many plans who perform well on this measure will face the same changes. Although we do not expect any technical measure changes in response to this matter, CMS has delayed the implementation of cutpoint guardrails until measurement year 2021 to account for the reality that situations like this will impact the clustering algorithms. This change to the guardrail implantation will allow cutpoints to decrease by more than 5% for measurement year 2020 to account for the rate changes that will undoubtedly occur on many measures due to situations such as this.


CMS’ recent announcement provided some clarity on Star Ratings relief in response to the coronavirus crisis. We still have many unanswered questions, but we expect many more updates to be shared in the coming weeks and months. Subscribe to our newsletter to stay up-to-date with the latest news and regulatory changes.

If you need help navigating Star Ratings, updating workplans, and building the right strategies given these unprecedented times, get in touch with one of our experts.

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