We have received many questions in recent weeks regarding the Centers for Medicare & Medicaid Services (CMS) plan to increase the weight of Patient Access and Experience Star Ratings measures from 1.5x to 2x as announced in the Final Rule. Because this has such significant impact on Star Ratings strategies and investments, we want to share some of these questions (and our responses):
Question: When does this change take effect?
GHG Response: Section 422.160(c) states these changes are applicable beginning with the 2019 measurement period and the associated 2021 Star Ratings.
Question: Why would CMS make this change?
GHG Response: CMS is committed to better valuing the “voice of the patient” in evaluating the quality of care they receive. Not only is this change aligned with this vision, but CMS has also signaled its intention to further increase the weights of these measures in the future and has requested feedback on how to improve the Consumer Assessment of Healthcare Providers and Systems (CAHPS®) survey (including topics, suggestions for additional measures, and modifications to existing measures).
Question: Is it too late to provide feedback to CMS on this change?
GHG Response: CMS welcomes feedback from industry stakeholders regarding current and potential future program changes and frequently incorporates such feedback in program updates. However, this change has now been promulgated through legislation, so any future adjustments based on additional industry feedback would require legislative action.
Question: The Final Rule sets forth that these changes will take effect with the 2021 Star Ratings. However, we are still waiting for CMS to finalize the 2019 and 2020 Star Ratings technical criteria. Could CMS implement this change earlier through subregulatory guidance (issuance of Technical Notes, the 2020 Advance Notice/Call Letter, etc.)?
GHG Response: Though CMS has not signaled any intention to do so, CMS does retain the authority to implement these changes earlier than the 2021 Star Ratings through subregulatory guidance.
Question: Why aren’t more people talking about this?
GHG Response: Most Medicare Advantage Organizations (MAOs) are currently focused on the 2019 and 2020 Star Ratings and only beginning to think about the 2019 Plan Year, during which time this change takes effect. Because the mathematical magnitude of this change on Star Ratings is so material, we are suggesting to our clients they begin preparing for this change immediately by assessing the new risks this change presents and implementing high return on investment mitigating strategies and tactics to preserve their Star Rating.
Question: Could the Technical Expert Panel change CMS’ direction on this planned change?
GHG Response: The Technical Expert Panel could make recommendations that differ from this direction. However, because this change has been promulgated through legislation, any suggested adjustments would require legislative action.
Question: Will the weights of Health Outcomes Survey (HOS) measures also change since they, too, represent the “voice of the patient”?
GHG Response: Current legislation does not include any changes to the weights of HOS measures.
According to J. D. Power’s 2018 Medicare Advantage Study, even as Medicare Advantage membership continues to grow, overall customer satisfaction dropped 5 points from 2017 to 2018. This is an alarming trend that will likely manifest through the 2019 and 2020 Star Ratings. MA members continue to tell us that their most important priorities are what I refer to as “doctors, dollars and drugs” – essentially the construct of our provider network and formulary, and how easy and costly it is for members to understand and use them. But we all know that it’s not enough to offer robust benefits: we have to communicate them effectively during and after enrollment, we have to pay claims and handle calls accurately and quickly, we have to coordinate clinical care and medication use the way we describe during the sales process, and (of course) we must comply with CMS regulations. We know this isn’t easy. If you need help diagnosing high-risk areas as you prepare for this change, we can help. Please contact me at email@example.com.
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