In 2015, plans were met with the first “a-ha” moment when the Centers for Medicare & Medicaid Services (CMS) published the 2016 Star Ratings Medication Therapy Management (MTM) Comprehensive Medication Review (CMR) completion Star Ratings cut points indicating, at least when it came to delivering a completed CMR to a member, some plans were clearly outperforming others. Since then, the stakes have continued to be raised on MTM vendors or those conducting MTM in-house to meet the challenge of how to cost effectively improve their delivery of completed medication reviews. This is especially challenging given the varying nature of plan delivery types and the vastly different member demographics for whom they provide services.
As plans wade through the ever-changing regulatory environment, it bears noting, beginning this year (measurement year 2018) and realized in 2020, an increasing percentage of measures included in Star Ratings will be directly or indirectly impacted by MTM or medication-related focused activities. Although the Pharmacy Quality Alliance has some MTM metrics in development, currently the single-weighted CMR completion rate is the only Star Rating directly correlated with MTM. As CMS has continued to migrate its focus from process to outcome measurement, a number of outcomes-oriented measures have started to focus on medication-related areas such as Medication Reconciliation Post Discharge and Statin Therapy for Cardiovascular Disease as well as opioid overutilization and asthma. Most medication-based or impacted measures are triple weighted and therefore have a proportionally higher impact on the overall Star Rating, including several Part C measures such as Plan All-Cause Readmissions, Blood Sugar Control for Diabetics, or Blood Pressure Control.
On November 16, 2017, CMS issued a proposed rule that aims to remove any ambiguity surrounding the positioning of MTM services within the context of the CMS requirement MA plans must spend at least 85% of their revenues on medical loss ratio activities. These are defined as clinical services, prescription drugs, quality improvement activities, and direct benefits to beneficiaries to reduce Part B premiums. This broadened interpretation of MTM may impact the investment plans will make to improve the health impact of their MTM Programs.
Existing MTM processes offer a logical avenue to improve Star Ratings while at the same time ride out the period as CMS migrates its attention further to the qualitative impact of MTM and beyond the quantity of CMRs delivered. Not getting caught flat-footed like that day when those 2016 cut points were published will be key to plans and their partners achieving and maintaining their Star Rating and member health goals.
Join us on April 25-26 at the Gorman Health Group 2018 Forum at the Red Rock Resort in Las Vegas to hear more about the MTM landscape during our MTM Master Class session. Gorman Health Group pharmacy consultants can work with you to optimize your MTM Program to meet your Star Ratings needs. Our room block expires on March 23. We look forward to seeing you there!
Need more hands-on insight? Don’t miss our workshop on Star Ratings at the Gorman Health Group 2018 Forum where we’ll review the technical construct of the Star Ratings program. From measure specifications to financial impacts, we’ll cover the full spectrum of technical aspects. Download our preliminary agenda and register today!
Gorman Health Group’s summary and analysis of the 2019 Advance Notice and Draft Call Letter for Medicare Advantage and Part D is now available. Download now
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