Insights From CMS’ Annual Request For Comments For Star Ratings

Despite the seismic transition underway in Washington, the now-annual ritual of CMS’ Request for Comments on Proposed Enhancements to the 2018 Star Ratings program will be remembered not for noteworthy new Star Ratings program information but rather for the absence of significant new insights or new measures.

As anticipated, and consistent with CMS’ growing practice of reducing measure ratings to 1 Star in response to audit and enforcement actions, CMS sought feedback from health plans regarding proposed options for adjusting Star Ratings for audits and enforcement actions within the Request for Comments.  CMS continues leveraging and enhancing the Star Ratings program to advance its policy goals in addition to using the program to improve quality of care and health status of Medicare beneficiaries.

But this year’s Request for Comments surprisingly offered no updates on measures which may be added to or removed from the program or on measurement concept changes that may be applied to the 2018 or 2019 Star Ratings. In recent years, many health plans have used the annual Request for Comments feedback period as an operational trigger to initiate the many internal discussions and decisions necessary to determine whether (and how) to adjust processes and infrastructure to account for proposed measure changes.

Given the new clinical areas to be evaluated through many of the measures under consideration by CMS for future addition to the program, combined with NCQA’s recent request for public comment regarding potential removal of several HEDIS measures from 2018 Health Plan Accreditation scoring (which may foreshadow similar consideration by CMS to remove such measures from the Star Ratings program in upcoming ratings cycles) and CMS’ ongoing efforts to develop data-driven care coordination quality measures for use in the Star Ratings program, 2017 may serve as an important bellwether year which will differentiate innovators and trendsetters from the rest of the pack.

Despite the ongoing uncertainties within the Star Ratings program, this is a great opportunity to revisit your 2017 Star Ratings workplan and care management programs to ensure that you are well-positioned for success.  It’s an ideal time to evaluate reports, analytics, member and provider interventions, education and targeting strategies, and budgets to make sure that you’re prepared to earn your 4 Star rating next year.

Gorman Health Group’s team of experts can help your organization adapt to the new clinical areas under consideration by CMS, to enhance care coordination within your programs, and to evaluate the effectiveness of your current Star Ratings program.  To learn more about how GHG can support your organization’s Star Ratings efforts, please contact me at



In order to positively impact quality and financial outcomes, health plans must prioritize clinical capabilities as part of their goal to provide the best care to members, strengthen provider relationships, and drive overall plan performance. This is where we come in. GHG’s clinical team of experts can assess your current quality program, and develop integrated strategies to build a new foundation focused on the areas that matter to you most: cost, quality and revenue. Visit our website to learn more >>

On November 1, GHG’s Founder & Executive Chairman, John Gorman, and colleagues Melissa Smith, our Vice President of Star Ratings, as well as Eric Letsinger, President of Quantified Ventures, a firm committed to supporting the progress of the social enterprise community, and his colleague Brendan O’Connor, an Impact Manager, provided insight on how social impact investing can be used to improve health outcomes and Star Ratings and how your organization can benefit. Download the recording here >>

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