COVID-19 Star Ratings Changes: What Do We Know? What Remains Unknown?

On March 30, 2020, the Centers for Medicare & Medicaid Services (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. The announcements contain various actions and regulatory changes to help providers handle the surge of COVID-19 patients, better enable workforce expansion, increase telehealth and in-place testing, and put “Patients Over Paperwork” through temporary relief in various areas. CMS also announced significant temporary changes to Star Ratings that all plan leaders need to understand and prepare for.

Changes announced to the 2021 Star Ratings include:

  • Removal of the requirement to submit HEDIS® data for the 2019 measurement year
  • Removal of the requirement to submit the 2020 CAHPS survey data
  • Use of the 2020 measure-level ratings for HEDIS® and CAHPS measures
  • In the event that validated data is not available, or there are systemic data integrity issues for certain other measures, a plan’s 2020 measure-level rating will be used as its 2021 rating (e.g., potentially MTM CMR Completion Rate, SNP Care Management, FL/TTY measures)
  • For HEDIS® and CAHPS measures included in the Improvement measures, CMS will use the measure-level improvement change score from the prior year to compute the measure score
  • Calculation of the CAI using data will be aligned with the period actually measured. (For example, 2018 for the HEDIS® and CAHPS measures, based on the above-noted changes.)

CMS also announced that, in the event its own functions become solely focused on performance of essential Agency functions in a manner that prevents it from calculating the 2021 ratings, a plan’s 2020 Star Rating will be used as its 2021 rating. (For new plans, new plan status would just be extended one additional year.)

Technical program changes and temporary waivers impacting the 2022 Star Ratings include:

  • Postponement of the 2020 HOS survey period until at least late summer (with CMS monitoring the situation to determine whether additional adjustment is needed)
  • Replacement of the 2022 HOS measure ratings with the 2021 measure-level ratings in the event the HOS data cannot be collected in 2020, if the public health emergency continues through summer
  • Affirmation that HEDIS® data for the 2020 measurement year and spring 2021 CAHPS surveys are expected to be submitted per normal procedures and timelines in 2021
  • Removal of the cutpoint guardrails from the 2022 ratings by delaying the applicability date for the cutpoint guardrails from January 1, 2020, to January 1, 2021, (to allow 2022 cutpoints to decrease by >5% if national trends decline dramatically due to the outbreak)
  • Allowing plans to relax “refill too soon” and maximum day supply edits, as well as to relax plan-imposed policies discouraging home and mail delivery of drugs (which will improve adherence and CAHPS measures)
  • Allowing plans to waive cost sharing and provide expanded telehealth benefits beyond the level included in the 2020 bid (which will support numerous CAHPS measures and may discourage disenrollment)

There remain many unanswered questions that we expect numerous plans to pose to CMS, including:

  • Will CMS possibly consider additional adjustments, notably for the many small- and mid-sized plans who were not satisfied with their 2020 ratings and invested heavily in improving (among other measures) CAHPS and HEDIS® measures?
  • Will CMS possibly grant any additional HEDIS® measure adjustments for plans whose current measurement year 2019 rates are already higher (per their certified HEDIS® software) than the final 2018 measure rates (to provide some tangible reward for the investments of effort and resources)?
  • For the plans that invested disproportionately in CAHPS during measurement year 2020 in preparation for these measures to be increased to 2x-weights in the 2021 rating, how can it possibly be fair to apply the increased measure weights to the old performance (which occurred prior to investments of time and effort)?
  • Will all previously announced measure additions, measure removals, and increase in patient access and experience weights slated for the 2021 Star Ratings occur as planned?
  • Will the COVID-19 outbreak impact any of the measure additions, measure removals, weight changes, etc., proposed in the 2021 Advance Notice?
  • Because yesterday’s announcement only rewards plans who performed well during measurement year 2018, and because this crisis is impacting ALL plans similarly, would CMS possibly entertain paying a set QBP for one year to ALL plans, regardless of their 2021 Star Rating, rather than financially penalizing plans for not hitting 4+ stars in the 2021 ratings?

Conclusion

We encourage plans to continue offering feedback to CMS and legislators. The unique nature of the public-private partnership of Medicare Advantage and Part D requires it! We will be watching closely for clarifications to the questions listed above and will share as soon as we hear confirmation.

We know how challenging it may feel to determine what to do next in this unprecedented situation. If we assume that the changes to the 2022 ratings as described above represent the full extent of relief provided by CMS, it will be vital for plans to prepare to deploy adjusted workplans as soon as their service area permits. If you need assistance during this challenging time, we can help. From augmenting current staffing capacity to developing “post-lockdown” Stars workplans that position you for 4+ star 2022 ratings, our experts all have deep expertise inside of health plans and can help. Please contact me at msmith@gormanhealthgroup.com for more information.

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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