Proposed Star Ratings Changes in 2020 CMS Draft Call Letter

Proposed Star Ratings changes reinforce CMS commitment to private sector innovation and creativity by incenting plans via quality bonus payments to continue the hard work required to achieve the Triple Aim. In alignment with previously announced plans to increase stability and predictability in the program, CMS has introduced a separate proposal to implement cut point guardrails for measures in the program for more than three years. This long-awaited predictability is counterbalanced by other proposals:

  • Removal of the Adult BMI Assessment and both Part D Appeals measures citing “low reliability” beginning with the 2020 measurement year (2022 Star Ratings)
  • Increased weighting of the Statin Use in Persons with Diabetes (SUPD) measure beginning with the 2020 Star Ratings

CMS’ policy claims of programmatic stability are a bit misleading, as the combination of previously announced guidance, along with NCQA’s proposed measure changes last week, present the most sweeping set of Star Ratings measure changes we’ve experienced in many years. Changes under consideration at the measure level include:

  • Patient access and experience measure weight increases from 1.5x to 2x beginning with the 2019 measurement year
  • Changes to the Controlling Blood Pressure measure will retire it from the 2020 and 2021 ratings
  • Changes to the Plan All-Cause Readmissions measure will retire it from the 2021 and 2022 ratings
  • Transitions of Care measure expected to be added as a new 2020 display measure and 2021 Star Ratings measure; Medication Reconciliation Post-Discharge to be one of four measure elements
  • Disease-Modifying Anti-Rheumatic Drug Therapy for Rheumatoid Arthritis proposed for retirement beginning with 2021
  • Change proposed to Osteoporosis Management in Women with a Fracture to remove two numerator events and include additional fractures in denominator
  • Change proposed to Care for Older Adults – Functional Status Assessment to remove a numerator event
  • Medication Adherence measures may be risk adjusted for various socio-demographic characteristics beginning with 2018 calculations
  • MPF Price Accuracy measure changes will be implemented through the Display Page for the 2020 and 2021 ratings
  • NCQA is considering additional frailty exclusions

And, if the sweeping changes above were not enough, CMS includes a stark reminder in the Advance Notice to plans of the importance of strategic, flexible investments in technology. CMS reminds plans that certain Star Ratings measures have been purposely designed to require data/technological interoperability for sustained success. This reminder comes as a harsh reality for plans that have deployed human capital in recent years to “block and tackle” areas CMS designed to be solved through technology and scale. These measures include: 

  • The HEDIS® measures of Transitions of Care and Post-Discharge Medication Reconciliation 
  • The CAHPS® Care Coordination measure

Finally, CMS proposes adding new opioid-related measures to the Display Page for the 2019 and 2020 measurement years. This addition to Star Ratings is inevitable as the growing crisis will become a key barrier to achieving the Triple Aim in Medicare Advantage. Though these measures have a long potential runway before they could be added as Star Ratings measures, plans will need to use this runway effectively to ensure their Star Ratings don’t falter if/when CMS adds them to the program. And with CMS’ encouragement for plans to offer targeted benefits and cost-sharing reductions to patients with chronic pain or undergoing addiction treatment, the CAHPS® impacts of effective opioid strategies and support will filter through to Star Ratings immediately.

All of CMS’ proposed Star Ratings changes are being made under the backdrop of CMS’ shift in 2020 from strict uniformity requirements to significantly greater flexibility for plans to offer chronically ill patients a broader range of supplemental benefits specific needs and conditions, such as home-delivered meals or transportation for non-medical needs, and the allowance of telehealth in bids. These policies, combined with the increase of patient access and experience measure weights to 2x beginning January 1, 2019, dramatically alter the importance of products that meet members’ needs and seamless, effortless operations.

Change is never easy. If you need assistance preparing for these changes, we can help. Please contact us for more information.

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