The First Plan Preview period for the 2018 Star Ratings began last week with the Centers for Medicare & Medicaid Services’ (CMS’) release of measure rates and an initial draft of the technical notes. As is always the case, CMS is allowing only a very short review period with all feedback due by THIS FRIDAY, August 18 – so time is of the essence!
While plans must validate the accuracy of the measure rates by Friday, this is also an important time to begin internal preparations for the planned changes in the draft 2018 technical notes, including the following:
- Planned addition of Improving Bladder Control measure
- Planned addition of Medication Reconciliation Post-Discharge measure
- Planned retirement of High Risk Medication measure to the Display page
CMS announced several additional measure changes that could impact plan ratings:
- Reversion of the MPF Price Accuracy measure specifications to the 2017 methodology
- Return of Plan All-Cause Readmissions measure to the Health Plan Quality Improvement measure calculation
- Removal of three Consumer Assessment of Healthcare Providers and Systems (CAHPS®) measures from Health Plan Quality Improvement measure calculation
- Adjusted measure specifications for Call Center – Foreign Language and TTY Availability measures
And, in case you missed it, CMS added new language to Section 30.10.1 of the Medicare Marketing Guidelines preventing plans from referencing a Star Rating that was achieved based on prior contract year data when marketing materials are for an upcoming benefit year. Though Regan Pennypacker, Gorman Health Group’s Senior Vice President of Compliance Solutions, anticipates clarifying guidance from CMS to help plans better understand how this impacts use of the new 2018 Star Ratings in marketing materials being created for the upcoming selling season, this is an important issue for plans to evaluate and provide feedback to CMS. Star Ratings leaders should connect this week with your Compliance and Marketing experts to determine your stance on this new language so you can provide feedback to CMS prior to Friday’s deadline if your position differs from the current guidance.
What else should plans do now?
- Validate your measure rates. Communicate any errors, inaccuracies, or concerns about the rates (or data used to calculate the rates) to CMS by Friday.
- Provide feedback to CMS on the changes announced in the draft technical notes.
- Get to work! Every remaining day of 2017 matters to your 2019 ratings.
- Stay alert! It’s more than a bit surprising the new administration has still made no changes to Star Ratings, but they retain the right to implement changes until the 2018 ratings are finalized. Secretary Price continues efforts to reduce physician burden and slow the pace of regulated change through changes to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)/Quality Payment Program (QPP), cancellation of two mandatory cardiac bundled payment models, and scaling back of an additional joint replacement bundled payment model. However, CMS continues reiterating to plans to move more towards outcomes in Star Ratings. Even if no additional changes are made to the 2018 ratings, plans need to be ready when Star Ratings make their way into the new administration’s crosshairs.
- Prepare for Plan Preview #2, which begins in early September.
- Prepare for the 2018 Star Ratings to go live on October 11.
Improving performance is always challenging, particularly in times of uncertainty. Whether you need help improving current Star Ratings measure performance or designing workflows to support the new Star Ratings measures that may be added to the 2019 ratings, we can help. For questions or inquiries about how Gorman Health Group can support your Star Ratings program, please contact me directly at firstname.lastname@example.org.
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