As of March 22, 2020, the Centers of Medicare and Medicaid Services (CMS) has not yet announced regulatory or programmatic changes to Medicare Advantage (MA) Star Ratings as a result of the COVID-19 pandemic. Because Star Ratings is now codified, and all changes must be made via rulemaking, it may take a bit longer that desired for us to see official relief.
However, CMS has issued numerous other changes to help reduce the significant burden providers and MA plans are facing as they manage through the coronavirus disease pandemic, and it is only a matter of time before CMS issues some MA Star Ratings changes.
Based on relief already granted by CMS in other Medicare programs, we can expect the future changes from CMS to likely include:
- Additional relief for extreme and uncontrollable events (impacting 2021 and 2022 ratings)
- Changes to measurement period for certain measures (i.e., potential exclusion of January 1, 2020, through June 30, 2020, clinical measures, potentially impacting 2021 and 2022 ratings)
- Changes in procedures and/or use of hybrid HEDIS® data (impacting 2021 ratings)
- Potential changes in collection and/or use of the Consumer Assessment of Healthcare Providers and Systems (CAHPS) surveys to be fielded in spring 2020 (impacting 2021 ratings)
- Potential changes in collection and use of Health Outcomes Surveys (HOS) to be fielded in spring 2020 (impacting 2022 ratings)
With so many unknowns, many clients have asked what they can (and should, under the difficult circumstances) be doing from a Stars perspective in the midst of this crisis. Here are a few suggestions:
Focus everyone in your organization on the following measures: Rating of Health Plan, Rating of Drug Plan, Customer Service and Rating of Healthcare Quality
These measures are often among the hardest on which to focus during normal times. However, with theoretically all MA members vulnerable to coronavirus disease and experiencing restrictions not only on their daily life but also the availability of non-COVID-19 clinical care when they need it, it’s safe to say these are anything but normal times.
As your organization makes decisions in the coming weeks to cope with COVID-19, add the following questions to the decision-making process:
- How does this support our members seeing us as a 5 star plan?
- How does this help members receive the best possible quality of care?
- How well are we helping members get the information, care, and support they need?
Communicate to/with CMS and Congressional representatives.
Many plans do not provide feedback to CMS regarding desired program changes. Some plans assume that industry associations and advocacy groups can speak effectively on their behalf and/or assume that CMS will not read their feedback. Every plan has a unique perspective on how they would like to see CMS offer COVID-19 Star Ratings relief and a unique set of challenges that CMS should take into account in their relief package. Please offer your thoughts to CMS. All of the changes made to the Star Ratings program in recent years have been the direct result of plans providing feedback and recommendations to CMS. There has never been a more important time to be “on the record” with CMS to voice your needs!
Use the flexibilities offered by CMS as quickly as possible—and make sure members are aware of any changes.
CMS is already issuing frequent, real-time, prolific policy changes to help plans and providers best respond to this crisis. Watch closely for operational changes, implement immediately upon issuance, and communicate all changes to members using all possible media. Make sure your Customer Service representatives understand the changes being made and how to help members navigate those changes.
Focus Stars, Quality, and other available staff on developing a revised 2020 “POST-COVID-19 STARS WORKPLAN,” including efforts needed for success on new measures.
Regardless of any near-term relief CMS may provide to Star Ratings, such relief will only be temporary. This crisis will not last forever—and many of the new measures scheduled for addition to the program are not currently being adequately addressed by MA plans. If you have staff whose duties and assignments are on hold during the crisis, focus their time and efforts on:
- Revising your 2020 Stars Workplan: Carefully assess how your organization will need to adjust current Stars strategies and tactics, considering:
- How your members may need to manage expectations if “pent up” demand for routine/chronic care escalates after the crisis and stretches provider capacity thin once social distancing guidance is lifted.
- How your efforts may need to change if in-home support and services are reduced throughout the year due to lack of adequate personal protective equipment (PPE) for vendors.
- How your efforts may need to change if HEDIS® and prescription drug event (PDE) measures are suspended for at least some portion of the year.
- Developing tactics and strategies to address new measures: Cultivate a technical understanding, assess risks inside your organization and in your service area, surveil best practices, and begin formulating the “Post-COVID-19” new measure response strategy.
- Calculate the potential impact on projections: Mathematically model your ratings based on known changes as announced by CMS. Include a variety of modeling scenarios to help leaders understand the fluidity of ratings projections and incorporate modeling into your feedback to CMS.
Use the mental clarity that may be afforded by this season of remote working to carefully explore your organization’s readiness for, and potential response to, MedPAC’s recommendation to change Star Ratings dramatically.
In its March report to Congress, MedPAC continued reiterating its support for a replacement of the Star Ratings program. The Medicare Trust Fund was already facing an increasingly urgent inflection point and was slated to be depleted by 2026. The financial impacts of COVID-19 on the Trust Fund will expedite its insolvency and undoubtedly require unprecedented policy changes once it passes to cope with the Trust Fund’s insolvency.
Given the fact that many stakeholders throughout the industry acknowledge the shortcomings of the current Star Ratings program—and any relief could be pervasive across many current measures and program criteria—plans should prepare for the growing possibility that CMS will adopt MedPAC’s recommendations after the crisis passes. Use this period of remote work to expedite your assessment of readiness for the many strategic and operational changes that would be required if CMS ultimately uses this once-in-a-generation public health crisis to implement a once-in-a-generation change to Star Ratings as part of their longer-term response to the financial impacts of this crisis.
Right now, the industry is wrought with uncertainty and awaiting specific rulemaking from CMS in regard to the Star Ratings program. As leaders in this space who are closely monitoring for updates, GHG can support you with assistance during this challenging time. From revising Stars workplans to running contract-level modeling, our staff has the expertise you need to stay on top of your Stars initiative throughout this crisis. Contact our team to start the conversation on how we can help. Contact our team to start the conversation on how we can help.
If you still have questions on the potential impacts that COVID-19 will have on the Star Ratings program, consider attending our upcoming virtual open forum on Thursday, March 26th, where the healthcare experts at GHG and analytics leaders at Pareto Intelligence will answer all of your specific questions across a variety of topics, including Marketing, Star Ratings, Risk Adjustment, Compliance, Network Adequacy and Development, Telehealth and Analytics.