Changes Within Stars for CMS Final Call Letter for Medicare Advantage Part C & D

The Centers for Medicare & Medicaid Services (CMS) released the Final Call Letter on April 1, 2019. The Call Letter solidifies some of the proposed changes that were included in the Part 1 Advance Notice. The following details highlight the key takeaways within the Stars elements of the call letter, including new measures, weighting changes, display measures and what to expect in the coming years.

Within the Call Letter, CMS acknowledges the unique challenges of serving subsets of the population with disabilities or dual eligibles. They discuss the Technical Expert Panel (TEP), which was created across various stakeholder groups on May 31, 2018, to provide feedback on framework, measures, and methodology. CMS did note that starting from 2021 Star Ratings, all changes with methodology, addition of measures, and changes within measures will be proposed and finalized through rulemaking. On November 1, 2018, CMS published a 2020 and 2021 Proposed Rule (83 FR 55021), which proposed changes to the methodology for calculating ratings beginning with 2022 Star Ratings. A proposed rule included a “guardrail” for non-CAHPS measures allowing only a 5% increase/decrease within measures that have had three years or more of historical scoring within the Stars program. Major changes to measures for the upcoming Stars 2020 are as follows:

Part D

  • Medication Adherence (ADH) for Cholesterol (Statins) (Part D) – Updated measure for 2018 to exclude beneficiaries with end-stage renal disease (ESRD). This exclusion was applied to Medication Adherence for Hypertension (RAS Antagonists), Diabetes Medications, and Statin Use in Persons with Diabetes (SUPD).
  • Medication Therapy Management (MTM) Program Completion Rate for Comprehensive Medication Reviews (CMR) Measure (Part D) – PQA for 2018 included a new denominator rule to accurately account for all CMRs received.

Beneficiaries who were enrolled in contract’s MTM program for less than 60 days at time in measurement year:

  • Continue to exclude them from calculation.
  • (New) Include them in denominator and the numerator if they received CMR within the timeframe.
  • Medication Adherence Diabetes, RAS Antagonists, Statins, and SUPD –Beneficiaries who elected to receive hospice at any time in the measurement year will be excluded from the denominator.
  • Statin Use in Persons with Diabetes (SUPD) (Part D) – In draft call letter CY 2020, it was proposed that this measure be changed to a weight of 3. After majority feedback opposing this weighting change, CMS is keeping this measure at a weight of 1.

Part C

  • Controlling High Blood Pressure (Part C) – With the release of new hypertension treatment guidelines, this measure will be placed on the display page for Stars 2020 and 2021. The proposal is to bring this measure back into Stars 2022.

New 2020 Display Measures

  • Transitions of Care (Part C) –This measure will be very important in the coming years to the Star Rating to improve the quality of care transitioning from an inpatient setting to a home.
  • Follow-up after Emergency Department Visit for Patients with Multiple Chronic Conditions – Based on ED visits, not members.
  • MPF Price Accuracy (Part D) – Changes will be made for the 2020 and 2021 display of these measures.

Forecasting 2021 and Beyond – Notable

  •  Plan All-Cause Readmissions (Part C) – The proposal includes moving this measure to display from Stars 2021 and returning it as a 1 weight in 2023 and then 3 weight thereafter.
  • Medication Reconciliation (Part C) – This measurement is under consideration of retirement as this data collected will roll up to the Transitions of Care measure.
  • Osteoporosis Measures (Part C) – Several minor changes to the denominator regarding members with frailty or living in long-term institution during measurement period.
  • Care for Older Adults (Part C) – Proposals have been made to remove the fourth option for meeting the numerator. NCQA proposes this change for HEDIS 2021 and would be moved to the display for 2022 and 2023.
  • High Risk Medication and Diabetes Medication Dosing – Will be retired both from the display measures and will no longer be reported.

Removal of Measures from the 2022 Star Ratings 

  • Adult BMI Assessment (Part C) – This will be removed from the Star Ratings beginning with measurement year 2020 for 2022 Star Ratings.
  • Appeals Auto-Forward (Part D), Appeals Upheld (Part D) – These two measures will be removed beginning with 2020 measurement year and 2022 Star Ratings.

A Look to the Stars

CMS is beginning to take a very different approach to the Star Ratings system from where it  began. The importance and weighting of HEDIS is beginning to be outshone by drug adherence measures, member satisfaction, and patient access. With a proposal to potentially change the Patient Access and Experience measures (Final Rule), we could see a drastic difference in the overall approach taken by health plans. This modification would see the measure(s) weighting from 1.5 to 2 beginning Stars 2021 and 2022 and then potentially 3 weighted within Stars 2023. The importance of an engaged member outreach team connecting with the beneficiary on all aspects of care including HEDIS and drug adherence will create a greater need for proactive, accurate, analytical, data-driven outreach teams.  Advalent can work with your plan to  help you incorporate these changes  today, so you are prepared for tomorrow.