** UPDATED INFORMATION AVAILABLE HERE:  

https://carenethealthcare.com/infographic-2021-23-stars-changes-and-impact-analysis/

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The following Medicare Advantage Stars update was written in February 2020 by Rex Wallace, Principal, Rex Wallace Consulting, and provides an important overview of the impact of the 2021 Advance Notice (Part II) and 2021 Proposed Rule.

On February 5, 2020 the Centers for Medicare & Medicaid Services (CMS) released the Advance Notice of Methodological Changes for Calendar Year (CY) 2021 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies – Part II (referred to as Advance Notice, going forward in this post). The entire 83-page document includes important information for MA plans across a variety of topics. This post will focus solely on the impact on Star ratings.

On the same day, CMS released the Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program and Programs of All-Inclusive Care for the Elderly (referred to as CY 2021 Proposed Rule, going forward in this post). Like the Advance notice, the entire 895-page document includes an enormous amount of valuable MA proposed changes, but this post will focus solely on the impact on Star ratings.

The following high-level information summarizes the key points but does not yet dig into the ultimate ramifications of some of these proposed changes, which are still being explored.

For simplicity, I’ll break it down by Star rating year, combining key changes we already knew and proposed changes that were just released. I’ll distinguish between the two. And please realize this is just key changes to Stars, in my opinion. There are many, many pages in the actual documents that need to be reviewed in their entirety by your organizations.

2021 Stars – Key Changes

Expected/Known

  • No new measures
  • Controlling High Blood Pressure (CBP) on Display (year 2 of 2)
  • Plan All-Cause Readmissions (PCR) moving to Display (year 1 of 2, PCR also obviously not included in Improvement Measure calculation)
  • Member Experience measures moving from weight of 1.5x to weight of 2x (All non-Flu CAHPS measures, Disenrollment, Appeals, Call Center, and Complaints measures)

Newly Proposed

  • Reviewing Appeals Decisions – CMS now allowing re-openings through June 30
  • CMS encouraging plans to use and reference digital specifications for HEDIS measures
  • Some HEDIS measures now allow data from patient-used devices to fulfill numerators (such as home BP machines)
  • 2019 saw only one natural disaster impacting Stars (Puerto Rico earthquake, 12/28/2019), compared to 2018, which included an earthquake, wildfires, a typhoon and two hurricanes
  • New on Display page (definite future Stars candidates)
    • Concurrent Use of Opioids and Benzodiazepines (COB)
    • Use of Opioids at High Dosage in Persons Without Cancer (OHD)
    • Use of Opioids from Multiple Providers in Persons Without Cancer (OMP)
    • Use of Opioids at High Dosage and from Multiple Providers in Persons Without Cancer (OHDMP)
  • Updates to other Display measures
    • Antipsychotic Use in Persons with Dementia Overall (APD)
    • Antipsychotic Use in Persons with Dementia, for Community-Only Residents (APD-COMM)
    • Antipsychotic Use in Persons with Dementia, for Long-Term Nursing Home Residents (APD-LTNH)

2022 Stars – Key Changes

Expected/Known

  • CBP returning with initial weight of 1x
  • PCR still on Display (year 2 of 2)
  • BMI, Appeals Auto-Forward and Appeals Upheld officially retire from Stars
  • New mean resampling and guardrails apply to cut points

Newly Proposed

  • Important tweaks to Transitions of Care (still on Display page)
  • Important tweaks to the CBP denominator
  • Important changes to Care of Older Adults (COA) – Functional Status Assessment Indicator (would move to Display for 2022 and 2023 Stars)
  • New HEDIS cross-cutting exclusions (affecting members who require nursing home level care but do not reside in one, and those receiving palliative care)
  • Re-evaluation of the Initiation and Engagement of Alcohol and Other Drug Abuse and Dependence Treatment measure (no indication of future inclusion in Stars)
  • Updates to Hospitalization for Potentially Preventable Complications (no indication of future inclusion in Stars)

2023 Stars – Key Changes

Expected/Known

  • PCR returning with initial weight of 1x
  • CBP weight increasing back to 3x

Newly Proposed

  • Adding Transitions of Care (HEDIS) as a new official Stars measure
  • Adding Emergency Department Visit for Patients with Multiple Chronic Conditions (HEDIS) as a new official Stars measure
  • Member Experience measures moving from weight of 2x to weight of 4x (All non-Flu CAHPS measures, Disenrollment, Appeals, Call Center, and Complaints measures)
  • Removing the Rheumatoid Arthritis measure from Stars
  • In addition to the mean resampling and guardrails, cut points would also apply Tukey outer fence outlier deletion, a method of removing outliers that would result in higher 1 and 2 Star thresholds and, combined with the 5% guardrails, would result in 16% of MA contracts decreasing by half a Star, and one contract decreasing by a full Star (would result in reduced Quality Bonus Payments (QBP) of $1.5 billion by 2030)
  • Reclassifying Statin Use in Persons with Diabetes (SUPD) as a process measure
  • Changes to the two, 3x-weighted HOS measures (Improving or Maintaining Physical Health; Improving or Maintaining Mental Health)
    • Changing the case mix adjustment methodology to mirror CAHPS
    • Increasing the minimum denominator from 30 to 100
  • Contract consolidations (new rules for when measure scores are missing from either the consumed or surviving contract)
  • Disasters (changes proposed regarding such topics as missing data and the impact of a contract being affected in multiple years by natural disasters)
  • QBP payments (changes proposed, primarily regarding how QBPs apply to new MA contracts)
  • Important changes to COA – Functional Status Assessment Indicator (would move to Display for 2022 and 2023 Stars)
  • Retiring Osteoporosis Testing in Older Women from Display page

2024 Stars – Key Changes

Expected/Known

  • PCR weight increasing back to 3x

Newly Proposed

  • Proposing that all three Medication Adherence measures are risk-adjusted for socioeconomic status (SES) or sociodemographic status (SDS)

Potential New Measure Concepts

  • End-Stage Renal Disease (ESRD): Proposing other measures to replace Diabetes Care – Kidney Disease Monitoring
  • CMS asking for feedback on including Prior Authorizations as future Stars measure
  • New HOS measure going on 2021 Display (Physical Functioning Activities of Daily Living)
  • Potentially expanding existing HOS measures to under 65 population
  • Osteoporosis Screening measure (Potential HEDIS measure for CY 2020)
  • Cardiac Rehabilitation (Potential HEDIS measure for CY 2020)
  • Diabetes Overtreatment (Potential HEDIS measure for CY 2021)
  • Home Health Services (Potential HEDIS measure for CY 2021)
  • Generic Utilization: CMS desires to reward plans for high rates of generic utilization
  • Initial Opioid Prescribing (IOP) measures
  • Initial Opioid Prescribing at High Dosage: Still being analyzed
  • Initial Opioid Prescribing for Long Duration: CMS plans to begin reporting this measure on Display for 2023 Stars
  • Initial Opioid Prescribing for Long-Acting or Extended Release Opioids: Still being analyzed
  • Net Promoter Score: CMS considering adding NPS question to CAHPS to include in Stars

 

For more information

Visit https://www.cms.gov/newsroom for details.

Rex can be reached via rex.wallace@rexwallaceconsulting.com.

For discussions on improving your Medicare Advantage plan’s member engagement and outreach—and impacting HEDIS and other measures—reach out to our Carenet Health team.