Star Ratings Impact: Medicare Advantage and Part D Rate Announcement

CMS Advanced Notice Summary:

On April 4^th, 2022, CMS released their 2023 Medicare Advantage and Part D Rate Announcement. This notice contained several proposed changes to both methodology, calculation and future measures. However, the short-term impact overall is minimal in 2022 and 2023. Proposed changes could potentially have to go through the rule making process and work take additional time. With each new notice from CMS, plans should always be forward-thinking.

Below, we highlight two critical considerations for Health Plans to be successful in Stars. These take into account future changes to the program and will position your plan to be successful both now and into the future.

HEDIS Impacts – Data Transformation:

CMS has announced that they are removing the hybrid reporting method for Colorectal Cancer Screening in MY2024 and transitioning the measure to electronic clinical data systems (ECDS) reporting only beginning in MY2024. For the Breast Cancer Screening measure, CMS will move the measure away from administrative collection and to ECDS collection beginning in MY2023.

What is the difference between traditional HEDIS reporting and ECDS? The ECDS method has specific guidelines for reporting data to NCQA using four data source categories: EHR, health information exchanges/clinical registries, case management system and administrative claims/enrollment. Contracts will no longer be able to assess performance based on a sample of members when the hybrid method is removed, but they can continue to use data from chart reviews if it is standardized upon abstraction and included in an electronic database. They can perform year-round chart review and have it audited as non-standard supplemental data and use it to report the measure.

Plans need to consider data transformation efforts to shore up their ECDS capabilities if, in fact, CMS decides to migrate all eligible HEDIS measures toward ECDS reporting.

Future Changes to Star Ratings – A Focus on Health Equity

CMS, in its latest ruling, hinted at several potential changes to the Star Rating program, several of which had a focus on Health Equity. These changes would come across as net new measures and calculation/methodology changes.

The biggest takeaway for health plans is not to focus in any one specific new potential measure, but to consider health equity broadly when devising Stars strategies. Forward thinking plans would be wise to consider the following:

Intelligent Data Collection

• Plans need to rethink how they collect and document data from members (i.e., on housing security, food security, etc.). Creative plans are thinking about enhancements to Health Risk Assessments, Application Data and other data collection opportunities along the continuum of a member’s journey with the plan.

Community Collaboration

• Health plans should consider enhanced public/private partnerships within the communities they serve. This includes improved programs and/or incentives with focuses on social risk factors and assisting members to obtain community resources available to them.

Reminders for Star Rating Measures in 2023 and Future Years:

Reminders for Star Rating Measures in 2024 and Future Years: