Surprise! Part II of the 2022 Medicare Advantage & Part D Advance Notice is Here

In one last “October Surprise,” the Centers for Medicare & Medicaid Services (CMS) have released Part II of the 2022 Medicare Advantage and Part D Advance Notice 3 months early, allowing plans more time to prepare 2022 bids and projections in light of the pandemic.

New Changes Announced in the 2022 Medicare Advantage Advance Notice Part 2

Part II of the Advance Notice is filled with good news for plans. The changes proposed in Part I (released on September 14th) and those in Part II (released on October 30th) are expected to increase plan revenue by 2.82%, compared to the 2021 rate notice that projected an increase of under 1%. And consistent with the rulemaking requirements for Star Ratings changes where new measures and measures with substantive specification changes must remain on the Display Page for at least two years, CMS proposes the following additional changes:

• Delay returning Controlling Blood Pressure to the 2023 Star Ratings (postponed from previous planned return in 2022 ratings to allow revised measure to be on Display for 2 years)
• Delay returning Plan All-Cause Readmissions measure to 2024 Star Ratings (postponed from previously planned return in 2023 ratings to allow revised measure to be on Display for 2 years)

These delays in returning Controlling Blood Pressure and Plan All-Cause Readmissions to Star Ratings may cause plans to wonder whether this may indicate similar delays on CMS’s proposal to add Transitions of Care (TRC) and Follow-up After ED Visit for Patients with MCCs (FMC) to Star Ratings in 2022. Since these measures will have met the criteria of being on Display for at least 2 years (they were on Display in the 2020 Ratings and will be on Display for the 2022 and 2023 ratings), they could be added as early as the 2024 ratings; thus, we must wait for the next Final Rule to be released for more certainty and/or clarity on these potential measure additions. We still anticipate one more Final Rule in 2020, in which additional guidance is expected.

Other Star Ratings Changes to Note

These proposals are in addition to numerous non-substantive changes described in the Advance Notice, as well as already codified changes previously announced to Star Ratings:

• Implementation of cut point guardrails to take effect in measurement year 2021 (2023 Star Ratings)
• Expansion of the hold harmless provision for Improvement measures to all contracts for 2022 Star Ratings
• Significant modifications to the extreme and uncontrollable events policy for 2022 Star Ratings, allowing all plans to receive the higher of their measure-level ratings from 2021 or 2022

Final Comments

CMS will accept comments on both parts of the CY 2022 Advance Notice through Monday, November 30th. CMS is also considering publishing final 2022 rates a few months earlier than required, with the final rate announcement required by law to be announced no later than April 5th, 2021.

As always, CMS is soliciting input on how to improve Medicare Advantage and Part D star ratings. In particular, CMS is seeking feedback on a potential COVID-19 vaccination measure and a provider directory accuracy measure. Should CMS continue with their proposal to add FMC and TRC in 2024, when combined with these latest announcements, the Star Ratings workplans in 2022 will need to be dramatically different for plans to achieve success.