The first Plan Preview of 2022 Star Ratings generated a significant buzz in the Medicare Advantage (MA) world. Here’s what plans can expect as The Centers for Medicare and Medicaid Services (CMS) prepare to release Plan Preview #2.
“Better of” Measures Create a Threat for Complacency
The vast amount of COVID-19 relief in the 2022 Star Ratings is going to (very falsely) make most plans’ ratings look stronger than they really are. By allowing plans to use the “better of” their actual 2022 rating or 2021 rating (which reused the 2020 CAHPS and HEDIS ratings) for most measures, many plans whose performance is eroding will be able to hide it well, since they can recycle their clinical and member experience ratings from as far back as measurement year 2018.
We know memories are short when the numbers look good. In the next few weeks, plans who know their actual performance is worse than the 2022 Star Ratings reflect will have plenty of pre-work to be done before the second Plan Preview ratings are released to prevent complacency.
TOP TIP #1
Spend the next few weeks educating leadership on how misleadingly positive the 2022 Star Ratings are going to look. Make sure they know your REAL performance status, and secure commitment that 2021 and 2022 budgets won’t be trimmed based on the anomalously strong 2022 ratings.
TOP TIP #2
Expand your 2022 Star Ratings reporting package to consistently display “pre-COVID relief results” and “with COVID relief results.” And over-communicate, repeatedly, your true performance status.
Start the Countdown to 2022
There are only 4 months left until an unprecedented number of new measures take effect in January 2022. CMS gives plans a 2-year notice period for new measures to account for the long runway needed to prepare for the new measure needs and implement new tools, processes, and strategies for success.
The new measures taking effect in ~120 days focus on rapid action by providers, patients, and caregivers within days of discrete clinical events. Some events require completion within 24 hours of an event (e.g., transmission of admission data and robust discharge data after an inpatient admit/discharge), and none allow more than 30 days (e.g., an appointment and medication reconciliation after discharge from an inpatient stay or avoidance of readmission).
But many plans have done very little to prepare for these new measures, and the average national rating on new measures is typically under 3 Stars. The measures being implemented in 2022 are very different than our current slate of measures, and success is unlikely without very different investments in very different areas. Many plans have tackled similar issues in the past using human staff employed by the health plan, but CMS has been very transparent that success on these measures requires interoperability among providers across settings, and alignment between payers and providers regarding needs, expectations, and collaboration.
TOP TIP #3
Validate the adequacy of investments and preparations for the following measures: Transitions of Care, Follow up after ED Visits for Patients with MCCs, and Plan All-Cause Readmissions. If your workplans are a little skinnier than they should be for these measures, accelerate investments in interoperable technology immediately as these measures are time-sensitive, require real-time member and provider engagement/action, and noncompliance in early 2022 cannot be reversed later in the year.
TOP TIP #4
Educate stakeholders on the medical cost savings associated with success on these measures. CMS has added these measures not only because they help members achieve better health outcomes by avoiding admissions or readmissions, but also because reducing admissions and readmissions are key drivers of Medicare expenditures. Enlist clinical, actuarial, and facility/provider network leaders for rapid, clinically appropriate success.
Shore Up Q4 Workplans
The “4th quarter Stars push” has truly become an annual tradition in Medicare Advantage at this point. Every year, we start the year with the best of intentions, but we always wind up with a wild wave of “hail Mary surge effort” as we head into the 4th quarter. In recent years, most of that surge work has focused on closing clinical and medication adherence “gaps in care” – but now that CAHPS measures are 4x weighted, those efforts alone are just not mathematically enough anymore.
And worse, combined with the resurgence of COVID, many of the strategies that have worked in the past are simply no longer as successful as they used to be (appointment scheduling efforts, in-home care to close gaps, etc.). This year’s 4th quarter surge simply must be focused on the whole person – connecting them with the care they need and remedying experiential barriers and challenges as we can learn about them for CAHPS success.
This fall is an ideal time to shift from conceptual CAHPS efforts to mathematized CAHPS strategies.
TOP TIP #5
Design and perform a “smart Mock CAHPS” project. Don’t waste time or money re-analyzing the same members and same issues – rather, perform a high-volume CAHPS proxy survey to gather a robust volume of actual member responses to the actual CAHPS questions. And then use those responses to engage with the right members and solve actual problems.
TOP TIP #6
Expand 4th quarter interventions, both internally and externally, towards clinical and CAHPS measures using the actual data collected during the surveys. Fix member-specific problems to the maximum extent your budget will allow. And use the data collected to infer broader, systematic problems that can be simultaneously solved to prevent future survey risk.
If you need assistance, Healthmine is here to help. From supporting scalable, efficient member engagement to validating your 2022 workplans or providing expert staff augmentation support, our experts have deep Medicare Advantage and Star Ratings expertise and can support your needs for success. For more information, email me at Melissa.Smith@Healthmine.com.