Navigating CMS’ Proposed Star Ratings Program Changes

The Centers for Medicare & Medicaid Services (CMS) announced several regulatory updates to better align Medicare Advantage plans over the next three measurement years with the Triple Aim, which seeks to improve patient care, reduce healthcare costs and improve population health.

Amidst these complex technical and operational changes is the secret to unlocking stronger quality scores and advancing quality care for all members. Healthmine’s Expert Advisory Services team categorized, analyzed and strategized around the big and small changes tucked away in the 2024 CMS Proposed Rule and the 2024 CMS Advanced Notice in an in-depth webinar moderated by Kent Holdcroft, Chief Growth Officer. Speakers included:

• Melissa Smith, Executive Vice President, Consulting & Professional Services
• Kimberly Swanson, Senior Vice President, Consulting & Professional Services
• John Willis, Vice President, Consulting & Professional Services

Each presenter shared their perspective on how these changes will impact Star Ratings calculations, health equity, data collection and stratification, and quality measure reporting. Watch the on-demand webinar and access the presentation slides to understand where you need to direct resources, staff and time to get ahead of these proposed changes to reach and maintain four or more Stars.

Member Experiences and Digital Transformation

The triple-weighted Consumer Assessment of Healthcare Providers and Systems (CAHPS) measures have long been a challenge for health plans looking to unlock four or more Stars. While CMS has proposed bringing them back down to double-weighted and removing the 15-minute wait time CAHPS question, Smith identified another big change: web-based surveys. Smith noted that this shift to digital formats is a running theme, citing the implementation of digital clinical quality measures, prior authorization and member engagement.

“CMS is moving the industry away from old modalities of direct mail and phone into a proper, modernized environment,” says Smith. “They’re looking for us to go digital. This is one more sign that we are to use the technology tools available to us at maximum capacity.”

Tukey Outliers and Cut Point Calculations

CMS has officially selected the Tukey Outlier Deletion Methodology as the standard statistical model for determining cut points. Through this methodology, outlier scores that heavily impact the mean Star Ratings will be removed from the final calculations. This will increase the minimum threshold for cut points when calculating Star Ratings and potentially suppress scores by removing statistically outliers at a contract level. As a result, it will be harder for plans to achieve three, four or five Stars, but it will stabilize calculations year-over-year by surpassing statistical anomalies.

Measure Changes at a Glance

Alongside the Tukey method, a significant amount of measure changes is set to evolve how Star Ratings are calculated and where plans focus their attention over the next three years. These changes are the result of a variety of initiatives, including:

• Moving from medical chart reviews to electronic clinical data systems for four of the longest standing measures.
• New eligibility requirements for screenings protocols to incorporate transgender and gender diverse members into measure calculations.
• Adding new active and display measures to Medicare Advantage to stimulate innovative strategies that empower the industry to address substance abuse, behavioral health and chronic disease management.
• The return of the two Health Outcome Survey measures for Improving or Maintaining Physical and Mental Health to monitor how a member’s health changes over time.
• Limiting the Hold Harmless provision for the Improvement measures to only five-Star plans and making it more challenging for four- to four-and-a-half-Star plans to improve or maintain the scores.
• Replacing the Rewards Factor with the Health Equity Index to incentive plans to reduce health disparities for marginalized populations.

Rethinking the Bid Process

Addressing the many changes coming out of CMS rests upon the ability to prioritize what can be done today to future-proof plan performance and how to set yourself up for success against future challenges. Your 2024 CMS Bid is the perfect starting point for building the infrastructure and tools that foster healthy behaviors among members to influence quality scores. The more diverse, precise and comprehensive a bid is, the better capable quality teams will be at achieving the new normal for Medicare Advantage.

Priorities and Predictions

Our Expert Advisory Services team dug into specific technical changes, quality improvement priorities, Stars predictions and insightful questions submitted by attendees during the webinar. Some highlights included:

• Will the Health Equity Index only impact high performing plans or are all plans eligible for the Stars boost?
• How will the Tukey method influence cut point calculations for measurement year 2021 and 2022?
• When will colorectal cancer screenings convert to electronic clinical data systems?
• Does the return of Health Outcome Surveys signal the removal of Reduce Fall Risk and Improve Bladder Control questions from the survey?

The Expert Advisory Services team has decades of experience helping plans understand and address Star Ratings challenges since the program’s inception. Fill out the form to access the on-demand webinar to explore how to incorporate their insights into CMS’ Proposed Rule and Advanced Notice into your quality improvement strategies.