Star Ratings: 10 Years, 10 Lessons
The Star Ratings program celebrates its 10th birthday this year. In honor of the first decade of quality ratings systems within managed care, and to celebrate the many lessons we've learned during these formative years of the Star Ratings program, here are 10 of our top lessons from the first 10 years of the program.
- Success is not easy. Not only are Star Ratings constantly evolving, but the ever-changing regulations and Centers for Medicare & Medicaid Services (CMS) guidelines surrounding Medicare Advantage and Part D prescription drug benefit plans and the increasingly competitive Star Ratings environment make Star Ratings success a continuous, often challenging battle. Evolution is difficult, and every detail matters.
- One size does not fit all. Every health plan has a unique culture, strategic plan, and relationship with its members and providers. And every health plan has a unique combination of vendors, analytical tools, systems, and business decisions that support its culture and strategic vision. As a result, every Star Ratings work plan is similarly unique. Customization, personalization, and tailoring is vital for success.
- All healthcare is local. Every provider network is unique and has a unique combination of systems, tools, programs, priorities, and business decisions through which it provides clinical services to your members. And every group of members presents its own unique prevalence of conditions, expectations of local physicians, and social and lifestyle patterns. As a result, every Star Ratings work plan is unique.
- Social determinants of health are a lynchpin to achieving and sustaining high quality ratings. Critical gaps between clinical care and community services exist in the current healthcare delivery system. CMS Innovation Model tests are underway to systematically identify and address the health-related social needs of beneficiaries while evaluating their impact on total healthcare costs, improved health, and quality of care. Star Ratings success on challenging triple-weighted measures is far easier accomplished when plans simultaneously support the clinical, social, and lifestyle needs of their members.
- Easy, understandable, and contextually-appropriate requests (of members and providers) are most successful. Systems work best if they are kept simple rather than made complicated; Star Ratings is no different. Whether we are asking our members or our providers to take action, simplicity should be a key goal and external-facing, unnecessary complexity should be avoided.
- Converting "big data" into "actionable intelligence" is key. Include carefully selected clinical, pharmacy, and Health Risk Assessment data elements for efficient, holistic success.
- Member and provider interactions and programs are most successful with carefully targeted investments. This requires data-driven strategic planning, close alignment of routine operations with Star Ratings measure needs, and consistent execution of well-planned processes.
- Manual workarounds and tactics likely won't sustain success over the long term. When data and reports are manually built or Star Ratings-impactful activities occur outside of system-driven workflows, Star Ratings success isn't easily scalable. As the principles and foundation built during the first 10 years of Star Ratings expands into the Health Insurance Marketplace, Medicare Fee-for-Service, and managed Medicaid, this is an excellent time to reengineer any manual activities into sustainable workflows.
- The physician-patient relationship is the foundation for high-quality healthcare. Support members' physician relationships wherever possible and augment where/how needed by developing personal relationships between carefully-selected members and a care coordinator.
- "Best Practices" are often claimed as "best" before they have been carefully evaluated for wide-scale adoption. And don't forget — a best practice is only a best practice until it becomes standard practice.
For questions or inquiries about how Gorman Health Group can support your organization's Star Ratings efforts, please contact me directly at msmith@ghgadvisors.com.
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Advancement in Analytics
It's all about the numbers! As the Centers for Medicare & Medicaid Services (CMS) tries to quantify more and more aspects of government-sponsored healthcare, metrics are a critical component.
Metrics are needed to measure quality programs, returns on investment in patient care, redistribution of staffing and financial resources, as well as benchmarking.
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is a perfect example of how CMS is pushing this financial focus. The past few years of shared savings models for Fee-for-Service members have evolved into very strict timelines and formulas that will directly impact the financial performance of providers in addition to the intended impact on improving member experience and quality of care.
As providers and health plans now have to walk this tightrope of real and projected results with multiple stakeholders (regulators, health plans, providers, members, and third parties), the necessity of analytics and good internal reporting are now of utmost importance.
The best tool to manage these priorities and resources is to have a solid reporting mechanism. Whether you are a start-up or an existing organization, the need for an integrated data repository cannot be ignored. Multiple vendors can help with specialized needs like population health or customized provider scorecards, but the sources have to be integrated. For a provider, this means to coordinate efforts with vendors and multiple health plans or payers. For a health plan, this means to coordinate efforts with vendors and payers as well as from within the health plan organization. Once the data is normalized and complete, reports and dashboards can be built, but keeping an eye on the whole organization is critical to recognize trends as they occur. The "whack a mole" analogy is appropriate — if you focus on one area, you might see improvement, but another area could suffer. You have to look at all areas.
We understand systems must be integrated to help identify actionable strategies. A gap analysis might be needed to assess organizational issues, procedures for reviewing the data to identify problems and their solutions, as well as timing — once a year budget variance reports will not be sufficient. Deep dives into specific problem areas are also critical — making sure you are looking for outliers (regardless of overall performance). Even if the organization does not change, the providers and members and regulations will change. This is a constant effort.
Recognizing the industry will spend nearly $600 billion on healthcare technology by 2020, we have built external, strategic partnerships, facilitated the development of internal solutions, and staffed a team of industry leaders to address this market trend in analytics. Our niche division cannot only connect Gorman Health Group clients with the solutions that are the best fit for their organization, the Healthcare Analytics team can ensure the governance of exiting systems and the investments in new technology are both implemented and optimized.
Let us help you keep your eye on the numbers and find solutions that will bring a return to satisfy all stakeholders.
Resources
On June 7, 2016, Daniel Weinrieb, Gorman Health Group's (GHG's) Senior Vice President of Healthcare Analytics & Risk Adjustment Solutions and colleagues, David Sayen, Senior Vice President of Client Relations and Melissa Smith, Senior Consultant, recapped the details of the MACRA proposal and how these changes will affect providers, health plans, the care delivery system, and patients. Download the webinar recording here >>
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Why Is Conducting a Part D Operational Assessment so Important?
Medicare Part D is a complex program that is continually in motion. The Centers for Medicare & Medicaid Services (CMS), in an attempt to provide clarity to stakeholders, actively publishes updated guidance to sponsors to assist in process improvement and encourage optimal beneficiary outcomes and experience. Keeping up with Health Plan Management System (HPMS) memos, best practices, yearly call letters, and webinar information is challenging. Dynamic and ever-changing guidelines inevitably bring uncertainty and risk. Understanding these guidelines and operationalizing a compliant program is key to a successful program and financial sustainability.
For an organization to succeed in this fluid environment, it must achieve higher quality and Star Ratings, improve beneficiary satisfaction and retention, while staying on top of compliance and operational efficiency. CMS expects all plan sponsors to carefully and regularly evaluate risks to their organization. Emphasis is placed on compliance, identification and prevention of fraud, waste, and abuse (FWA), and oversight of first-tier, downstream, and related (FDR) entities. Additionally, in recent years, there has been increased focus on coverage determinations, appeals, and grievances. All of these areas can have an impact on a plan's Star Ratings and financial outlook.
Conducting a comprehensive operational assessment is an excellent strategy to identify a plan's strengths and weaknesses and evaluate the adequacy and reliability of operations. Information is gathered and evaluated from multiple sources such as current policies and procedures, oversight activities, reports, and operational processes. Comprehensive evaluation of this information will proactively identify areas of risk, allowing plans to strategically adapt to the changing environment to reduce identified risks. Gorman Health Group, with our team of industry experts, can provide an assessment of areas of greatest risk exposure along with solutions based on best practices, ensuring the organization is well positioned for future success.
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Our broad array of services can assist you in post-audit remediation, implementation of best practices, PBM contracting and implementation, interim staffing, clinical process re-engineering, Star Ratings improvement, and claims and PDE assessment and adjustments. Visit our website to learn more about our Part D services >>
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Health Plans Need to Start Talking About Disparities in Care
On the heels of a recent groundbreaking RAND report on racial disparities in Medicare Advantage (MA), the US Department of Health & Human Services' Office of Civil Rights (OCR) issued a regulation that requires serious attention in health plans participating in MA, Part D, Medicaid, and ObamaCare. It's a game-changer in advancing health equity and reducing disparities.
The new regs, implementing Section 1557 (the nondiscrimination provision) of the Affordable Care Act, prohibit discrimination, marketing practices, or benefit designs that discriminate on the basis of race, color, national origin, sex, age, or disability. This will escalate disparities from simply being a "quality improvement need" to being a huge compliance issue. It goes without saying that an investigation of your plan by the civil rights cops splashed across local news would be devastating. As the Centers for Medicare & Medicaid Services (CMS) has begun more aggressively using their data to identify these disparities, health plans certainly should begin doing the same.
The final rule prohibits sex discrimination in healthcare, including by:
- Individuals cannot be denied healthcare or health coverage based on their sex, including their gender identity and sex stereotyping. These last two items are of particular importance given transgender policy enforcement is relatively new. OCR has prosecuted cases recently where transgender patients were discriminated against in hospital admissions and room assignments, denying mammograms to transgender females, denial of gender reassignment surgery as "cosmetic," and harassment by medical transport drivers.
- Women must be treated equally with men in the healthcare they receive and the insurance they obtain. OCR has prosecuted several cases recently where hospitals assigned male guarantors when a wife obtained services but not the other way around.
- Categorical coverage exclusions or limitations for all healthcare services related to gender transition are discriminatory.
- Individuals must be treated consistent with their gender identity, including in access to facilities.
- Sex-specific health programs or activities are permissible only if the entity can demonstrate an exceedingly persuasive justification.
The regs also include important protections for individuals with disabilities and those with limited English proficiency by:
- Requiring covered entities to take appropriate steps to ensure communications with individuals with disabilities are as effective as communication with others.
- Covered entities must post a notice of individuals' rights, providing information about communication assistance, among other information.
- Covered entities are required to make all programs and activities provided through electronic and information technology accessible to individuals with disabilities, unless doing so would impose undue financial or administrative burdens.
- Covered entities cannot use marketing practices or benefit designs that discriminate on the basis of disability.
- Covered entities must make reasonable changes to policies, practices, and procedures, where necessary, to provide equal access for individuals with disabilities.
- Requiring covered entities to make electronic information and newly constructed or altered facilities accessible to individuals with disabilities and to provide appropriate auxiliary aids and services for individuals with disabilities.
- Requiring covered entities to take reasonable steps to provide meaningful access to individuals with limited English proficiency. Covered entities are also encouraged to develop language access plans.
Resources
CMS recently announced the release of the 2017 Medicare Marketing Guidelines for Medicare Advantage Organizations and Part D Sponsors, which include added language, clarifications, and new requirements. Join Regan Pennypacker, GHG's Senior Vice President of Compliance Solutions, and Carrie Barker-Settles, Director of Sales and Marketing Services, on Tuesday, June 28, from 1-2 pm ET, to discuss what provisions in the final guidelines will have the greatest impact on your organization and how plan sponsors can prepare for the upcoming changes. Register now >>
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Latest Sherlock Benchmarks Confirm Medicare Advantage is a Miserable Beast to Manage
The geniuses at Sherlock Company, whose benchmarks on health plan administrative standards are considered the gold standard, have released their 2016 findings and the numbers paint a clear picture: Medicare Advantage (MA) is a miserable beast of a product. It's complicated and labor- and capital-intensive, requiring tremendous patience for executives and investors alike.
First: Sherlock's benchmarks confirm that MA requires nearly double the staff per 10,000 members as do commercial group products, and nearly triple that of Medicaid managed care. Much of this staffing is driven by unique requirements in the "Account and Membership Administration Cluster" (Enrollment / Membership / Billing, Claim and Encounter Capture and Adjudication, Customer Services, and Information Systems.)
Second, successful MA management requires big investments and, above all, patience. Sherlock found investments in Medical Management, Star Ratings and Sales/Marketing in Medicare takes at least a year, and often much longer, to show results.
Third, Sherlock demonstrates seniors are high utilizers of customer services relative to all other insured populations, and low costs are not optimal costs. Plans that spend little on service typically suffer worse member retention, membership growth, and customer satisfaction. MA members have longer service handle times, higher appeal rates, much higher rates of claims inquiries, and are less likely to utilize automated call systems.
The upshot? Once you master MA, all other lines of insurance business are a walk in the park in comparison. If this was an easy business, we'd be out of business.
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More than 200 health plan clients and an additional broad range of other industry participants each year trust Gorman Health Group's team of professionals to deliver expert counsel and tools to help them meet their goals. We pride ourselves on having both day-to-day alignment with the latest CMS guidance and the long-term strategic vision to keep it all in perspective. Contact us today >>
Under the provisions of the 2015 Medicare Access and CHIP Reauthorization Act (MACRA), physicians and other practitioners will face a Hobson's choice: live with a more aggressive risk-based adjustment to payments or join forces with an alternative delivery model, like an Accountable Care Organization (ACO), that is taking risk. Read the full article >>
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An Important Component of MACRA: Quality Measures Development Plan
The Centers for Medicare & Medicaid Services (CMS) recently released a proposed regulation that will implement the payment incentives through the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). An important component of these new incentives is the Quality Measure Development Plan (MDP), which CMS finalized and posted this week. The purpose of the MDP is to create a strategic framework for the future of quality measure development to support MIPS and advanced APMs.
Under MIPS, clinicians will see a payment adjustment beginning in 2019 based on their performance score across four performance categories: quality, resource use, clinical practice improvement activities, and advancing the use of information technology. Under advanced APMs, payments must be tied to quality measures comparable to those quality measures used under MIPS. These quality measures will be developed by CMS by November 1, 2016, as required by MACRA, and CMS will utilize this new MDP to guide the development and implementation of these new measures. CMS currently has an ongoing solicitation to stakeholders to assist in finalizing the initial set of measures.
CMS will also incorporate the seven core measure sets recently released by the Core Quality Measures Collaborative, a partnership between America's Health Insurance Plans (AHIP), CMS, and other industry groups. The plan notes its focus on coordinating with federal agencies and other stakeholders in order to lessen the duplication of efforts within the industry and promote person-centered healthcare.
The MDP notes current known measurement and performance gaps and solutions to close these gaps through new quality measures. For the first measure set, the MDP posted the initial priorities for measure development in six quality domains: clinical care, safety, care coordination, patient and caregiver experience, population health and prevention, and affordable care. CMS will update the MDP as they identify new gaps in measurement and performance in order to develop additional quality measures annually.
In reviewing the recent MACRA legislation for potential changes, and putting together comments to CMS, organizations should also carefully review the new Quality MDP in order to ensure their comments are incorporated into the release of the first set of measures by November 1, 2016.
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CMS recently released the proposed rule that sets forth the replacement for the Sustainable Growth Rate (SGR) formula and creates the new payment system based on value rather than volume. Daniel Weinrieb, GHG's Senior Vice President of Healthcare Analytics & Risk Adjustment Solutions, along with our team of experts will provide a detailed analysis as well as industry recommendations. Stay tuned!
The ABCs of Member Satisfaction
Member satisfaction. Customer centricity. Member retention. Consumer experience. Regardless of the term used, the Consumer Assessment of Healthcare Providers and Systems (CAHPS®) survey measures continue to be the common denominator by which the Centers for Medicare & Medicaid Services (CMS) measures a health plan's success, creating a positive member experience. CAHPS® survey responses now represent 16% of a Medicare Advantage (MA) plan's overall Star Rating, and an additional 33% is comprised of member-reported health outcomes and administrative measurements of member access and experience. With approximately 50% of the overall Star Rating now driven by some element of the member's experience, many health plan leaders now better appreciate the value of consistently providing members with excellent service and a positive experience.
I recently had the pleasure of listening to a group of members from a variety of MA plans share their health plan experiences with industry leaders. Though health plan discussions regarding member experience are often abstract and very general in nature, listening to the experiences of actual members is always a refreshing way to remind ourselves not only what a privilege it is to service the healthcare needs of Medicare beneficiaries but also how emotionally our "routine hiccups" impact members. Not surprisingly, this group of MA members shared stories that illustrate we've still got room for improvement in our quest to create a 5-star customer experience. The experiences of these members spotlight some of the ABCs for a successful member experience:
Access — When members discover providers with closed panels, struggle to make timely appointments with physicians, experience arduous referral or service authorization requirements, or are unable (even if only temporarily) to obtain medications at the retail pharmacy, we reduce the likelihood of the member reporting positive experiences with our plan on their CAHPS® survey. Because many problems have multiple and/or multi-layered root causes, use of a technique such as the "5 Whys" can efficiently and effectively support root cause analysis of issues so impactful improvements can be rapidly deployed.
Better Communication — Many plans struggle to effectively communicate with members and often compensate by over-communicating to members, particularly via low-cost channels such as mail and IVR. By carefully crafting outreach strategies, letters, mailings, and scripts and using each member's preferred communication channel(s), plans can improve the effectiveness of their communications and demonstrate customer-centricity to members.
Coordination and Clinical Context — During the early years of Star Ratings, many plans deployed measure-specific tactics and interventions which were often conducted by disparate teams. In many cases, such tactics were implemented without anyone "connecting the dots" to ensure such strategies passed the "common sense" test from the member's perspective or that such tactics were appropriate within the clinical context of the member's overall health status. By strategically planning and developing outreach scripts and workflows, leveraging Health Risk Assessment (HRA) and claims data, and developing effective business rules through which to identify member interventions, plans can identify the right intervention for the right member at the right time.
Determination and Decision-making — Organizations with a sustained, strong customer experience are intensely focused on consistently making decisions that deliver value to their customers and meet customer expectations. This requires persistent determination, particularly as problems arise which necessitate process improvements or additional resources to resolve. Transforming a health plan into a consumer-focused organization with strong CAHPS® measure performance often requires a new or refreshed consumer focus within each operational area (from benefit design to care management to customer service to sales/marketing) supported by an effective customer experience leader and customer experience governance structure.
The member experience will continue to be a necessary core competency as the industry evolves over the next few years. Gorman Health Group (GHG) understands this can be challenging, both logistically and politically.
Whether your plan needs help establishing an effective member experience or member communication strategy, cataloging and evaluating existing member communications, or identifying opportunities to streamline and strengthen the return on investment from existing materials, tactics, or interventions, we can help. For additional questions and inquiries about how GHG can support your organization's member experience efforts, please contact me directly at msmith@ghgadvisors.com.
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Today you need to identify opportunities to increase your score for next year, implement an enterprise-level strategy, and carefully monitor your progress over the next plan year. We can help you every step of the way with our full portfolio of GHG practices, products and services.Visit our website to learn more >>
Our distinguished team of experts collaborated to provide our interpretation of this announcement and the key features that will have the greatest impact on the industry, emphasizing core business functions in Risk Adjustment, Provider Network, Quality, Compliance, Pharmacy, and Data Integrity. Download our full Summary & Analysis of the Final Rate Announcement & Final Call Letter >>
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Where is Healthcare Now? The Long March to Value-Based Care.
"Why won't the Centers for Medicare & Medicaid Services (CMS) let health plans gather some health information at the point of sale?
How is CMS going to use the data they are collecting?
What is CMS going to do when the first round of Accountable Care Organizations (ACOs) comes to an end?"
At the Gorman Health Group 2016 Forum in Fort Worth, these and other questions were on the minds of our clients. It can be challenging to guess what the agency will do going forward in an election year when the water is choppy. But that forecast is a critical factor in your planning.
In "The March to Value-Based Payment," I described something that is a long march indeed. The Republican-driven Medicare Modernization Act of 2003 ushered in the attenuation of payments to hospitals, first for quality reporting and soon after for quality results. Then, the Affordable Care Act driven by the Democratic Obama Administration doubled down on this "good government" approach. The program was extended to more provider types, outcomes and efficiency were added to the measures, and we began to see downside risk associated with less-than-average performance.
Under the provisions of the 2015 Medicare Access and CHIP Reauthorization Act (MACRA), physicians and other practitioners will face a Hobson's choice: live with a more aggressive risk-based adjustment to payments or join forces with an alternative delivery model, like an Accountable Care Organization (ACO), that is taking risk. The goal moving forward is to render unto Caesar what is Caesar's: the government is willing to bear the risk associated with each patient's demographic characteristics and health history. They will render unto providers the risks of inefficiency and poor performance. This could encourage more doctors to choose alternative payment models like ACOs or to affiliate with Medicare plans. Are you ready?
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The Gorman Health Group 2016 Forum concluded last week with over 200 of our closest clients and partners. There was great news and rough news, so here are a few takeaways >>
Our distinguished team of experts collaborated to provide our interpretation of this announcement and the key features that will have the greatest impact on the industry, emphasizing core business functions in Risk Adjustment, Provider Network, Quality, Compliance, Pharmacy, and Data Integrity. Download our full Summary & Analysis of the Final Rate Announcement & Final Call Letter >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG's weekly newsletter. Subscribe >>
Takeaways from the Gorman Health Group 2016 Client Forum
The Gorman Health Group 2016 Forum concluded last week with over 200 of our closest clients and partners. There was great news and rough news, so here are a few takeaways:
- The playing field of government programs continues to expand rapidly, with improving revenue outlook across the board:
- We're sticking by our projections of over 29 million Medicare Advantage (MA) enrollees by 2023, driven by more positive rate trends and a plan-friendly baby boomer tsunami underway.
- Six to eight more states expand Medicaid — once President Obama leaves office.
- Significant enrollment gains for dual eligibles as home and community-based services (HCBS) waivers and managed long-term services and supports (MLTSS) initiatives become the new normal. We expect dual eligible special needs plan (D-SNP) enrollment to double and exceed 4 million by 2019.
- Rising ObamaCare enrollment, albeit slowing and below projections, as more difficult-to-reach populations remain outside coverage.
- During the Forum, United announced its departures from most ObamaCare Marketplaces. We characterized the news as a nothingburger in terms of enrollment or market impact but huge symbolically and politically. We expect another two to three messy years sorting out the pricing and finances of the Marketplace business, with membership reconciliation and cleanup of membership discrepancies front of mind for issuers.
- Risk Adjustment Data Validation (RADV) audits will begin to be conducted in MA — 2016-2018 will be the first time we see plans prosecuted under the False Claims Act and hundreds of millions clawed back by the Centers for Medicare & Medicaid Services (CMS) for unsubstantiated codes submitted for higher payments.
- Clinical and pharmacy data integration and strong provider partnerships around person-centered care were clear priorities in medical management, Star Ratings improvement, and Pharmacy Benefit Manager (PBM) oversight.
- The Star Ratings system of performance-based payment drives the payer and provider markets. This year will be the first year where plans below 3 stars are terminated. It's also when another 180+ MA plans will be scored for the first time, diluting ratings for existing plans, especially those at 4+ stars and denying many their bonuses and rebates in what promises to be an ugly "October Surprise."
- The turbulent Presidential elections will likely be won by Hillary Clinton, promising continued gridlock with a likely weakened and more polarized Congress. This means CMS will increasingly fight out policy changes "below the waterline" in subregulatory guidance and enforcement, where politicians are less likely to intervene. That means more surprises for plans not paying attention.
- Appeals and grievances and pharmacy benefit management vendor performance remain the #1, 2, and 3 regulatory infractions in MA and integration of long-term care and supports and services the leading challenge facing Medicaid health plans.
- CMS is on pace for its most aggressive enforcement year ever, with over a dozen actions taken against plans this year already.
As we've said since the passage of the Affordable Care Act, we are now in the Golden Age of government-sponsored health programs, and the opportunities and challenges that come with this shift have never been greater. Our clients went home with a clear grasp of both, and we are thrilled so many joined us this year.
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Our distinguished team of experts collaborated to provide our interpretation of this announcement and the key features that will have the greatest impact on the industry, emphasizing core business functions in Risk Adjustment, Provider Network, Quality, Compliance, Pharmacy, and Data Integrity. Download our full Summary & Analysis of the Final Rate Announcement & Final Call Letter >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG's weekly newsletter. Subscribe >>
CMS Largely Holds Firm on Most Proposed MA Payment & Policy Changes for 2017
On April 4th, the Centers for Medicare & Medicaid Services (CMS) issued the Final Notice of Methodological Changes for Calendar Year (CY) 2017 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies, and 2017 Call Letter. This is the final notice of changes in rates of payment and overall policy.
CMS finalized most of its proposals from the Advance Notice and Call Letter, however did make some notable changes:
- Rates and Trend: The final trend is 3.12% inclusive of underlying trend and prior period adjustments. The underlying trend was slightly higher than estimated while the correction to the prior period was lower than expected (0.14%), so in the end, the trend nets out close to the original estimate. CMS estimates a 0.85% increase of all-in rates.
- Normalization Factor: CMS notes a technical error which affected the proposed normalization factors in the Draft Call Letter. The normalization factor was updated from 0.993 to 0.998.
- Encounter Data: CMS will increase the use of encounter data-based risk scores to 25% in 2017, instead of 50% as proposed in the Draft Call Letter.
- Employer Group Waiver Plans (EGWP): CMS is finalizing its new policy for calculating EGWP county payment rates, with two modifications. First, CMS will blend individual market plan bids and EGWP bids from 2016 for 2017, in order to allow for a two year transition period. Second, CMS will use prior payment year information to calculate base payment amounts in order to release the final EGWP payment rates in the Rate Announcement instead of August as previously expected. It is also important to note that while the methodology waives the bidding requirements, MA EGWPs must still submit plan benefit package and formulary in accordance to the 2017 Final Call Letter.
- Star Reduction Policy: As noted in a March HPMS memo, CMS is suspending the reduction of the overall and summary Star Ratings of contracts that are under sanction, while CMS re-evaluates the impact of sanctions, audits, and CMPs on the Star Ratings. CMS plans to describe the new proposals in Fall 2016.
- Low rated plans to be terminated: Although CMS will continue with termination of plans falling below 3 stars, CMS announced it may ‘stay' a termination, including notification of beneficiaries, if the organization holding the poorly-rated contract is prepared to consolidate that contract into a higher rated contract during the bid cycle for the upcoming plan year.
The following major proposals were finalized as proposed:
- Risk Model for Dual Eligibles: Although the proposed methodology will be implemented, data will be updated, so the original estimated rate impact by category may change. Despite the new rate impact, organizations should still expect increase in payments for non-institutional full-duals and reduced payments for all other categories. CMS estimates a net impact on rates of -0.6%.
- Stars dual Interim Adjustment: CMS is moving forward with its proposal to apply the Categorical Adjustment Index factor to overall, Part C Summary and Part D Summary Ratings as an interim solution to account for the Star Ratings impact of dual-eligible and disabled beneficiaries.
- Opioid Overutilization: CMS is finalizing its proposal to combat opioid overutilization by implementing new edits to prevent overutilization at the Point of Sale (POS). CMS expects sponsors to implement either a soft edit or hard edit, or use both as originally proposed in the draft Call Letter, and work toward at minimum a hard edit in 2018.
Compliance Updates:
- CMS again reminds Part D sponsors that it is stepping up enforcement actions on coverage disputes and complaints, the leading noncompliance issue for plans.
- Plans failing financial audits conducted on one-third audits will now also be subject to sanctions and civil money penalties
- CMS is ramping up audits and enforcement actions in network adequacy, provider directory accuracy, and medication therapy management programs.
These are just the major highlights of from CMS' Final Notice and Call Letter. Stay tuned for Gorman Health Group's (GHG's) industry experts summary and analysis of the final changes for 2017, coming out shortly. questions about the summary? Contact us to start a dialogue.
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New Webinar! Join us TODAY from 1-2 pm ET for a hard-hitting analysis of the final rulings in the 2017 MA rate announcement and final Call Letter. We will outline the critical areas that will have the greatest impact on the industry, emphasizing core business functions in Risk Adjustment, Provider Network, Quality, Compliance, Pharmacy, and Data Integrity. Register Now >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG's weekly newsletter. Subscribe >>