Part II of the CY 2022 Advanced Notice: Continued Evolution of the Medicare Advantage Star Ratings

On October 30, 2020, CMS surprised plans with the early release of Part II of the CY2022 Advance Notice. Per CMS, this earlier-than-anticipated issuance may allow for the early publication of the CY 2022 Rate Announcement. This would provide plans with more time to prepare their bids and would provide some level of certainty during this unprecedented global health pandemic.

Part C & D Star Rating updates (detailed in Attachment IV of the notice) have health plans continuing to adjust strategies and recalculate their unique mathematical routes to 4 & 5-Star attainment.

Key Updates from Part II of the Advance Notice

  • A series of Star Year (SY) 2022, COVID-19 related changes adopted in an effort to reduce provider impact (issued in the March 31, 2020, Interim Final Rule): 
    • Delay of guardrail application until the 2023 Star Ratings,
    • Expansion of the hold-harmless provision for the Part C & D Improvement measures to include all contacts for SY 2022, and
    • Revision of the definition of a “new MA plan” (for SY 2021) to mean an “MA contract offered by a parent organization that has not had another MA contract in the previous 4 years”.
  • The COVID-19 IFC (CMS-3401-IFC) issued on August 25, 2020, which modifies the Extreme and Uncontrollable Circumstances (EUC) policy for SY 2022 to allow nearly all plans nationally to receive the higher of SY ‘21 or SY ‘22 measure-level ratings. 

 CMS also reminds plans of the changes and allowances that were made to measures and their specifications effective SY ‘22, including:

  • Replacement of the Medicare Plan Finder (MPF) Price Accuracy measure with the re-specified version that has been on display,
  • Modification of the Controlling Blood Pressure (CBP) measure to allow readings taken by a member with any digital device for the 2020 measurement year, and
  • Addition of outpatient telehealth, telephone visits & e-visits as qualifying numerator/denominator events for numerous HEDIS measures and for HEDIS advanced illness exclusions. 

These modifications help ensure MA recipients have access to needed care in the current COVID-19 environment.

Additional Updates on the Horizon

For SY 2023 (MY 2021), CMS proposes the use of the updated PQA measure specification recommendations for Statin Use in Persons with Diabetes (SUPD). The updates include a list of additional exclusionary criteria and limit denominator inclusion to beneficiaries whose earliest date of service for diabetes medication is at least 90 days prior to the end of the MY.

CMS also introduced the new Kidney Health Evaluation for Patients with Diabetes (KED) measure to the SY 2022 display page. Health plans should watch for future announcements that could propose the addition of this measure to the Ratings (and the potential retirement of the current CDC-Kidney measure) as early as MY 2022 (SY 2024).

A surprise to many payers is the 1-year delay in returning the revised Controlling Blood Pressure & Plan All-Cause Readmissions measures to the Ratings. These delays will allow each measure the codified 2-full-years of data on display prior to returning them to the Ratings in SY 2023 & 2024, respectively.

Future Star Rating announcements forecast continued change and complexity as evidenced by CMS’ potential introduction of a new COVID-19 vaccination measure to the 2023 display page (with possible future inclusion in the Ratings, pending rulemaking). This new measure would be added to the CAHPS survey administered in the Spring of 2022 and would mirror the current flu vaccine measure. CMS is also soliciting comments on the development of a potential new Provider Directory Accuracy measure, a significant pain-point for most plans!

CMS will accept comments on both parts I & II of the CY 2022 Advance Notice through Monday, November 30th. Many plans seek clarity around the impacts of the EUC policy revision to specific measure sets and methodologies as well as the proposed timelines for the retirement of CDC-Kidney & MRP as a stand-alone measure, the addition of TRC, FMC & KED, and detail surrounding proposed changes to the 3Xs weighted HOS measures Improving Physical Health & Improving Mental Health. We anticipate the release of one more Final Rule prior to the close of the calendar year.

Stars 101 Workshop

GHG’s Senior Directors of Stars, Jessica Assefa and Cynthia Pawley-Martin, are leading a Stars 101 Workshop at the Strategic Solution Network’s upcoming Medicare Star Ratings & Quality Assurance Summit on December 1-3, 2020. 

Their workshop titled, “How to Build and Grow Your Stars Program to Integrate All Measures” will include an in-depth review of the technical Star Ratings framework and data sources, as well as a deep dive into the technical specifications for measures used in Star Ratings.

This event is FREE to all health plans and providers. If you haven’t already, click here to register today!