Relief for Plans Serving Dual Eligibles?

It seems as though the Centers for Medicare & Medicaid Services (CMS) may be taking a detour in their position on the effect of socio-economic characteristics of a plan’s enrollees. Last week, CMS announced plans to release a proposal to change Star Ratings for plans with significant low socio-economic beneficiaries, in a forthcoming request for comment for updates to the program in 2017. CMS stated the agency will release this request for comment by early November.

Although the health industry has voiced their dissatisfaction for quite some time now with the current rating system being applied to dual eligibles, CMS warming to the idea is a bit surprising. Just last month, CMS announced its results from the study, stating that while “research to date has provided scientific evidence that there exists an LIS/Dual/Disability effect for a small subset of the Star Ratings measures, the size of the effect is small in most cases and not consistently negative.” This month, the Medicare Payment Advisory Commission (MedPAC) also chose to postpone making recommendations until it saw what action CMS takes.

While this change in position is welcome, it is unclear whether CMS will actually implement a solution. CMS has previously proposed a temporary solution to reduce the weight of seven measures but, after negative feedback, chose not to implement the proposal. It is also unclear whether this change in position comes from new findings CMS has yet to release or whether it changed its position based on the analysis released from the study last month, where the disparities in measures were found to be “insignificant.”

Until we see whether CMS changes its position on dual eligibles, plans falling below three stars for three years under the current rating system will still face termination, regardless of the number of dual eligible enrollees enrolled in the plan, if they cannot improve their performance to at least three stars.

 Stay tuned.

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