What the CY2027 Final Rule means for Medicare Advantage quality strategy, and why 2026 is the year that decides 2029.
CMS finalized the most significant structural overhaul of the Star Ratings program in over a decade. The agency is removing 11 measures focused on administrative processes and on areas where beneficiaries cannot distinguish performance between plans because performance is high and varies little across contracts. CMS is not implementing the Excellent Health Outcomes for All reward (previously called the Health Equity Index reward) and will continue the historical reward factor. A new Part C Depression Screening and Follow-Up measure is being added, beginning with the 2027 measurement year and the 2029 Star Ratings. CMS estimates the combined changes will increase Medicare payments to plans by approximately $18.56 billion over ten years.
Most of the market coverage has focused on which measures are leaving. The more consequential question is what happens to the measures that stay.
What’s Being Removed, and When
Despite the CY2027 label, nothing in this rule changes the 2027 Star Ratings measure set. The earliest impact arrives with the 2028 Star Ratings, drawn from measurement year 2026, which is already underway. The bulk lands with the 2029 Star Ratings, drawn from measurement year 2027. Because three of the removed measures are scored separately under both Part C and Part D, the 11 measures translate into 13 individual rating factors.
| MEASURE | CODE | PART | LAST RATINGS YEAR |
|---|---|---|---|
| Statin Therapy for Patients with Cardiovascular Disease | C19 | C | 2028 |
| Call Center – Foreign Language Interpreter & TTY Availability | C33 | C | 2028 |
| Call Center – Foreign Language Interpreter & TTY Availability | D01 | D | 2028 |
| SNP Care Management | C07 | C | 2029 |
| Customer Service | C24 | C | 2029 |
| Rating of Health Care Quality | C25 | C | 2029 |
| Complaints about the Health Plan | C28 | C | 2029 |
| Complaints about the Drug Plan | D02 | D | 2029 |
| Members Choosing to Leave the Plan | C29 | C | 2029 |
| Members Choosing to Leave the Plan | D03 | D | 2029 |
| Plan Makes Timely Decisions about Appeals | C31 | C | 2029 |
| Reviewing Appeals Decisions | C32 | C | 2029 |
| Medicare Plan Finder Price Accuracy | D07 | D | 2029 |
Call Center – Foreign Language Interpreter & TTY Availability, Complaints about the Plan, and Members Choosing to Leave the Plan are each scored separately under Part C and Part D. CMS proposed 12 removals and finalized 11, retaining Diabetes Care – Eye Exam.
The pattern is unmistakable, and CMS stated its intent directly: to refocus the measure set on “clinical care, outcomes, and patient experience of care measures where performance is not topped out and where there is more variation in performance across contracts.” What remains is clinical quality, medication adherence, and member experience.
The Weighting Effect Few Plans Are Modeling
For many plans, the removed measures are their weakest performers. On its face, their departure appears to deliver an automatic lift to the composite rating.
In practice, that assumption does not hold reliably. When low-scoring administrative measures leave the calculation, the measures that remain carry proportionally more weight. A plan holding steady at 3 stars across its HEDIS and adherence measures, while relying on removals to lift the average, should expect the arithmetic to move against it by 2029.
The market backdrop compounds the problem. Per CMS’s 2026 Star Ratings Fact Sheet, the enrollment-weighted average MA-PD Star Rating declined from 4.14 in 2023 to 3.98 in 2026, and roughly 40% of MA-PD contracts earned 4 Stars or higher. Fewer measures mean each remaining measure carries more weight and more exposure to single-measure movement, in a market where the margin for error was already thin.
“Once the operational measures are gone, a flat clinical trajectory stops being stability and starts being decline. The plans that understand that trajectory in 2026 will still have time to change the outcome. The plans that wait for the 2027 ratings to confirm it will be reading a result they can no longer influence.”
A Framework for Diagnosing Where You Actually Stand
Before building a recovery plan, sort every declining measure into one of four categories. The category determines both the intervention and the realistic timeline.
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OPERATIONAL FAILURES
Recoverable • fast ROI
High-performing service measures that collapsed on process breakdowns rather than clinical gaps. The infrastructure already exists, which makes these the fastest return. Several appear on the removal list, which tempts plans to deprioritize them. We would caution against that, as these measures continue to drive member experience, quality accreditation, and CAHPS.
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NEW MEASURES
Cold start • build the pipeline
First-year measures where plans enter with no baseline and no historical data. Thresholds can be stringent enough that a plan achieves a strong raw rate and still scores 1 star. Depression Screening and Follow-Up is the immediate case. The screening-to-follow-up data pipeline needs to be built now, not in 2027.
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CHRONIC CLINICAL GAPS
Not improving • long-term battleground
Measures stuck at 1 or 2 stars for multiple years. These represent the long-term battleground, and they gain weight as removed measures exit. No near-term remedy exists, which is precisely why the work must begin early.
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GRADUAL DECLINE
Preventable • fix regardless
Measures trending down roughly one star per year. Some will exit after 2027, but the underlying operational cause usually touches member experience, Health Plan Accreditation, and population health initiatives well beyond Stars.
What Changes in 2027 Beyond Removals
Separately from the removals above, the measure set is already shifting for the 2027 Star Ratings. Those changes are driven by prior rulemaking rather than the CY2027 Final Rule. Measures are added, removed, respecified, and re-weighted within the same cycle. Plans tracking only the CY2027 removals risk being unprepared for changes already in motion.
The draft technical guidance now circulating for the 2027 ratings year reinforces that direction and adds operational detail that is easy to overlook. It confirms the weight increase for the two health-outcomes measures, the respecified screening and functional status measures entering at weight 1, and the two new Part D patient-safety measures. It also signals a lower enrollment threshold for several Part D measures, pulling smaller contracts into measures they were previously excluded from, and a scaled reduction of up to four stars on the Part C appeals measures where reported data cannot be confirmed as complete. Draft guidance is not final, but it shows where the operational bar is being set.
| MEASURE | STATUS | WHAT IT REQUIRES |
|---|---|---|
| Care for Older Adults – Functional Status Assessment | Enters at weight 1 | Historically difficult to score consistently. Rebuild assessment workflow and documentation. |
| Concurrent Use of Opioids and Benzodiazepines | Enters at weight 1 | Pharmacy coordination and prescriber outreach. |
| Polypharmacy: Use of Multiple Anticholinergic Medications in Older Adults | Enters at weight 1 | MTM and deprescribing workflows. A natural home for redirected MTM resources. |
| Colorectal Cancer Screening | Respecified | Expands to ages 45–49. The expanded age group is excluded from improvement calculations for the year. |
| Statin Therapy for Patients with Cardiovascular Disease | Exclusion added | A statin intolerance exclusion is added before the measure exits with the 2028 ratings. |
| Care for Older Adults – Pain Assessment | Removed | Redirect assessment resources rather than retire the workflow outright. |
| Medication Reconciliation Post-Discharge (standalone) | Removed | Still drives Transitions of Care and readmissions, so keep the process running. |
| MTM Program Completion Rate for CMR | Moved to display page | May return following re-specification. Redirect pharmacy resources to the new opioid and polypharmacy measures, but do not dismantle the infrastructure. |
Source: CMS, 2027 Star Ratings Measures. Improving or Maintaining Physical Health and Improving or Maintaining Mental Health also increase in weight, reinforcing CMS’s focus on outcome-based performance.
The Timing Argument
2027 ratings are effectively locked and publish ahead of the October 15 Annual Enrollment Period. Nothing a plan does this fall changes that outcome.
What this fall does change is 2028 and 2029. The 2026 measurement year is already underway. Every week spent on 2027 postmortem analysis is a week not spent on the performance period that is actively being scored.
Plans that treat 2026 as the operational planning year will enter 2029 with two full performance periods of advantage. Plans that wait until the 2027 ratings land and then begin strategizing will not recover that time.
2026 MEASUREMENT YEAR
Underway now
Performance being scored today. This is the year you can still influence.
2027 RATINGS YEAR
Locked
Publishes ahead of the October 15 AEP. No further action changes it.
2028 RATINGS YEAR
3 rating factors exit
From measurement year 2026. Statin Therapy and both call center interpreter/TTY factors drop out.
2029 RATINGS YEAR
Remaining factors exit • Depression Screening debuts
From measurement year 2027. Clinical and experience measures now carry the rating.
Recommended Actions This Quarter
- Re-weight your forecast without the removed measures. Model your 2029 overall rating using only the measures that will still exist. If the result is lower than your current rating, you have your priority list, and confirmation that removals alone will not carry you.
- Separate care gaps from data gaps. Before funding a clinical intervention, determine whether the care is genuinely not happening or simply not visible. Care management platforms, HRAs, lab feeds, and EMRs routinely capture events that meet HEDIS numerator criteria but never generate a claim. Measuring the wrong problem wastes a full performance year.
- Audit the operational measures you are tempted to abandon. Call center, customer service, and appeals timeliness still count toward the 2027 and 2028 ratings, and they continue to drive CAHPS, accreditation, and regulatory exposure well after they exit the rating calculation. These measures warrant investment on their operational merits, independent of their Star Ratings value.
- Confirm Stars accountability reaches someone with authority. Measure-level performance depends on quality, care management, pharmacy, network, and data teams acting together. Where a governance structure cannot assign a named owner and a deadline to a specific measure, improvement plans rarely withstand the demands of the operating year.
How BluePeak Helps
BluePeak Advisors partners with health plan leaders to improve clinical quality outcomes, optimize Stars measure performance, strengthen accreditation readiness, and operationalize regulatory change through executive advisory and hands-on implementation support. Stars is one component of a broader performance agenda spanning quality, revenue protection, accreditation readiness, operational excellence, and regulatory preparedness. Our service model spans five core areas:
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01 ANALYTICS
Measure-level analytics and benchmarking, plan-by-plan and year-over-year
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02 PRIORITIZATION
Strategic focus on the measures with the highest leverage per unit of effort
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03 CLINICAL OPTIMIZATION
Clinical program improvement, workflow redesign, and care-gap closure
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04 DATA CAPTURE
Supplemental clinical data strategy, validation, and compliant reporting
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05 REGULATORY READINESS
CMS and NCQA Change Management impact translated into a roadmap
Engagements begin with a structured review of quality, care management, HEDIS, CAHPS, pharmacy, and data operations, the same inputs CMS and NCQA scrutinize, so recommendations are grounded in how the plan actually runs rather than what the documentation says. Scope ranges from a performance assessment through a full improvement roadmap and implementation support.
Start the conversation before your 2027 measurement year begins.
Sources: CMS Fact Sheet, Contract Year 2027 Medicare Advantage and Part D Final Rule (Apr 2, 2026); Federal Register, 91 FR 17384 / CMS-4208-F3 & CMS-4212-F (Apr 6, 2026); CMS, 2027 Star Ratings Measures; CMS, 2026 Medicare Advantage and Part D Star Ratings Fact Sheet; CMS, Recalculated 2026 Categorical Adjustment Index Values for 2027 Quality Bonus Payment Ratings; CMS Part C & D Star Ratings Technical Notes. All figures reflect CMS’s published data and regulatory analysis. Analysis and recommendations are BluePeak Advisors’.
