Early Release of Medicare Advantage and Part D Advance Notice:  Part C & D Star Rating Changes

CMS published Part I of the Advance Notice of Methodological Changes for Calendar Year (CY) 2022 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies (the “Advance Notice”) on September 14, 2020.  On October 30, 2020, CMS published Part II of the Advance Notice. Part II of the Advance Notice includes updates for Part C and D Star Ratings and also specifically requests comments on a potential new measure related to the COVID-19 vaccination and whether enrollees received the vaccine when it becomes available.

This earlier-than-anticipated release of the Advance Notice is in keeping with the Center for Medicare & Medicaid Services’ (CMS) intent to provide plan sponsors more time to prepare their bids during the unprecedented pandemic. While the Advance Notice is primarily focused on rates and payment policies, it also contains important Star Rating changes that plans should understand and consider in their planning.

General Updates for Part C and D Star Ratings & Quality Bonus Payment (QBP) Program

New MA Plan Definition  – For the purposes of 2022 QBPs based on 2021 Star ratings only, modifies the definition of a “new MA plan” to mean an MA contract offered by a parent organization that has not had another MA contract in the previous four years. This change affects 2019 new contracts.  Historically, a new contract with an effective date of January 1, 2019 would normally be treated as new for purposes of QBPs for 2019, 2020, and 2021 only; now, such a contract will be treated as new for 2022 as well.

Extreme and Uncontrollable Circumstances – For the 2022 Part C and D Star Ratings (2020 measurement period) and because of the COVID-19 pandemic, most contracts will qualify for disaster adjustments pursuant to the extreme and uncontrollable circumstances policy. Affected contracts will receive the higher of their measure-level ratings from 2021 or 2022 on non-CAHPS measures.

Guardrails – Removes guardrails for the 2022 Star Ratings by delaying their application until the 2023 Star Ratings.

Hold Harmless – Expands  the hold harmless provision for the Part C & D Improvement measures to include all contracts for the 2022 Star Ratings.

Changes to Existing Part D Star Ratings Measures in 2022

Medicare Plan Finder (MPF) Price Accuracy – will be transitioned off the display page and into the 2022 Star Ratings as a new measure.  It will continue to be a process measure with a weight of 1.

Changes to Existing Part D Star Ratings Measures for Future Years

Statin Use in Persons with Diabetes (SUPD) (Part D) – Enrollees are included in the SUPD measure calculation if the earliest date of service for a diabetes medication is at least 90 days prior to the end of the measurement year. As a reminder, the SUPD measure currently excludes enrollees enrolled in hospice or that have end-stage renal disease (ESRD) at any time during the measurement period. Starting with the 2023 Star Ratings (2021 measurement period), the following exclusions will be added: enrollees with rhabdomyolysis or myopathy; pregnancy, lactation, or fertility; liver disease; pre-diabetes; and polycystic ovary syndrome (PCOS).

Changes to Existing Part C Star Ratings Measures in 2022

Controlling Blood Pressure– modified the requirements for out-of-office readings to allow readings taken by an enrollee with any digital device for the 2022 Star Ratings (2020 measurement period).

HEDIS Measures and Telehealth – added additional codes for the 2020 measurement year for several HEDIS measures.  The measures included in this change are:

  • Rheumatoid Arthritis Management – Removed from the denominator the restriction that only one of the two visits with a rheumatoid arthritis diagnosis could be an outpatient telehealth, telephone visit, e-visit or virtual check-in (when identifying the event/diagnosis) and added telephone visit, e-visit and virtual check-in encounter codes to the advanced illness exclusion.
  • Breast Cancer Screening – Added telephone visit, e-visit and virtual check-in encounter codes to identify the advanced illness diagnosis exclusion.
  • Care for Older Adults – Clarified that, for the numerator, services rendered during a telephone visit, e-visit or virtual check-in meet criteria for Functional Status Assessment and Pain Assessment numerator indicators.
  • Controlling High Blood Pressure – Removed the restriction that only one of the two visits with a hypertension diagnosis could be an outpatient telehealth, telephone visit, e-visit or virtual check-in when identifying the event/diagnosis and added telephone visit ,e-visit and virtual check-in encounter codes to identify the advanced illness diagnosis exclusion.
  • Comprehensive Diabetes Care – Removed from the denominator the restriction that only one of the two visits with a diabetes diagnosis could be an outpatient telehealth, telephone visit, e-visit or virtual check-in (when identifying the event/diagnosis) and added telephone visit, e-visit and virtual check-in encounter codes that could be used to identify the advanced illness diagnosis exclusion.
  • Colorectal Cancer Screening – Added telephone visit, e-visit and virtual check-in encounter codes to identify the advanced illness diagnosis exclusion.
  • Osteoporosis Management in Women Who Had a Fracture –Added telephone visit, e-visit and virtual check-in encounter codes to identify the advanced illness diagnosis exclusion.
  • Plan All-Cause Readmissions – Added telephone visits to the Risk Adjustment Comorbidity Category Determination in the Guidelines for Risk Adjusted Utilization Measures.
  • Statin Therapy for Patients with Cardiovascular Disease – Removed the restriction from the denominator that only one of the two visits with an ischemic vascular disease (IVD) diagnosis could be an outpatient telehealth, telephone visit, e-visit or virtual check-in (when identifying the event/diagnosis) and added telephone visit, e-visit and virtual check-in encounter codes to identify the advanced illness diagnosis exclusion.

Potential New Star Ratings Measures for Future Years

Provider Directory Accuracy (Part C) – CMS is soliciting comments on a potential new Star Ratings measure on provider directory accuracy. For example, the measure could consider what percent of plan information is inaccurate. CMS requests feedback on the utility of such a measure, given other requirements for application programming interfaces (APIs), and what it could look like.

COVID-19 Vaccination (Part C) – CMS is soliciting comments on a potential new measure concept related to the COVID-19 vaccination for the 2023 Part C & D performance measure display page and for potential inclusion in the Star Ratings program. As work continues to develop a vaccine for COVID-19, CMS plans to concurrently develop and test question(s) to add to the CAHPS survey administered in early 2022, similar to the flu vaccine. Such question(s) may ascertain whether an enrollee received the COVID-19 vaccine during a specified timeframe (e.g., in 2021) to therefore measure the percent of enrollees who received the COVID-19 vaccine. This is because health plans play an important role to help educate and encourage their enrollees to get the COVID-19 vaccine. CMS requests feedback on the utility of such a measure and any considerations in its development including any potential exclusions.

Changes to Display Measures in 2022

In 2022, CMS will retire the following measures from the display page:

  • Timely Receipt of Case Files for Appeals (Part D)
  • Timely Effectuation of Appeals (Part D)
  • Drug-Drug Interactions (Part D)
  • Antipsychotic Use in Persons with Dementia – for Community-Only Residents (APD-Comm) (Part D)  –  This measure will also be removed from patient safety reporting. The overall Antipsychotic Use in Persons with Dementia (APD) and Antipsychotic Use in Persons with Dementia – for Long-term Nursing Home Residents (APD-LTNH) measures will remain on the display page.
  • Use of Opioids at High Dosage and from Multiple Providers in Persons Without Cancer (OHDMP) (Part D)  – This measure will also be removed from patient safety reporting. The Use of Opioids at High Dosage in Persons Without Cancer (OHD) and Use of Opioids from Multiple Providers in Persons Without Cancer (OMP) measures will remain on the display page.
  • Drug Plan Provides Current Information on Costs and Coverage for Medicare’s Website. (Part D)

CMS will add, modify or announced plans to make future changes to the following measures on the display page:

  • Kidney Health Evaluation for Patients With Diabetes (Part C) – This measure will be added to the 2022 display page and CMS will consider adding it to Star Ratings through future rulemaking.
  • Controlling Blood Pressure (Part C) – In 2022, this measure will remain on the display page for the second year.  This measure, with substantive changes to the measure specification, will return to the 2023 Star Ratings.
  • Plan All-Cause Readmissions (Part C) – This measure will be on the display page for the 2022 and 2023 Star Ratings. This measure, with the substantive changes to the measure specification, will return to the 2024 Star Ratings.
  • Polypharmacy: Use of Multiple CNS-Active Medications in Older Adults (Poly-CNS)/ Polypharmacy: Use of Multiple Anticholinergic Medications in Older Adults (Poly-ACH) (Part D) – These measures will remain on the display page.  In 2023 (2021 measurement period), CMS will implement substantive changes to the measure specification and it will remain on the display page.

Reminders for 2022 Star Ratings

CMS provides various data and reports to plans sponsors throughout the year.  CMS encourages plan sponsors to regularly review  their underlying measure data and immediately notify CMS if errors or mistakes are identified and can be resolved prior to the first plan preview period. CMS announced a deadline of June 30, 2021 for all contracts to make requests for review of the 2022 Star Rating appeals and CTM measure data.