Is Your Part D Stars Program Ready to Ring in the New Year?

On April 12, 2023, Centers for Medicare & Medicaid Services (CMS) published the 2024 Final Rule that postponed moving the three polypharmacy measures (Concurrent Use of Opioids and Benzodiazepines, Polypharmacy Use of Multiple Anticholinergic Medications in Older Adults, and Polypharmacy Use of Multiple Central Nervous System Active Medications in Older Adults) from the Display page until at least the 2025 measurement year. As a result, Part D sponsors have an extra year to implement new interventions and/or measure the effectiveness of existing interventions before these measures become part of the Star Ratings.

The 2024 Final Rule also finalized several smaller revisions that may require plan sponsors to adjust their Stars programs for the 2024 measurement year.

First, CMS is changing from the existing member-years (MY) calculation to the continuous enrollment (CE) methodology used by the Pharmacy Quality Alliance (PQA), starting with the 2024 measurement year for the Medication Adherence for Diabetes Medication, Medication Adherence for Hypertension (RAS Antagonists), Medication Adherence for Cholesterol, and Statin Use in Persons with Diabetes (SUPD) measures. As a comparison, a member who is enrolled in the plan for 6 out of 12 months counts as 0.5 MY in the rate calculation, while CE includes the “whole” member as long as there were no enrollment gaps longer than 31 days for SUPD or 1 day for the three adherence measures. As part of the conversion to CE, CMS is also adjusting the inclusion criteria for SUPD to use the member’s age at the start of the measurement year, regardless of whether they age in or out during the measurement year.

CMS determined that changing from MY to CE is a non-substantive change, but their analysis of the SUPD measure, for example, found that only 88 percent of beneficiaries included in the measure using MY were also in the denominator using CE. Part D sponsors who use targeted interventions should assess their targeting specifications compared to the CE methodology to ensure that interventions are delivered to the correct members.

Other measures that use the member-years calculation, including Concurrent Use of Opioids and Benzodiazepines, Polypharmacy Use of Multiple Anticholinergic Medications in Older Adults, and Polypharmacy Use of Multiple Central Nervous System Active Medications in Older Adults will be converted to CE for a later measurement year.

CMS also finalized the reweighting of the patient experience, complaints, and access measures from 4x to 2x, starting with the 2026 Star Ratings. While this change reduces the weight of the Complaints about the Drug Plan and Members Choosing to Leave the Plan measures for the 2024 measurement year, plan sponsors should keep in mind that the Call Center – Foreign Language Interpreter and TTY Availability, Rating of Drug Plan, and Getting Needed Prescription Drugs measures still carry 4x-weighting for 2024 data collection (2025 Star Ratings).

Finally, the 2024 Consumer Assessment of Health Providers & Systems (CAHPS) survey will include a web-based mode that CMS anticipates will improve survey response rates. Part D sponsors can work with their CAHPS survey vendor to include additional survey questions in order to take full advantage of survey responses.

Now is also a good time to review the list of the Star and Display measure datasets and reports that CMS provides throughout the year. While CMS has not changed the availability of this information, Part D sponsors should ensure that staffing and other changes have not left them unprepared to review the information and identify potential errors prior to the Stars plan preview periods. For full details, plan sponsors can refer to the April 17, 2023 HPMS memo “Information to Review Data Used for Medicare Part C and D Star Ratings and Display Measures” until CMS releases the corresponding memo for 2024. Part D sponsors can also review the 2025 proposed rule that CMS released on November 15, 2023, for potential future changes to Star Ratings.