By Sara Ratner November 9th, 2020
With the challenges created from the COVID-19
pandemic, CMS released Parts I and II of the 2022 Advance Notice earlier than
usual. Here’s what you need to know.
On October
30th, the Centers for Medicare and Medicaid Services (CMS) issued Part II of
the 2022 Advance Notice of Methodological Changes for Medicare Advantage. Parts
I and II have historically been published in December or January, and as late
as February, respectively, as the proposed announcements are required to be
issued at least 60 days prior to the first Monday in April. With the challenges
created from the COVID-19 pandemic, CMS released Parts I and II much earlier.
There is consideration around publishing the Rate Announcement earlier in 2021
to give plans more time to prepare their bids. With this time frame in mind,
CMS is on track to release the Rate Announcement in the January/February
timeframe.
Part I of
the 2022 Rate Announcement was released on September 14th, 2020 and primarily
focused on risk adjustment changes. Under the CY2022 proposal, CMS will
calculate 100% of the risk score using the 2020 CMS-HCC model. This means that
100% of risk scores will now be based on Encounter Data (EDS) and FFS claims.
CMS proposes to end use of RAPS inpatient diagnoses to supplement encounter/EDS
data, and to end the blending of encounter data-based and RAPS-based risk
scores. This proposal is expected to increase revenue a quarter of a point.
There are
several changes announced through Part II. The CMS 2022 Advance Notice proposes
an increase of 4.82% to the National Per Capita MA Growth Percentage, which is
not as large as the increase from the 2021 Final Announcement of 5.62%. This
ultimately translates into a new rate 2.82% rate increase. The Advance Notice
reaffirms changes announced earlier in 2020 that pertained to removing cutpoint
guardrails, expansion of the hold harmless for improvement measures, and
application of the extreme and uncontrollable circumstance policy for
calculating the 2022 Star Ratings (for which almost all plans qualify). In
addition, the Medicare Plan Finder (MPF) Price Accuracy measure was re-
specified and will be transitioned off the display page and into the 2022 Star
Ratings as a new measure. CMS will continue weighting it as a process measure
with a weight of 1.
There are
several non-substantive changes to 2022 Star Ratings which permit additional
data sources as part of the measure.
1.
Controlling
Blood Pressure (Part C). Modification
to the requirements for out-of-office readings to allow readings taken by a
member with any digital device for the 2020 measurement year.
2.
HEDIS
Measures and Telehealth (Part C).
Modifications were issued to the following measures that enable the greater use
of telehealth (telehealth, telephone visit, e-visit, virtual check-in) in
identifying those excluded from the Star Rating due to advanced illness:
·
Rheumatoid Arthritis Management
·
Breast Cancer Screening
·
Controlling High Blood
Pressure
·
Comprehensive Diabetes Care
·
Colorectal Cancer Screening
·
Osteoporosis Management in Women Who
Had a Fracture
·
Statin Therapy for Patients with
Cardiovascular Disease
CMS also
proposed several changes to existing Star Ratings. One important change relates
to Statin Use in Persons with Diabetes (SUPD) (Part D) which changed the index
prescription start date for the SUPD measure to at least 90 days prior to the
end of the measurement year. This means that beneficiaries 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. This
is important as this measure moved from a weight of 1 to 3 in the most recent
Star Ratings.
In addition
to non-substantive changes above, any substantive changes made must remain on
the display page for at least two years. With this in mind, Controlling Blood
Pressure will be delayed and remain on the display page and used in calculating
2023 Star Ratings. In addition, Plan All-Cause Readmissions will return to the
display page for 2022 and 2023 Star Ratings and used in calculating 2024 Star
Ratings.
There are
several market trends worth noting that will influence future strategy. Plans
that lost at least half a Star did so by losing ground on Part D. Star
reductions were a result of Part D losses at a rate of almost three to one
compared to Part C losses. Separately, plans that increased at least half
a Star did so through a balanced approach with a cause ratio of .84 to 1,
reflecting a Part C and D improvements trend in a near 1 to 1 ratio. At a
corporate level, five parent companies accounted for 45% of all declining
plans. Of note, these five parent companies hold more than 60% of the market
share of all MA enrollment nationwide, and accounted for 86% of net enrollment
growth between 2015 and 2018.
In testing
new approaches and concepts, CMS is soliciting feedback on two new measure
concepts. The first, Provider Directory Accuracy, is a new proposed Star Rating
that considers the percent accuracy of plan information. The second relates to
the potential for including a COVID-19 vaccination measure on the display page
for potential Star Rating inclusion. Concurrently, CMS will test 2022 CAHPS
survey questions related to COVID-19 vaccinations similar to those related to
flu vaccines.
The Advanced
Notice continues to reinforce CMS’s commitment to telehealth and enabling
engagement while creating accommodations to support the hardships created by
COVID-19. Personalized messaging continues to be critical to drive member
health action that improves outcomes and is accretive to Star Ratings. With
COVID-19 a central focus, health plans will also need to prepare for future
changes, measures, and ratings centering on managing changes during the
pandemic and programs critical to member health and prevention.
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