Wednesday, February 23, 2022

CMS Seeks to Level Member Playing Field Via Stars Changes

Today's Featured Story

CMS Seeks to Level Member Playing Field Via Stars Changes

by Lauren Flynn Kelly

Aside from a headline-grabbing estimated pay boost of nearly 8% for Medicare Advantage organizations next year, the Biden administration’s first preliminary rate notice didn’t include many surprises for MA and Part D sponsors. Instead, the notice focused largely on potential changes to star ratings in the name of advancing health equity and monitoring member experience. 

CMS floats compliance-related stars changes 

  • CMS in the Advance Notice of payment updates for the 2023 plan year asked for comment on multiple star ratings enhancements, including the addition of data related to misleading marketing in calculating the Complaints About the Health/Drug Plan (Part C and D) measure, and the potential return of the Beneficiary Access and Performance Problems (BAPP) measure. 
  • These potential changes serve as examples of how the Advance Notice mirrors CMS’s recently proposed MA and Part D rule and of CMS’s renewed interest in having plan compliance be reflected in the star ratings, suggests Jessica Assefa, chief stars officer at ATRIO Health Plans 
  • The proposed rule, for example, seeks to expand the basis on which CMS can deny MA applications based on poor performance and to strengthen beneficiary oversight of third-party marketing organizations, she points out.  

CMS seeks comment on possible equity index 

  • New ideas that CMS floated include developing a Health Equity Index to account for social risk factors in a subset of measures.  
  • “As we further explore this option, we are considering what other data are available and what other SRFs might be appropriate to include over time,” stated CMS.  
  • The agency added that it is considering replacing the current reward factor — which is added to a contract’s overall score for high performance and low variability — with the new index. 
  • The “million-dollar question,” however, is when the index would be implemented, as it’s still highly conceptual at this point, adds Assefa. Once these changes are implemented, though, there could be a “big gap between plans that just haven’t paid attention to this and plans that have been working on social determinants for years in a really meaningful way,” she predicts. 

All told, nothing’s shocking about 8% 

  • To Brad Piper, principal and consulting actuary with Milliman, the 8% revenue increase wouldn’t be so eye-popping if CMS had included an estimated coding trend of 3% to 3.5% in its rate projections for 2022.
  • Given that 2021 risk scores were impacted by diagnoses gathered in 2020, when the COVID-19 pandemic was having its biggest effect on utilization, “it’s hard to say that a 3.5% coding trend would have been a correct assumption for every year, [but] it’s starting to feel like we’re returning to normal,” he adds

From Radar on Medicare Advantage

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