Policymakers are taking various approaches to minimize negative impacts on Medicare Advantage Star Ratings stemming from the coronavirus.
September 04, 2020 - As the coronavirus pandemic
continues to rage across the US, the payer industry must consider how the
current environment will affect Medicare Advantage Star Ratings for years to
come. The industry may need to adapt their engagement strategies around public
policies, Avalere explained in a recent analysis.
The analysis unpacked the policies that are reshaping
Medicare Advantage Star Ratings during the coronavirus pandemic and glanced
into the long-ranging effects that these policies could have.
CMS has taken two major actions to try to counteract the
long-ranging effects that the coronavirus pandemic could have on the Medicare
Advantage Star Ratings Program.
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CMS Temporarily
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·
CMS Reveals Low
Part D Premium, AHIP Warns of Rebate Rule Impact
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How CMS Can
Standardize Prior Authorization Using MA Star Ratings
The agency released its Contract Year
2021 Medicare Advantage and Part D Final Rule, which not only
addressed the Medicare Advantage Star Ratings system but also controversially
expanded end stage renal disease eligibility and expanded telehealth and rural
health plan options.
The rule changed star rating cut points. It also shifted
greater emphasis to patient experience and complaints along with adding more
significance to access measures.
More recently through the Interim Final
Rule, CMS took its second step in reforming star ratings to
account for the effects of the coronavirus pandemic.
“The IFR suspends reporting requirements for Star Ratings in
2020, allowing the CMS to continue to use their 2020 scores,” explained experts
from Avalere in a recent analysis.
“Notably, a suspension in MA Star Ratings data could impact the market for
several years as measurement data is collected 2 years in advance of Star
Ratings being released.”
On top of these CMS actions, the Medicare Payment Advisory
Commission (MedPAC) Medicare Advantage value incentive program proposal could
also have far-ranging impacts.
MedPAC has been pushing this proposal since long before the
coronavirus pandemic. In June 2019, the commission recommended replacing
the Medicare Advantage quality bonus program with the value incentive program,
a plea which it reiterated in its June 2020 report.
In its 2020 report, MedPAC argued that the quality bonus
program does not satisfy MedPAC’s principles for a quality incentive program.
The Medicare Advantage value incentive program, on the other hand, incorporates
five key features.
First, the value incentive program would not overly
emphasize beneficiary experience, but rather it incorporates population-based
measures to assess patient outcomes. Furthermore, the set of measures would
need to be reduced, MedPAC stated.
Second, MedPAC suggested analyzing performance on the basis
of the local Medicare Advantage market.
Third, the value incentive program contextualizes patient
data by implementing peer-grouping. This method incorporates social risk
factors, for example factors that may particularly influence fully
dual-eligible beneficiaries. The commission suggested that by comparing similar
groups of beneficiaries, the scores would both account for plan performance
differences and social risk.
Fourth, plans should receive funding for quality
improvement, not just for hitting above a certain benchmark. This would help
save plans from experiencing a “cliff” whereby they suddenly lose extra funding
after not hitting a specific benchmark. Instead, improved performance should
improve points and, as a result, rewards.
Finally, MedPAC recommended that the funds accrued from plan
payments should be distributed at the local market level in rewards and
penalties based on each plan’s performance compared to its competitors.
Aiming for budget-neutral quality bonuses would affect all
Medicare Advantage plans and could have negative impacts.
“Plans with 4 stars or higher that receive an increase in
their benchmarks could be at risk for losing part or all of their payment ‘bonus,’”
the Avalere experts warned.
Additionally, these impacts go beyond simply the star rating
to also affect plans’ enrollment, premiums, and supplemental benefits.
Other factors that could influence the level of impact
include how many enrollees are low-income or disabled, the plan’s own local
market, and how the plan performs on a population health level, as opposed to
specific conditions or processes.
“Stakeholders can anticipate that these proposed changes may
move separately and can develop customized engagement strategies with the CMS
and Congress around certain components,” the Avalere experts projected.
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