CMS recently released its latest Interim Final Rule, including new guidance on Star measure reporting for Medicare Advantage plans. Despite 2020 being an extraordinary year, CMS is not giving plans a free pass; 2022 Star Ratings will still be calculated. However, plans will have greater flexibility in the data they submit to determine those scores and subsequent quality payments.
With new CMS flexibility, plans may see a temporary lift in Star scores in 2022. But it will likely be short-lived without a sustained focus on member engagement.
That flexibility will likely give plan performance a bump across the board, but those changes will only be temporary. Plans without a sustained focus on member engagement will likely find their higher scores to be short-lived and unsustainable.
So what exactly does all this mean for your plan? Here’s everything you need to know, plus strategic insights to optimize the new flexibility and boost performance both this year and beyond.
CMS: Plans Granted Flexibility in 2020 Star Measure Reporting
CMS is amending the “uncontrollable circumstances” policies for 2022 rating purposes only. Plans will have their 2022 Star Ratings calculated based on data from the current year—or the previous, whichever is better. This gives plans the opportunity to cherry pick, selecting the best data for each individual measure across two years.
In addition, CMS has removed their previous guidance that kept cut points from falling by more than 5% for each measure. The 5% rule will be re-applied in 2021 (affecting 2023 Star Ratings. But in the meantime, measures could fall to lower levels and, because CMS grades on a curve, the standard for 4-Star Ratings may drop as well.
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Icario: Our Strategic Takeaway on the CMS Rule
With this new guidance, many plans may see a temporary lift in Star scores in 2022, and even more plans will achieve a 4-Star Rating. But it’s likely this performance will be short-lived.
In other words, the opportunity to choose 2019 or 2020 data shouldn’t be seen as a pass to coast through the rest of the year. What you’re doing right now to engage members, close HEDIS gaps, and impact Star Ratings is still incredibly important. If you let up, you face the prospect of a one-year uptick, only to fall back in subsequent years without the benefit of these temporary rule changes.
As we like to say, member engagement is a marathon, not a sprint. Rather than take your foot off the gas now, continue to accelerate your member engagement efforts, solidifying your performance to achieve the best 2022 Star Ratings possible. Not only will this boost your quality bonus payments for 2023, it will also set you up for higher scores and payments in years to come.
You can be assured your competitors will be positioning themselves to take advantage of these new rules and advance their Star scores as well. So if you’re standing still, others will bypass you.
Instead, keep your momentum going through the end of the year and focus on improving specific measures, particularly those that didn’t perform well in 2019. With an Icario program boosting communication and engagement, you have the opportunity to move the needle this year—and play the long game for 2021.
