After much anticipation, CMS released the 2024 Medicare Star Ratings on Friday, October 13. And wow, was it worth the wait. As strongly suspected, the impact of Tukey has put to rest any doubt that CMS is requiring new and greater accountability and ownership for Medicare Advantage (MA) plans to do more for their members.
In many ways, the changes outlined in Friday’s announcement came with little surprise. CMS has been signaling since the end of the pandemic that the days of loopholes and gimmickry were over and that plans would need to deliver on the Triple Aim if they expect Medicare Advantage to remain profitable.
From the stage at RISE National in Colorado Springs, Inspector General Christi Grimm set the expectation that MA plans would need to do more than just code gaps—they’ll need to close them. CMS’s announcement of the forthcoming Health Equity Index sent the message that those gaps need to be closed for all members, not just those who are most engaged. And at the NCQA Health Innovation Summit last fall, Peggy O’Kane encouraged Mickey Tripathi at DHS to bring back greater emphasis on clinical measures and outcomes. Weeks later, CMS released its guidance reducing CAHPS from 4-weight measures to 2-weight measures. Taken together, these changes sent strong signals to the industry that CMS was intent on putting teeth into 2024 Stars—and it shows in the Star Ratings performance revealed on Friday.
43% of plans earned 4 Stars or higher for 2024, down from 51% in 2023. While 8% may not seem like a lot, it translates to an estimated 2.4 million members no longer being in a 4-Star Rated plan (even with 74% of members remaining in a 4-Star Rated plan). MA plans that have fallen back at the start of the Annual Enrollment Period should brace for member attrition since consumers use Star Ratings as one element in their decision making when choosing a plan.
Key Highlights of 2024 Star Ratings
Tukey Outlier Deletion
The application of Tukey has reset cut points for every measure. While only a one-year adjustment to help stabilize overall ratings and to help create better future cut point prediction, it has had an impact on nearly every plan. Average Star Ratings fell from a high of 4.37 in 2022 (following the post-COVID “best of” methodology) to 4.04 in 2024, which is roughly the same level we saw in 2021.
Tukey was the leading reason for the decreases in 2024 Star Ratings. The 229 MA-PD plans that maintain 4.0+ Star Ratings have a distinct advantage in this marketplace. Nearly three quarters of all MA-PD members belong to a plan with four or more Stars. Put another way, if your plan isn’t performing at a 4-Star level, you’re only competing for about a quarter of the MA market.
What’s a Plan to Do?
Lean into the new cut points and recognize that this isn’t an accident. CMS is declaring to MA plans that it cannot sustainably continue to pay for grade inflation. Moving members from engagement to action is the only way to ensure that Star Ratings are “Tukey-proof.”
2024 Star Ratings kept CAHPS as 4-weighted measures and for plans who scored high it paid off. Those that played “money ball” with CAHPS and successfully invested in member experience and satisfaction in the last few years have seen a boom in performance that frequently offset by other (HEDIS) measures that were not weighted as heavily. But with CAHPS weights coming back down to earth, plans that took their eye off the ball in clinical measures will need to redouble their efforts to ensure their performance doesn’t continue to drop.
What’s a Plan to Do?
Reinvest in those tried-and-true HEDIS measures. All in all, HEDIS measures continue their downward slide year-over-year with cancer screenings and diabetes care seeing the most alarming (and avoidable) declines. The takeaway? Plans can’t take HEDIS for granted and count on CAHPS scores to save their Star Ratings. Get cancer screenings done. Make sure your members with diabetes are doing their HbA1c tests and eye exams. Motivate members to keep their blood pressure under control. All while you gauge your members’ satisfaction with their care, their network, and your plan. Sometimes the best answers are the simplest ones.
Three New Star Ratings
A few new ratings came on the scene for 2024, and they are more than tangentially related to one another:
- Plan All-Cause Readmissions
- Transition of Care
- Follow Up for Emergency Department for High-Risk Chronic Members
Put simply, CMS is acutely aware that 14% of hospitalized Medicare beneficiaries wind up back in the hospital within 30 days of discharge at an average cost of $15,200 per readmission (that’s $57.6 billion). Keeping members from returning to the hospital for the same thing that sent them there in the first place is a cornerstone of Stars in 2024.
What’s a Plan to Do?
First of all, real-time data has never been more important. The Follow Up for Emergency Department for High-Risk Chronic Members measure has a seven-day window. That’s not seven days to make contact with the member, that’s seven days to get them seen. Your plan needs to:
- Leverage ADT, HIE, and EHR data to ensure timely outreach to members.
- Use every available channel to engage discharged members; member abrasion takes a back seat to getting them seen.
- Use telehealth resources whenever possible to ensure members aren’t waiting on a provider in your busy network.
Finally, because these are Part C measures, it’s likely that many MA-PD plans will overlook the importance of the medication side of readmissions. But it’s worth noting that a 2018 peer-reviewed journal article reported that 21% of all 30-day hospital readmissions were due to medications, and of those, nearly 70% of them were preventable. These new Part C measures, coupled with the Part D side, mean that medication reviews and accuracy have never been more important to your Star Ratings.
What’s on Our Radar for 2024
The National Committee for Quality Assurance (NCQA) will move away from flu performance based on CAHPS survey responses. As such, the annual flu vaccine measure would move from saying “Yes, I did it,” to an actual claim. With a continued decrease of the flu utilization measure across all markets, plans will face new challenges in getting members to get their flu shots should CMS move forward with this change.
Controlling Blood Pressure
Back as a Star Measure in 2023, plans frequently struggled with this measure because claims weren’t being captured and coded correctly. 2023 was a year of CBP chart chasing. In 2024, with this measure now being triple weighted, it will require even greater attention and diligence as it carries more weight in a plan’s overall Star Rating.
Kidney Health Evaluation for Those with Diabetes
Beginning in 2024, members will need two tests—both a blood test for kidney function (estimated glomerular filtration rate [eGFR]) and a urine test for kidney damage (urine albumin-creatinine ratio [uACR]) to complete the measure. Members and providers will need to be aware of the change in these requirements in order to move the numerator; member and provider education will be critical.
Quality Improvement – Removal of Hold Harmless
Historically, plans that were rated overall 4.0+ and above had the opportunity to remove negative scores from this measure. However, beginning in 2024, CMS is now only allowing this for 5.0-Star Plans, and as such, the pressure is on to maintain quality across all measures.
The Digital Experience in CAHPS
CMS is adding a digital survey for the first time ever to CAHPS. As Icario has seen, Medicare members are growing in their digital savviness and CMS is taking notes. We’ll be watching the rise of respondents who choose the digital versus mail path and the downstream impact to other CMS surveys such as the Health Outcomes Survey (HOS).
Set Your Strategy for 2024
Don’t wait and assume your strategy will come to you. Talk to Icario’s Stars experts today to set a strategy for 2024 and beyond. Together, we can achieve the goals you have for your members and your plans.