The Stars Impact of the 185-Page CMS Call Letter in 1,000 Words or Less

On April 3rd, CMS released the “Final” 2018 Call Letter. If you have been involved with Stars for long, you know the possibility for surprise changes exists right up through the 2nd Plan Preview period, but the Call Letter at least gives us great visibility into what CMS proposes to do with 2018 Stars and beyond.

NEW: Medication Reconciliation Post Discharge (Part C)

After two years in a row of no new measures, CMS injects one that should do two things.

1. Incent plans to ensure that Medicare Advantage members (specifically 66 and older for this measure) have their medications reconciled after being discharged. This is absolutely the right thing to do. It should result in a better outcome and quality of life for the member who has been discharged to go home. Thumbs up CMS.
2. Having yet another Part C HEDIS measure with strong ties to Part D promises to keep the healthy tension alive between the Quality, Care Management, and Pharmacy areas. Stars teams, it’s time to dust off those Measure Owner grids.

RETURNING: Improving Bladder Control (Part C)

• The band is getting back together! The missing member of the HOS 5 is back. Hopefully, health plans have enjoyed only being scored on 4 HOS measures for two years, as well as a brief hiatus from having to ensure that physicians are discussing urinary incontinence with their members. Vacation is now officially over.

RETIRING: High Risk Medications (Part D)

• HRM is, arguably, the measure physicians hate most. They are aware which medications they prescribe and the associated risks. To have CMS and health plans look over their shoulders and question their prescribing habits drives them mad. They won’t be disappointed to see this measure retire.
• However, this is an important measure that stays on the display page and will likely return from the bench to be a Stars measure again. Plans simply must stay on top of it.

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Additionally, CMS is making specification changes to several existing measures. One notable change is worth mentioning. In 2017, CAHPS 5.0 began being used, with minor changes from the prior CAHPS survey. As a result, the following CAHPS measures are being excluded from the Part C Improvement Measure:

• Getting Care Quickly
• Customer Service
• Care Coordination

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Some key changes were anticipated that did not get implemented in the Call Letter.

• The Beneficiary Access and Performance Problems (BAPP) measure is unchanged.
• CMS has received feedback regarding this measure’s timing, methodology, and relation to such plan penalties as sanctions and CMPs. After consideration, CMS is keeping the current BAPP measure in 2018 Stars.
• CAHPS weights remain unchanged.
• No changes to the analysis or criteria related to the Categorical Adjustment Index, which benefits plans with high vulnerable populations.
• Though CMS continues to look for measures that have topped out that they can remove, none were removed for this reason in 2018. Good news for plans.

Now, let’s look ahead to the 2019 Star Ratings, which requires that we also look back, because the measurement period began three months ago. It’s best to consider them as definite, launch the appropriate programs, and begin measuring performance now.

CMS is proposing to introduce three new measures to the 2019 Star Ratings.

NEW: Hospitalizations for Potentially Preventable Complications (Part C)

• CMS had planned to include this measure in the 2018 Star Ratings. NCQA concerns around unknown reasons for outliers caused CMS to continue it as a display measure for 2018, with plans to make it a 2019 Star Ratings measure. Is your plan an outlier? Does your plan even understand what this measure measures? You’re not alone.

NEW: Statin Therapy for Patients with Cardiovascular Disease (Part C)

• This is a statin-related HEDIS measure that CMS included on the 2017 display page. CMS plans to include it in the 2019 Star Ratings.

NEW: Statin Use in Persons with Diabetes (SUPD) (Part D)

• Unlike the other new statin-related measure above which is a HEDIS measure, this is a Part D measure developed by PQA. CMS plans to make it a 2019 Stars measure.

CHANGING: Colorectal Cancer Screening (Part C)

• Aside from measures that will likely be temporarily removed from Stars, this is the only existing measure that CMS firmly proposes changing for 2019 Stars. In 2016, based on USPSTF recommendations, NCQA revised this measure to include additional screening test options, specifically computed tomography colonography and FIT-DNA. These new test options will now be included in this Stars measure.

TEMPORARY REMOVAL: Beneficiary Access and Performance Problems

• CMS plans to remove enforcement actions and audit-related sanction reductions. If so, CMS would remove this measure and place a revised version on the display page. CMS continues to take feedback from plans regarding this measure’s role going forward.

TEMPORARY REMOVAL: Reducing the Risk of Falling (Part C)

• The band reunion is short lived. NCQA made changes to the HOS survey questions for this measure, which will result in no data for 2019 and 2020 Stars. So long, HOS 5. Look forward to another Reunion Tour possibly in 2021.

NOTEWORTHY:  Plan All-Cause Readmissions (Part C)

The following changes are being explored for this heavyweight measure:

• Include observation stays
• Make overall plan population the denominator
• Include death when risk adjusting this measure

NOTEWORTHY: Non-Recommended PSA-Based Screening in Older Men (Part C)

• The Draft letter proposed this measure as a new 2019 Stars measure. It is no longer being proposed.

FINAL NOTEWORTHY: Two areas of focus

• CMS makes it clear that both care coordination and transitional care will play increasingly important roles in Stars going forward. Keep them in focus.

That sums up the highlights. The Call Letter in its entirety is located here.

Good luck with Stars. Your members deserve all the good that comes their way from all the hard work you and your teams are putting in. Thank you.

rex.wallace@rexwallaceconsulting.com