Key Points about Star Ratings from the CMS 2015 Draft Call Letter
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1 News From February 24, 2014 Key Points about Star Ratings from the CMS 2015 Draft Call Letter On February 21, 2014 CMS released the 2015 Draft Advance Notice and Call Letter for Medicare Advantage plans. The final version will be released on April 7, Comments are being accepted and must be submitted by Friday, March 7 th. TMG has put together the following summary of the 2015 Draft Call Letter portion of the document, specifically as it relates to the Star Ratings. The full document with additional content is available here. CMS received 115 comment letters following the Request for Comments sent out in November, Those comments were considered as part of the development of the Draft Call Letter. Low Performing Plans CMS plans to terminate, effective December 31, 2014, those contracts that have failed to achieve a three-star rating for Part C or D in any of the 2013, 2014, or 2015 sets of ratings. CMS advises contracting organizations to examine their star rating performance history and assess their level of exposure to the risk of having CMS terminate their Medicare contract based on Star Ratings before the start of the 2015 contract year. Special Needs Plans CMS received several comments arguing that special allowances should be made for SNP plans, but maintains that the current Star Rating methodologies adequately address differences between SNP and other MA enrollees. They advocate for a single standard of care for all MA beneficiaries. New 2015 Measure CMS intends to add the following to the 2015 Star Ratings. It will be assigned a weight of 1 since it will be a first year measure. Special Needs Plan (SNP) Care Management Completion of annual health risk assessments Changes to Measures for 2015 Star Ratings Additional clarification about how changes to measure specifications impact the Star Ratings: If the specification change has been announced in advance of the measurement period, there is no need to move the Star Ratings provides experienced resources, support, and solutions to Medicare Advantage plans across the nation. Contact Us Today Info@themyersgroup.net Stars improvement resources and recommendations Medication adherence outreach campaigns MTM program registration and scheduling of Comprehensive Medication Reviews (CMRs) Medicare CAHPS administration with in-depth analysis and reporting Health assessments Appointment scheduling and reminder calls Experienced OEV telephone agents
2 News From measure to the display page. If the specification change is announced during the measurement period and impacts the denominator or population covered by the measure, the measure will be moved to the display page for at least one year. If the change does not impact the denominator of the measure, CMS will continue to include it in the Star Ratings. CMS is modifying the methodology for the following measures: Part C Breast Cancer Screening Change to impact 2016 Star Ratings. This measure will move to the display page for the 2015 Star Ratings. Modification reflects changes in HEDIS 2014 to appropriate age ranges. Annual Flu Vaccine The flu shot question in CAHPS will be changed to ask members if they have received a flu shot since July of each year instead of September. The pre-determined 4 star threshold will be eliminated for the 2015 Star Ratings due to the change. Part D High Risk Medication This measure will use the updated Pharmacy Quality Alliance (PQA) HRM list Medication Adherence for Diabetes Medication CMS is adding two additional drug classes. Beneficiary Access and Performance Problems (Part C & D) This measure will move to the display page because of significant methodological changes. Change to the audit score calculation. Medication Adherence Measures The three medication adherence measures will be adjusted to account for members with hospice enrollment or Skilled Nursing Facility (SNF) stays. The Part D sponsor would not be responsible for providing prescription refills for these medications. Only standalone PDPs have SNF data available for the adjustment. All plans offering Part D will have hospice information available. Note: CMS received a number of comments about supplemental pharmacy data. The reporting of any PDE data that has not been submitted directly by network pharmacies or beneficiaries is prohibited, and CMS encourages Part D sponsors to develop incentives for network pharmacies to submit claims under the plan unless beneficiaries have explicitly requested otherwise. Obsolete National Drug Codes (NDCs) CMS will implement the PQA s specification change to account for obsolete NDCs. Retirement of Measures CMS plans to remove the Glaucoma Testing (Part C) measure for the 2015 Star Ratings. 2
3 News From Contracts with Low Enrollment CMS has determined that contracts with 500 or more enrollees in July of the HEDIS measurement year have sufficient data to reliably report Star Ratings. These contracts in most cases will have sufficient data to produce both overall and Part C and D ratings. CMS will delay for one year including Star Ratings for these contracts on Medicare Plan Finder to allow time for additional experience collecting and analyzing this data. Beginning with the 2016 Star Ratings, contracts with 500 or more enrollees as of July 2014 will be included in the 2016 Star Ratings, on the Medicare Plan Finder, and used for QBPs (quality bonus payments). The HEDIS data for contracts with less than 500 enrollees will continue to be posted on the display page. Data Integrity CMS will continue to take steps necessary to protect the integrity of the data. CMS audits and other investigations have consistently shown that sponsors fail to follow requirements for forwarding Part C denials and auto-forwarding untimely Part D initial coverage determination or redetermination requests to the IRE. If erroneous or biased data has been submitted, it is CMS s policy to reduce the measure rating to 1; however CMS is interested in suggestions for other options to ensure accurate measure data. For example, audits conducted at the contracts expense or incremental reductions to measures based on the number of errors found. Changes for Measures Posted on the CMS Display Page Measures to remain on display page for 2015 Pharmacotherapy Management of COPD Exacerbation (PCE) (Part C) Initiation and Engagement of Alcohol and Other Drug Dependence Treatment (IET) (Part C) Medication Therapy Management Program Completion Rate for Comprehensive Medication Reviews (Part D) Measures being considered for the 2015 display page CAHPS measures about contact from a doctor s office, health plan, pharmacy, or prescription drug plan (Part C) CAHPS Health Information Technology EHR measures (Part C) Transition monitoring (Part D) Combined Medicare Plan Finder (MPF) Price Accuracy (Part D) Disenrollment Reasons (Part C and D) Measures with proposed specification changes for the 2015 display page Drug-Drug Interactions Measure (Part D) Diabetes Medication Dosing (Part D) Enrollment Timeliness (Part C and D) 3
4 News From Proposed Weighting Changes CMS is considering changing the weights for the improvement measure and the three Medication Adherence measures. Improvement Measure: CMS is proposing to increase the current weight of 3 to 5 for the 2015 Star Ratings. Medication Adherence: CMS is seeking feedback through the current comment process of reducing the weights of each for these three measures from 3 (outcome measure) to 1.5 (access measure) for the 2015 Star Ratings. They will continue to consider future alternative measures of clinically significant non-adherence, which would be weighted as outcomes measures (3x). Forecasting to 2016 and Beyond CMS plans to remove the pre-determined 4 star thresholds beginning with the 2016 star ratings. CMS is concerned that using whole-star individual measures and pre-determined 4 star thresholds results in a loss of information when aggregating to the levels of overall and summary ratings. There will be no changes to the 4 star thresholds for the 2015 Star Ratings. Data analyses of past Star Ratings found plans on average have more significant levels of improvements in Part C and D measures without pre-determined thresholds, as compared to measures where CMS has pre-set thresholds. CMS plans to move to this new scoring methodology for the 2016 Star Ratings by removing the pre-determined measure thresholds. They will continue to use the Reward Factor (previously called the I-Factor/Integration Factor). CMS will provide contract-specific information on the impact of removing the 4 star thresholds to HPMS following the release of this Draft Call Letter. CMS is monitoring additional measures being developed by NCQA, including a measure of potentially avoidable hospitalizations and measures of depression screening for inclusion in the Star Ratings. Expected changes to measure specifications or calculations: Osteoporosis Management in Women who had a Fracture (Part C) Treatment with estrogen may be removed, an upper age limit may be added, and dementia may be excluded. Monitoring Physical Activity (Part C) The HOS questions may be revised to include an outcome indicator that assesses whether patients increased their level of physical activity. Plan All-Cause Readmissions (Part C) Two changes possible: 1) excluding planned readmissions 2) removing current exclusion from the denominator for hospitalizations with a discharge date in the 30 days prior to the Index Admission Date. Improving Bladder Control (Part C) HOS questions will be revised for the 2015 data collection. As such, data will not be available for this measure for the 2016 and 2017 Star Ratings. 4
5 News From Plan Makes Timely Decisions about Appeals (Part C) CMS is revising the procedures relative to appeal dismissals beginning in January Appeals Upheld (Part D) CMS will modify this measure from using the current 6-month snapshot to use the same 12-month measurement period as the Part D Appeals Auto-forward measure. Adherence (DM and Hypertension) and Diabetes Treatment (Part D) Change to exclude End-Stage Renal Disease (ESRD) patients from the denominator of these measures Complaints about the Health/Drug Plan (CTM) (Part C and D) For 2016 Star Ratings, CMS will modify the CTM measurement period from 6 months of the current contract year to 12 months of the prior contract year. MPF Accuracy (Part D) The restriction on PDE claims from retail pharmacies that are also reported by sponsors as being long term care, mail order, or home infusion pharmacies will be reevaluated. Claims for 30, 60, and 90-day supplies will also be evaluated. CAHPS measures (Part C and D) CMS proposes to slightly modify the CAHPS methodology when the pre-determined 4-star thresholds are dropped to permit reliability contracts to receive 5 stars or 1 star depending on standard errors of their base stars. Measurement concepts CMS welcomes comment and input on additional measures and methodological enhancements, including levels of measurement analysis, care coordination, care transitions, patient reported outcomes, conditionspecific measures, member dissatisfaction, SNP-specific measures, methods to recognize improvement by low performing contracts, and the feasibility of replicating HEDIS measures by using FFS administrative data. 5
6 News From About is a full-service healthcare improvement organization providing healthcare surveys, call center services, and performance improvement tools and consultation. The company is an NCQA-certified survey provider for the CAHPS, CAHPS PCMH, and Medicare HOS survey, and a CMS-approved Medicare CAHPS and CAHPS for ACOs survey provider. has been a leader in healthcare solutions since We are dedicated to serving the healthcare community with tools and resources for improving quality and patient care. Regulatory Surveys Complete management of survey requirements Certified NCQA and CMS Approved Vendor In-depth, actionable reporting and analysis Trusted experience for the best results TMG Connect - Call Center Services Advanced call center support services Enhanced member outreach/engagement Full-service onsite, US-based call center Expertise in managing regulatory requirements Insight Surveys Comprehensive line of tested, reliable surveys Valuable, in-depth insight and feedback Customization and Flexibility Experts in survey design and execution Performance Improvement Consulting Star/Scores Improvement Experienced guidance and action planning Recommendations for quality improvement Understanding survey results and implications Copyright
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