With the number of 5-Star plans almost quadrupling in the 2022 Star Ratings, it is an understatement to say that—yet again—the COVID-19 pandemic has created truly unprecedented events. Even in Medicare Advantage (MA)!
74 plans earned a 5-Star rating this year, compared to only 21 last year. These strong ratings unlock the maximum available quality bonus payment and rebates to fund rich benefits for members. More importantly, the normally elusive 5-Star rating allows all of these plans to market their products throughout the entire year in 2022, providing them with a strong local competitive advantage as MA plans seek to attract a strong share of the 10,000 baby boomers aging into Medicare every day.
Almost 70% of all MA plans are now at 4 or more Stars, providing quality bonus payments to almost 90% of all eligible beneficiaries. This means that only 30% of plans are now under 4 Stars, compared to ~50% last year.
Here are 3 more things to know about these ratings:
- The vast amount of COVID relief granted by CMS artificially bolstered the 2022 Star Ratings for many plans. On average, plans eligible for all measures used the “better of” relief available under the Extreme and Uncontrollable Circumstances policy to revert to their actual 2021 rating for 6 of the 38 total measures, introducing artificial inflation on approximately 16% of the overall rating. In some cases, this year’s COVID relief in Star Ratings, combined with last year’s, causes these ratings to reflect performance potentially as far back as 2018, which we know, in many cases, has changed dramatically for some plans and is simply hidden among the regulatory relief for the COVID public health emergency.
- CMS’ last-minute removal of the 3x-weighted HOS measures of Improving or Maintaining Physical Health and Improving or Maintaining Mental Health also unexpectedly increased overall ratings. The average 2021 rating for these two heavily weighted, and consistently challenging, measures was 3.25 stars; thus, their removal also increased the overall 2022 ratings for most plans.
- Only 3 (yes, that is not a typo – 3!) contracts experienced a drop in their ratings. That is simply an astonishingly low incidence—and only possible due to the unprecedented, unusual, one-time COVID relief that is embedded throughout the 2022 ratings.
This strange year of unusually high ratings is likely a one-time anomaly, since the end of the public health emergency, combined with the many imminent technical changes, will change the performance calculus in the 2023 ratings.
Here are 3 things to do once plan leaders relish a few days of joy and celebration of these ratings:
- Get back to it! The work required to get ready for 2022 is as unprecedented as this year’s ratings. Many plans have struggled during the lengthy remote work period to robustly invest in and prepare for the new 2022 measures. With less than 90 days until the new measures take effect (all of which are time sensitive based on events occurring in January), now is the time to accelerate preparations for the three new measures (Transitions of Care, Follow-Up After ED Visit for People with High-Risk Multiple Chronic Conditions, and Plan All-Cause Readmissions) and to finalize preparations for the increased 2022 weight of the Controlling Blood Pressure measure. As more measures are retired by CMS, and with most new measures entering Star Ratings with initial national averages under 3 Stars, there is no room to hide from the impact these new measures will have on the overall rating.
- Get serious about CAHPS. The theme in MA throughout 2021 has been “CAHPS, CAHPS, CAHPS” all across the country. And now is when it really will matter most. As we head towards the new benefit year, make sure to delicately message all unpleasant surprises to members (not just via mail or the ANOC but through direct and meaningful interaction). Avoid shock by messaging negative formulary changes, changes to cost-share or copays, and removal or erosion of benefits. Yes, we know those phone calls and home visits are both hard and expensive to perform. But with the spring 2022 CAHPS survey driving more than 1/3rd of your Star Rating, consider this an investment with a high ROI.
- Objectively scrutinize your 2022 Stars investments and work plan. Most plans have a lot of “baggage” in their Stars work plans from the activities needed in the past that simply will not be necessary or accretive to their overall rating in 2022. Substantially all plans still over-invest in HEDIS®, while just dabbling in CAHPS and new measures. And don’t forget: The new CMS regulations for rewards and incentives (historically largely focused on HEDIS measures) take effect on 1/1/2022 and prohibit the use of HEDIS numerators and denominators for eligibility and disbursement determinations, which is going to require effort to either find and implement new vendors or develop and deploy new analytics quickly to launch the year in compliance. This is the perfect time to revisit incentivized activities to redirect an appropriate portion of membership towards activities other than those measured by HEDIS measures in order to achieve optimal ROI across the full spectrum of your plan’s needs (including Stars, health optimization, and experiences).
It’s Time to Invest in Strong, Sustainable Star Ratings
If you are struggling to find budget to fund the activities you need to perform during the 4th quarter to achieve your Stars goal, here’s one last tidbit to help! CMS sanctions plans who fail to achieve at least 85% MLRs for 3 years. Because 2020’s medical expenses were consistently low due to the pandemic, which has lingered into 2021 for many plans, some will need to increase their investments into quality improvement activities this quarter. If you are struggling to secure needed funding for your Stars program, check with your Finance and Actuarial teams to see if 2021 is on track to hit >85% MLR. If not, and if this is your 3rd year of missing the MLR requirement, remind your leaders that Stars investments (including CAHPS) focused on quality improvement are considered MLR!
We know how hard it is to succeed in Stars amidst an era of change, when decisions must be made with no safety net and when both the risks and stakes of decisions are high. If you need help to ensure success in 2022, call us. We love helping plans achieve and sustain strong ratings. Email me at email@example.com for more information.