2023 Final Rule: Last Minute Adjustments to Prepare for Stars Success


Just when you thought the remaining part of 2022 would bring stability in health care, CMS released the 2023 Medicare Advantage and Part D Final Rule. This administration is making it clear they are serious about creating structural and long-lasting change in Medicare Advantage (MA) to expand access to equitable, safe, and affordable care to ALL members.

But before you jump ahead to tackle these big changes—as well as the updates provided in the 2023 Final Rate Announcement—it is important to take a step back to understand the gravity of this regulatory update when preparing your strategies for Stars success.

Take a Second Look at Your Bid Submission

While the deadline for bid submissions, June 6, 2022, is quickly approaching, do not submit your bid just yet. Instead, use this last month to recheck, review, and revamp your 2023 bid submissions and plan designs through the lens of how these changes impact Star Ratings, Part D and Medication Adherence strategies (both at the network and beneficiary cost-sharing level), and members’ experience with your plan.

Prioritize Member Needs

Challenge the traditional cost cutting techniques to strike the right balance with the upcoming changes, financial solvency, and the specific needs of your membership to achieve the best possible outcomes. This is EXTREMELY important for plans with future growth strategies that may be at risk to fall to a 2.5 in either the Part C or D summary in SY2023.

Keep the New Past Performance Criteria Top of Mind

The 2023 CMS Final Rule clarifies that past performance, in a variety of areas, must be included in applications for new MA or service area expansions contracts. Plans will be evaluated on network adequacy, bankruptcy filings, medical loss ratio (MLR) reporting, and Star Ratings. CMS will now deny applications if plans have any combination of either a Part C Summary Rating, Part D Summary Rating, or overall Star Rating of 2.5 or less in the last 2 years.

Review and recheck your Stars Math to ensure any planned 2023 market expansions/entries do not taint your summary ratings.

This is your last chance to double and triple check you are set up for Stars success in 2023!

Given the significant impact of the Final Rule on Stars work plans, determining the right approach requires an in-depth understanding of the how these regulatory changes will your impact operations, budgets, and strategies—which is where our team can provide valuable insights. Every member of our team has weathered seasons of significant change, and established strategies for 4+ star success even during the most tumultuous periods of industry change. If you need help, please contact me at for more information.


Kimberly is a healthcare expert with more than 15 years of experience advising health plans through her robust knowledge of quality improvement solutions. Utilizing her strategic insights into HEDIS scores, NCQA measures, Star Ratings, Health Equity, population health management, and member satisfaction, Kimberly develops innovative strategies for connecting patients to care and improving plan performance for her clients. Kimberly has completed a Foundations of Health Equity Research certification through John Hopkins University.
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