We've put together a summary of the proposed changes to Star Ratings contained in the Advance Notice. Download it below.
3 Things to Know About CMS Proposed Changes
Most of the proposals catching the headlines and attention will require several years to come to fruition. However, buried within the sea of longer-term ‘Star Ratings moon shots’ are several much more likely immediate changes with surprising impact in 2022 and 2023.
The less glamorous looking proposals to add the Beneficiary Access and Performance Problems (BAPP) measure back to Stars amidst an era of aggressive compliance oversight and to accelerate the transition of the Colorectal Cancer Screening measure to Electronic Clinical Data Systems (ECDS) have immediate, significant operational consequences that will catch many plans off guard this year.
This administration is functioning similarly to the Obama administration, in which CMS repeatedly adjusted Star Ratings measures and methodology on a far faster timeline (often after the fact!) than the Trump administration’s industry-friendly rulemaking approach created. Plans should not automatically assume that changes will be as slow-rolled as they were under the previous administration and as exacerbated by COVID relief.
3 Things to Do Now for Stars Success
In these proposals, separate “fact” from “fiction.” Leadership attention will undoubtedly focus first on the blue sky headlines, which must be managed. Clearly separate “the art of the possible” from the “art of the more likely,” and carefully evaluate the impact of proposed near-term changes as quickly as possible. Adjust current year initiatives rapidly and enhance internal reporting to mitigate Stars risk associated with these changes.
Accelerate your digital transition. HEDIS measures, as the longest-standing mathematical backbone of high-performing plans’ ratings, continue to be squarely in CMS’ crosshairs. The proposed transition of measures to ECDS in 2022 and 2023 means that measure rates can no longer be controlled internally, require modernized data interoperability and technology-enablement, and require provider focus in new areas for success. Accelerate your digital transition by leveraging technical engagement with members to collect information that will help locate measure compliance evidence of past colonoscopies, and begin acclimating members to web-based CAHPS data collection. It may be unrealistic to assume that the traditional “measure owners” of HEDIS and CAHPS measures will be able to drive rapid success on new measures quickly enough to ensure 2022 success. Consider whether the proposed fast-tracked transition to ECDS and accelerated necessity for whole-person engagement might warrant assigning new owners and executive champions to these new measures. A fresh perspective can help advance the progressive work required this year to achieve rapid success in light of continued change.
Integrate Health Equity into your CAHPS strategy.If you haven’t begun working on health equity, start now. This is a long-play, not an urgent panic, but requires focus, attention, and perhaps most importantly, time to drive improvement. The same cohorts of members that will eventually become the focus of future health equity measures and accountability are the very same members for whom we’ve long deployed in-home services to close traditional HEDIS care gaps, used creative methods to obtain accurate HCC data for, and are, coincidentally, largely the very same members who are now the focus of our CAHPS efforts. Expand 2022 CAHPS efforts to be as detailed as possible using data elements associated with inequitable care (i.e., race, ethnicity, language, dual/LIS status, zip code, etc.) so that our CAHPS work this year can serve as a person-centered foundation for future health equity efforts. Use every member touchpoint to collect members’ race, ethnicity, and language in the nationally-standardized data format. And then, make sure every team is comfortable discussing difficult cultural issues and using specific, detailed demographic data in their CAHPS, risk adjustment, and clinical work to begin CMS’ evolution to use Star Ratings to ensure we are administering equitable care across the base of consumers who trust us to meet their healthcare needs.
We encourage all plans to provide feedback to CMS during the public comment period.
Industry and trade groups will provide generic feedback that may or may not reflect your plan’s preferences and lens on these proposed changes. We encourage you to be open with CMS about the elements of the proposal you support, both directionally and with specificity, and if you have concerns or worries about some of CMS’ proposals, offer insights regarding ways they could adjust or enhance their proposals to make them as effective and palatable for your plan as possible.
We know how hard it is to succeed in Stars in an era of change, when decisions must be made with no safety net, and when both the risks and stakes are high. Every expert on our team has experience working in Stars during the years of significant change in the program and can help you achieve your goals.
Melissa is a well-known thought leader and healthcare strategist with proven success developing enterprise-wide solutions to improve Star Ratings, HEDIS scores, quality performance, health outcomes, and the member experience. As EVP of Healthmine’s advisory division, she helps clients evaluate market dynamics and opportunities, optimize distribution channels, and fulfill strategic planning needs.